PO4: Distribution of Sites for Housing

1. Each prefferred Option appears to have been prepared in isolation and ends up with conflict of purpose between different ones. Whilst full of words there is little to see of the methodology of carrying these proposals out.
2. The Plan renders the whole concept of 'Green Belt' meaningless and the originators should be taken to task. To lose agricultural land to building loses, forever, the potential to produce food for the nation in future. Such acts will come back to haunt us all.
3. The land North of Leamington is also a Local amenity used for recreation and excercise which would disappear forever under the proposals. It is in conflict with other preferred Option statements on the subject.
4. The 'North Leamington Relief Road' will do nothing for traffic, making journeys to main road arteries long and circuitous. This road will add noise and light pollution together with added carbon emissions to a quiet country environment as well as an adverse visual impact. This road crosses a flood plain which will require expensive structural solutions and it risks causing enhanced flooding upstream. The Council will be well aware that historically new roads encourage development up to their boundaries and in this case use up more 'Green Belt'. Perhaps this is an underlying intent for further 'adjustment' to boundaries?
5. If so many people are scheduled to come to Leamington, where is the employment to be found for all these people for whom housing is to be built? The Council seems to be relying on retail. This can only increase the country's imports and send us deeper into debt. Surely the Council does not seek to be a party to that. Is there an intent to be merely a dormitory suburb for manufacturing areas to the north of our boundaries?
6. Employment comes out of industries created by local conditions or indigenous resources. There is no mention of the large coal resources to the south of Leamington. With development of clean coal electricity generation this resource will eventually be needed. In creating employment this will require housing development on land to be found on the south side of the town.
7. Nowhere does the Plan indicate that all the infrastructure will be completed (not just ideas) BEFORE housing development takes place. This is essential if any plan is to work
I find the plan poorly thought out with little substance.

Is pleased to note that the site, which is currently the home of Leamington Cricket Club in Arlington Avenue, is not listed as a "prefered option" for housing development. The location is one of the few, significant sized, green spaces left within Leamington. It is vital that a town, who's reputation has been built on wide, open spaces continues to protect those open spaces that remain, for the health and well-being of the town's residents and visitors.
In addition, such spaces are critical in providing habitat and pathways for fauna which will become more necessary as we see the impact of climate change

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Is pleased to note that the site, which is currently the home of Leamington Cricket Club in Arlington Avenue, is not listed as a "prefered option" for housing development. The location is one of the few, significant sized, green spaces left within Leamington. It is vital that a town, who's reputation has been built on wide, open spaces continues to protect those open spaces that remain, for the health and well-being of the town's residents and visitors.
In addition, such spaces are critical in providing habitat and pathways for fauna which will become more necessary as we see the impact of climate change

The propels to expand the existing built up area, will inevitable affect the local wild life, increase the carbon footprint, and building on such a scale as is proposed could adversely affect the existing water table increasing the possibility of localised flooding..The area already has excellent primary,junior and secondary educational facilities.There are a number of Supermarkets available and more are proposed on brown field sites in Leamington, why not utilise space on those sites for housing developments? the services exist as doe's the public transport network These facilities both over ground and underground would need to be created, the existing Victorian sewage and drainage in the area is constantly under repair and maintenance.

Has there or will there be a Public Consultation on This?
Has the effect of the proposed HS2 High Speed Train project been factored in? (that project alone will have an enormous impact on the local environment)
Doe's the market exist for the proposed private housing element of this project?
Are there enough retail commercial and manufacturing vacancies to absorb a significant increase in the population ?, (local unemployment is still high and with the proposed government cutbacks could increase)
How will the proposal be financed. no PFI ? I hope. where our grandchildren pick up the costs of the former folly of others.
I forward my objections to the proposal to build on green field land North Leamington, further to my comment on the affect on water tables in the area. There have already been incidents of the flooding of properties in Kenilworth Road due to runoff from the open land opposite, the concreting over of large areas in the vicinity could only affect the adjacent water table, and increase the probability of localised flooding.

This is my response to the New Local Plan Preferred Options Consultation

Number of homes
I have read the relevant material on how you calculate that 10,800 new homes will be required in Warwick District over the next 15 years, at a rate of 550 per year. I note that in your consultation questionnaire of 2011 the majority of respondents preferred the option of a lower number of houses per year, fearing overdevelopment and coalescence among other concerns, but it seems these views are being ignored. I would also question the figures predicting a growth in 'high level' and managerial jobs and wonder what and where these jobs are going to be. What jobs are those occupying affordable or low cost housing going to be doing?
Green Belt
The National Planning Policy Framework requires that development on Green Belt land should only be allowed in 'very special circumstances' which Warwick District Council maintains exist here. I would question this and note that you propose to 'alter Green Belt boundaries in line with development sites described'. You acknowledge that 'The Green Belt ... seeks to stop urban sprawl that would harm the open nature and rural character of the open countryside around the towns and the urban areas of the West Midlands', and yet 43% of preferred option sites are on Green Belt land.
In 2009 after substantial investigation and public consultation WDC adopted a development plan, for slightly more homes than the present proposals, which did not require release of Green Belt land. What has changed between 2009 and now? Most noticeably the land to the east of Radford Semele and Grove Farm that was in the 2009 plan has now been removed, in the case of Radford, because of gas pipelines and at Grove Farm because of coalescence with Bishops Tatchbrook. Why is coalescence with Bishops Tachbrook, which is outside the Green Belt, more important than coalescence with Leek Wootton and Kenilworth or the fact that Blackdown will be joined to Leamington? Why has the land at Radford been rejected when the gas pipelines did not pose a barrier to the previous plan?

The results of WDC's Green Belt study which scored Old Milverton and Blackdown highly have been ignored. If Green Belt development is necessary lower scoring land should be used.

Preferred Options and size of developments
According to WDC the Preferred Options have to be, and are apparently, supported by strong evidence. I would like to know what this evidence is.
WDC has presented a preferred plan rather than consulting on options. No options have been presented to the public for consultation. Who has suggested the proposed sites? Has WD carried out its own survey of possible sites, or have all the sites been proposed by developers? Apparently, these sites have become available because landowners wish to sell. Developers are very persistent with their offers to buy land and I'm sure some land owners could easily be persuaded to sell if they stood to make a substantial sum of money.

Some of the proposed developments are huge. 1600 on preferred site 3 would constitute a large village on its own and will merge with site 2, making a total of 2700 houses. This is an enormous development and would require a huge amount of infrastructure. It would not be part of either Warwick or Leamington, but would be a separate community therefore not integrated into either town. Sites 4 and 5 also represent a huge development, much of it on Green Belt.

The Thickthorn development in Kenilworth is also very large at 770 homes for the size of the town. Kenilworth underwent considerable expansion in the 1950s - 1980s; should it be further expanded to such an extent? Also, how was this site decided upon? Much of it is on Green Belt and farmland and includes a nature reserve which would be swallowed up by surrounding houses. It too would not be an integral part of the town. I do not live immediately near it but it does concern me that such a development would be so near the A46, the noise from which we can hear quite clearly from our garden. I don't think building business premises alongside the A46 would lessen the noise much for those living there. A new primary school and other facilities are proposed for this development. Why not build extra houses in some of the villages which could afford to expand and already have schools etc. Leek Wootton is a case in point where the school was once under threat of closure could take an increase in pupils.

Transport
It is estimated that £50,000,000 will be needed to improve roads. Where is this to come from? Regarding the road links between Kenilworth and Leamington, does this mean making the A452 a dual carriageway? This scheme was rejected a few years ago after a successful campaign and the realisation that it was not really needed to alleviate a minor problem of congestion twice a day. It provides a very pleasant green corridor between the two towns and should not be spoilt. Access to and from the Thickthorn development at one end of the A452 and to and from the Blackdown and Lillington developments at the other end would result in a massive increase in traffic. However, a dual carriageway would still lead to congestion at the entrance to either town as it funnelled into a single lane. A dual carriageway linking the A452 with the A46 would cut across a swathe of countryside and spoil the village of Old Milverton.
Communication
I am concerned that many people in Kenilworth are unaware that there has been this consultation period even if they are aware of the Local Plan. It is not enough to assume that everyone reads the local press as many do not, and most people would not be looking at your website unless they were aware of this plan and therefore there was something to look at. There has been some limited information in the library but for most of the time this was tucked away round a corner and I had to ask where it was. I know there have been various meetings but these were not well publicised. The exhibition in Kenilworth Library was staged only a week before the end of the consultation period and again there was little publicity. In the interests of transparency, surely every household should have been leafleted about this very important plan, not just people who had already responded to the questionnaire or registered on your website? I hope the next consultation will be better publicised.
I have other concerns but these are the main ones. Please listen to the views and concerns of the people and don't force this plan on us without giving us alternative options to consider.

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I am writing to express my dismay at the proposals for development on green belt land in North Leamington. I OBJECT STRONGLY to these plans.


It cannot possibly be right to build on beautiful countryside that provides green space for so many people. Once the land has been built on it is lost forever. This does not accord with the National Planning Policy Framework as it cannot be shown that the exceptional circumstances exist which allow green belt land to be built on. Other more suitable areas for development have been identified in South Leamington where, in addition, the infrastrucure is much more suitable for the extra development and there are already plots available for more industrial units and thus employment possibilites for the residents.


Another objection I would like to raise is the danger of Leamington Spa and Kenilworth moving closer and closer due to development beyond the boundaries of each of the towns. At the moment Leamington and Kenilworth are separate towns with different characters and it is normal policy to try and maintain this. This plan for North Leamington coupled with the proposals for South Kenilworth puts the separate identities of the two towns at ever increasing risk.


To conclude, I strongly object to the destruction of the green belt and hope that the Council will reconsider the options and not continue with this unjustified destruction.

I am writing to provide a business perspective on your recent development plans for Warwick District.

As one of the largest local employers, there are a number of issues that we face in employing people to support business growth. One really key point for recruitment, and for existing employees, is the lack of affordable housing close to our factory location at Heathcote Industrial Estate. As a consequence, we have always been anxious that the local areas that you had previously designated for development close to our site would be given the go ahead as part of your new plan.

We are very positive that your plans to build affordable properties are included in the new proposals, but, from a business perspective, we are dismayed that a substantial part of the proposed development is to the North of Leamington away from the business parks & employment. Apart from older workers who have been in the area for many years, most of our work force has to commute from Coventry or Birmingham putting a strain on car parking both on our site and on the roads in the industrial estate.

Almost all the job opportunities in the area are to the south of Leamington/Warwick, unless you include people commuting to other areas. Obviously, one important factor in locating new housing is proximity to jobs. In an ideal world we need to create new developments where people can walk (or cycle) to access local employment opportunities. By locating a substantial part of the development proposed away from the main business areas the people who are attracted to live in this area will be forced to commute to work, creating an unnecessary negative impact on the environment & quality of life. In addition, commuting from the north of the Leam in Leamington to the south, is restricted to 2 bridges, and these routes are already very heavily congested.

I would like to suggest, on behalf of the major employers in this area, that you reconsider your proposals and locate all of the new development to the south of Leamington/Warwick close to the employment opportunities.

I write to formally object to proposals contained in the Local Plan, specifically the Preferred Option as detailed in the proposals published in May 2012.
I have attended two of the public meetings held with representatives of local groups and Council officials; the most recent being the joint Blackdown and Old Milverton Parish Council's meeting held in Old Milverton Parish Church on 16th July 2012.
My first point is that two Council officials made threats against the public at this last meeting on 16th July ; I felt extremely upset that public servants could stand up in a public meeting and do this. Councillor Doody, who appeared erratic and unable to speak coherently, eventually threatened the audience by saying "Don't any of you bother involving / writing to your MP's - it's a waste of time". You will note that I have copied this response to both MP's for the local area and am expecting them to respond on this point.
Further, both Councillors Doody and Hunt continually threatened that if the local residents continued with their opposition to the Preferred Option, and stopped it happening, then Warwick would be left without a Local Plan and the consequence would be "that developers would be building in our back gardens, and everyone would be powerless to stop such development".
What poppycock! I do not take kindly to threats. How dare these people make statements such as these which are clearly incorrect and designed to frighten people. Do they assume we are all idiots? How very sad if so.
Personally, I would rather take my chances and forge ahead without a Local Plan, if this ill thought out Preferred Option is the best that Warwick and their planners can come up with.
I hope that Warwick Councils can justify their "preferred option" proposal. How can they call this democracy? There is no alternative. I expect the justification will be that they had "consulted previously" and "publicised the consultation". Again I say - poppycock! The document on the website entitled "Report of Public Consultation December 2011" contains a wealth of so-called "publications".
I have looked at where these proposals were publicised:
 A press release - I read nothing, I don't use radio much and heard nothing;
 I have seen nothing on either BBC or ITV local news programmes which I watch regularly;
 A public notice in the Courier - I only get the Courier about once a month, and again I saw nothing;
 An article in the Focus magazine which it is stated is delivered to all households in the Spring of 2011 - I have never received a copy of this magazine;
 An advertisement in the Leamington Observer - I have never seen or received a copy of this newspaper;
 An article in "Word on Warwickshire" - aimed at the local business community - I am not in business so have never seen this article;
 Flyers were produced and distributed by the Community Partnership Team at Community Forum events - I have never seen one of these events in Blackdown and therefore never received a flyer.
I contend therefore that this so-called "publicity" did not reach everyone in the district as evidenced above. Further, I have been surveying my own workmates, acquaintances and people working in the local shops and business I use, and 88% of people I have spoken to have no idea about what the Council are planning to do to the area.
Having considered carefully the so-called "Preferred Option" I declare it to be a travesty against the residents of Warwick, Leamington and Kenilworth. When I examined the map outlining the proposed development it all becomes clear. For whatever reason, although I cannot fathom what this reason may be, there is a move to delineate and remove the boundaries between the three towns. I can only assume that this is some ambitious plan by the Council to achieve city status for some sort of conurbation - maybe they feel it would raise the status of the Council in some way. No consideration as to what this will do to this beautiful, historic area!
My second point is that the District Council do not show that they have any proper planning knowledge as they consistently fail to demonstrate how a plan should be implemented. Have they just used a cheap planning consultant? Or bought a toolkit not fit for purpose off the shelf?
Surely, the order of events should be:
 Put infrastructure in place i.e. Fill all currently available commercial / industrial land. Gallaghers in Harbury Lane; IBM (already partly turned into a Premier inn); Warwick Technology Park; The Shires; the Ford site; ensure all fully occupied and that employment requirements are known and taken into consideration before building houses on green belt land!
 Employment - who will come into North Leamington to employ people? Get employers on site first.
 Ensure that proper plans are in place and that funding is available to service the requirements of the new housing you want to build, i.e. that doctors, schools, hospitals, security and emergency services will be available to service the demand before building commences (whilst being mindful that residents of South Leamington were promised schools and other services which have never materialised);
 Ensure that other infrastructure requirements can be delivered - i.e. water supply, sewerage, broadband, telephone, cable services taking into account that North Leamington is very poorly served at the moment (and whilst being mindful that residents of South Leamington who were promised services many years ago still do not have all services promised)
 Avoid costly "white elephant" development such as the Northern Relief Road. Where will the money be coming from to build this? Are developers asking for it to be built and offering to pay for it? If so they must have a reason to do so. Is this because they see enormous profit being dangled in front of them from expensive development of prime green belt land perhaps? And are the Council receiving monies too? I hope that under the Freedom of Information requirements that all of this will be publicised and to more people than this so-called Public Consultation has been.
I would also like the Council to explain why Leamington is being offered as a preferred housing site for workers at the Gateway? Surely there is much more established and needed housing opportunity in Coventry? There appears to be no reason why Leamington should be looking to offer to house more people who will use the amenities provided but will work and shop in Coventry!
I have considered the National Planning Policy Framework Have the Council really studied what the Government are saying in this document? From the meetings I have attended and the Preferred Option document published I find little evidence that this Framework has been interpreted properly.
For example, I cite part of the Framework here, in red, points 79-83 which specifically refer to the protection of the Green Belt, with my comments linking the Framework to the new Local Plan:
Protecting Green Belt land
79. 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. The Local Plan fundamentally opposes this requirement. The keywords are "permanent". What is the point of the permanence if Local Authorities can ride roughshod through the Green Belt when they feel it suits them?
80. Green Belt serves five purposes:
●● to check the unrestricted sprawl of large built-up areas; ok, let's join up Leamington, Kenilworth and Warwick and have a lovely big urban conurbation then. I have already lost sight of the boundaries between Warwick and Leamington!
●● to prevent neighbouring towns merging into one another; ok, let's join up Leamington, Kenilworth and Warwick and have a lovely big urban conurbation then.
The proposals will reduce the" Green Lung" between Leamington/Warwick and Kenilworth to less than 1 1/2 miles encouraging the merger of these three towns and their loss of independent identities.
●● to assist in safeguarding the countryside from encroachment; No need for countryside around here - we'll just build our "garden town" on top of the countryside to fool the residents into thinking we have their best interests at heart;
●● to preserve the setting and special character of historic towns; fundamentally in this case trying to take away the special character. Let's make the town in Leamington a replica of Slough, Swindon or Smethwick - none of the residents will notice!
●● to assist in urban regeneration, by encouraging the recycling of derelictand other urban land.No Warwick DC know better; we've changed our minds again, let's put commercial properties on green belt alongside all of this housing we're going to build. Oh - have we thought through whether existing residents, potential new residents and potential users will want this type of development? Or is it the developers that the Local Authority are trying to please?
81. Once Green Belts have been defined, local planning authorities should planpositively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Again, the Local Authority want to put dual carriageway roads where playing fields currently exist. Nice for the children to have to play football yards away from a dual carriageway.
82. The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. If proposing a new Green Belt, local planning authorities should:
●● demonstrate why normal planning and development management policies would not be adequate; with other land readily available outside of the Green Belt, this is a major failing in the Local Plan;
●● set out whether any major changes in circumstances have made the adoption of this exceptional measure necessary; nothing major has changed in Warwick - even the data the Local Authority are using to base their plans on has been proved to be flawed; there is no proven requirement for the additional housing we allegedly need;
●● show what the consequences of the proposal would be for sustainable development; this Local Plan does not show the consequences in an adequate manner;
●● demonstrate the necessity for the Green Belt and its consistency with Local Plans for adjoining areas; all this demonstrates is that the Local Plan for Warwick wilfully ignores Government guidlelines as outlined in the National Planning Policy Framework;
●● show how the Green Belt would meet the other objectives of the Framework. Unfortunately the Local Plan for Warwick does not demonstrate this adequately and largely appears to have been ignored.
83. Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established,
Green Belt boundaries should only be altered in exceptional circumstances - The Green Belt is already established in Warwick, and I contend that there are no exceptional circumstances to change these boundaries now.
The National Planning Policy Framework also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built. Again, I contend that there are no exceptional circumstances to change these boundaries now.
I also find that the Core Strategy plan adopted by Warwick District Council in 2009, just three years ago, identified land to the south of Leamington which is not in Green Belt and is still available, for development. The assessment performed, just three years ago, by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who would live there. It is close to the M40 and there are existing employment opportunities in the commercial areas; there are commercial development areas already in place to the south of Leamington as well as existing out of town shopping facilities and good access to the town centres.
Therefore, the previous 2009 Core Strategy plan is direct evidence that there are alternative areas for development other than the Green Belt and that the "exceptional and special circumstances" put forward by Warwick District Council are flawed and substantially wrong.
Warwick District Council argues that the land to the south of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.
In addition, The Local Plan proposals ignore Warwick District Council's own earlier study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value. Again, I ask why the Local Authority are permitted to choose their own path when it suits them to do so, and to change their minds every couple of years, without any firm foundation to do so.
I am incensed at the way Warwick DC are behaving.
Following the (albeit limited) responses to the poorly publicised public consultation held last year, I read that:
"Many respondents considered that there is a need to retain green belt land by using brownfield sites within the existing built-up areas of towns for new development and greenfield sites adjacent to the District's villages. Increasing the sprawl around the existing built-up areas would damage the rural setting of the towns to the detriment of both their economies and their environment. New developments can damage the natural environment and destroy tracts of countryside with consequential loss of habitat for wildlife which cannot be replaced and results in fragmentation. Additionally those green field spaces that have special landscape qualities should be retained. It is important to retain the balance between important towns and beautiful countryside."
It is clear that by adopting the Preferred Option now, no account has been taken of feedback from residents of the area.
I would now raise some additional specific points:
The approach to Leamington from the North takes the traveller through beautiful green countryside, past the historic beauty of Kenilworth Castle, through the town of Kenilworth and along the A452, bordered by beautiful greenery until the town of Leamington appears along the verge of Kenilworth Road. This introduction to the town ensures that visitors and residents alike know that they are approaching and when they have now arrived in a very special place.
Some 15 years ago, a plan was mooted to widen this A452 road into a dual carriageway. Planning professionals of the day threw the plan out of the window. This was because they recognised that traffic flowing along this dual carriageway would, at either end of it, spill out into a town centre. It is blindingly obvious that nothing has changed! All that will happen is that both heavy slow moving and lighter fast moving traffic will end up queuing to navigate either Kenilworth or Leamington town centres, neither of which will be able to cope with any additional traffic. So, all that will happen is that both town centres will snarl up; the current brief rush hour delays on the A452 will be recognised as a minor inconvenience, and commuters and shoppers alike will clog up the towns - that is, until those not forced to go into town decide that the town centres are just not worth the hassle and it is time to shop in Coventry, Solihull or Birmingham in preference to the local traffic jams. Hardly a solution!
I live on the A452. Traffic observance tells me that the majority of traffic flows from North to South, i.e. shoppers and workers wishing to get to Leamington Town centre. A dual carriageway here would therefore serve no purpose until the new residents move in, and then they might use it to avoid the inevitable town centre congestion, and depending upon where they are employed they may wish to access the A46 to travel to employment and shopping trips away from Leamington. It is also fair to say that widening of this road is certainly not required at the moment as there is only very temporary congestion during peak hours, and certainly when compared to congestion in city centres is merely a slight inconvenience.
In addition, 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 Local Authority appear to have ignored the fact that there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road". To my mind this constitutes unassailable proof that Developers are dictating the path the Local Authority will be taking. Leamington thrives as a shopping centre for the very reason that it contains a goodly number of small independent retailers. When the consumer visits Leamington, it appears pretty, and very different to the vast majority of conurbation towns which have "standardised" high streets. If the shopper wants to see identical shops they will either travel to other neighbouring towns which house all of the run-of-the-mill shops. Should the vision for Leamington be to create yet another "Slough, Swindon or Smethwick" I for one will shop elsewhere. And, let's face it, there are plenty of character filled towns within fairly easy reach. We are at the gateway to the Cotswolds for example.
The next point is that this road improvement scheme is really being extolled to try to justify the arrival of heavy lorries delivering heavy loads into huge shops in the centre of Leamington.
 The lorries will travel a mile or so down a dual carriageway and will then be bottlenecked into narrow road approaches to the Town Centre;
 Parking will be restricted and to ease these problems it is proposed to introduce a "Park & Ride scheme" - I suggest that a visit is paid to the scheme now operating in Stratford to see how successful (or not) that is!
 The large shops are not going to be profitable in the town here, people shop in Leamington for different reasons. Why go to a Town centre, with difficulty, when you can visit an out of town mall with relative ease, park for free, eat and shop at one location. A "no-brainer"
 New Housing in Kenilworth would have direct access to the A46. Unless travelling into Leamington Town Centre, they have alternative access to South Leamington, already in place.
 Heavy vehicles making deliveries currently use the A46 and/or M40 routes to easily place themselves into South Leamington. This infrastructure is already in place.
 The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live. Further "out of town" shopping will take trade away from the Towns. Would the charming small shops in Leamington survive if huge retailers were encouraged to set up shop in Leamington Town Centre? Look at the empty high streets across Britain for your answer.
 Pedestrian and car accidents will increase. This is a given with the increase in traffic, increase in speed and increase in housing. Is the A&E provision including ambulance response teams available to cope with the additional demand for services?
Regarding the Northern Relief Road, (at a cost, I understand of £28m)- I understand that Britain, its' Government, Councils and, not least, the great British Public are all undergoing a period of austerity. Be accountable - tell us where the money is being found to build this potential white elephant? Or is it being built to keep HS2 company perhaps?
It appears and not for the first time, that Warwick Councils, both District and County, believe themselves to be above the law, outside or above the Government regulations, guidelines and recommendations. Spend what they like! Is this money going to magically appear from developers? Or are developers just bribing Council officials by promising infrastructure which is never delivered? Where are the schools promised for Warwick Gates? Oddly enough, just like the road improvements in Balsall Common promised more than 8 years ago - nothing has materialised! Just how far do the Council think that residents' patience can be stretched? I would suggest we are at breaking point now.
Planners must recognise that widening the A452 and cutting a swathe through prime agricultural land to build the Northern Relief Road will not achieve improvement. There was a reason not to widen the A452 some years ago, and nothing has changed.
No referral to the Local Transport Plan is made. I specifically quote from the Final LTP: "There is a well established Green Belt surrounding the urban areas, which is protected by its definition within the Warwick District Local Plan. The Local Plan is currently being reviewed, but it is anticipated that similar levels of protection will continue to be applied. " I reiterate - what has changed?
If it were allowed to proceed, the proposed Local Plan would deprive residents and tourists of recreational facilities. Currently, many walkers, runners, riders, cyclists, ramblers and dog walkers enjoy the countryside. The beautiful countryside is used by residents of all three towns as it is so
accessible to their residents. This would therefore have a major impact on residents, which can never be replaced by green wedges or town parks. This could under no circumstances enhance its value to the community.
Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington and Kenilworth. I act as Treasurer of the Old Milverton Show, which is now in it's 115th year. The continued success of the Show is based upon the fact that this is staged in a village, by villagers, for the residents of the village and extended beyond. There is value in retaining tradition, and it is obvious that residents of Warwick want this to continue.
There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton - just at the time when the Government are promising to retain good agricultural land as a priority. Why not in Warwick? Are planners unaware of the Government promises?
At the meeting, residents were informed when questioning the LA calculations, that an additional 1,400 homes have been included in the plans as a contingency. If this contingency were removed from the Local Plan, then it is obvious that the Green Belt could be maintained as it is. Why is this fact not recognised? The other point that has been made on several occasions by the Councillors is that "we want to spread the pain". What sort of answer is that to give to a community? Why should residents any where have to have any pain? Is this what we are to expect if we want to stay in the land of our birth? Or should we just all move overseas and leave it to newcomers to infill and ruin Britain as they see fit?
 The Green Belt policy aims to check unrestricted sprawl. This proposed development does exactly the opposite of this. This area is already in danger of what I understand is known as "creeping development" and a step back to look at the bigger picture is necessary as this particular area has, I believe, suffered enough.
 A further aim is to safeguard the countryside from encroachment and to preserve the setting and special character of historic towns. This proposed development does exactly the opposite.
 The policy aims to assist in urban regeneration. This is not an urban landscape here and does not need to be regenerated.
On the basis of the above, I would ask that you reconsider your Preferred Option and remove the parts of it which sacrifices Old Milverton and Blackdown to cash rich developers. If the Plan continues in its' current form, you will have perpetuated a great disservice to the residents of our local area and you will blight properties in the district for all time. Remember that once you do this, it can never be reversed, and residents of the new Warton, or Leamwick (or whatever the new, grey city is called) will remember you, their public servants, for all time, for all of the wrong reasons.

See attached

Scanned Representations

The plan is flawed. It contains housing and infrastructure proposals far beyond requirements and ignores utilising existing brownfield sites.

To even contemplate using prime agricultural, green belt, land to the north of Leamington is scandalous.

I am totally opposed to these proposals and ask again that you seriously consider the alternative strategy, I have proposed.

See attachment

I am quite taken aback by WDC's statement in Para 2.1 of the Local Plan Preferred Options. WDC states that the Council's vision for the Warwick District .... "is to make Warwick District a Great Place to Live, Work and Visit."

There are and have been a great many local people who belong to respected societies, who range from all political persuasions (or none) or who are just hard working individuals who have made this locality what it is today - a really good place to live, work and visit. WDC can continue the work in this vein and I hope it does, but it would be more fitting in a document of this kind for WDC to acknowledge the dedication and effort to date of such people and not to give the impression that our District is not at this moment something other than a really good place to live, work and visit.

WDC please restructure this paragraph.

1. Quoting from the LOCALPLAN: "Introduction:
"Our approach can be summarized as one which:
"Plans positively for growth and meets the District's housing need by allocating areas of land for new mixed developments.
"Supports the future vitality and sustainability of villages by including development sites in or adjacent to some villages and relaxing some of the current restrictions on development in villages." End of Quote.

Comment: Yes, but WDC doesn't mention the Localism Act. If WDC has Preferred Options then by law I understand that it now has to obtain buy-in from elected representatives, residents and voters.

PO4 ...Quote: "The Council will work with developers...."
Comment: Under the Localism Act, the council, the elected representatives, the residents and the voters will all work with the developers if that is the consensus between the council, the elected representatives, residents and voters. This must mean no more "behind closed door" meetings or secrecy.

PO9...Start of quote: "Our Preferred Option is to incorporate retail and town centre policies to:
** Apply the 'town centres first' message at the heart of Government retail policy advice that will be central to promoting the vitality and viability of the district's town centres. Town centres will be the focus for retail development and the Council will plan positively for their growth and development in accordance with their particular role within the network of town and local centres;
Support the addition of a major retail -led development scheme in Leamington Town Centre, in accordance with the identified need/evidence within the retail study" End of quote.

Comment: WDC may still support this, but after discussion with residents and voters, district councillors decided not to support Application W10/0340 re Clarendon Arcade. The legitimate planning reasons for refusing the Application, given in a written statement to the Applicants, are clear and on record. This was before the Localism Act became law. WDC must observe that any decision taken from now on is to be as a result of a consensus between themselves, the elected representatives, the residents and the voters. Furthermore, should any rivaling scheme, however small or diverse, gain the "majority" support from the elected representatives, residents, voters and WDC, then that scheme must now by law prevail.
During the public discussion on W10/0340 (2007-2011), under the questionable heading of "public consultation", there was very little support and much opposition to that scheme but WDC went ahead regardless. It was due to the good sense of the elected representatives that the scheme was rejected in November 2010. Well over 200 people lodged their formal objections to WDC. There were but four or five letters in favour. A similar proportion of Leamington Courier readers wrote in to express their objections to the scheme. The first survey by Wilson Bowden in the Royal Prior Shopping Centre in 2007 demonstrated that some 40 people wanted more shops. However, 200 others in that survey did not express such a desire. Yet this survey result has been used on a number of occasions to provide justification for the scheme and more shops. There are now more empty shops in Leamington in 2012 than there were people who wanted more shops in 2007.

PO11
Quote: "Reviewing of the Conservation areas"
Comment: It is to be expected that all such matters are to be discussed with elected representatives, residents and voters under the framework of the Localism Act. Further, I would prefer that specific parts of the existing / previous Local Plan be carried over verbatim to the new Local Plan as follows (notwithstanding the welcomed comments in section 11 in the LOCALPLAN Preferred Options Complete with....):
1. A development will not be permitted which has an unacceptable adverse impact on the amenity of nearby users and residents such as loss of privacy, loss of sunlight and daylight and noise disturbance.
2. A development will only be permitted which protects important natural features and positively contributes to the character and quality of its existing environment
3. Developments will help to support the objective of reducing dependence on the private car, avoid excessive levels of car parking and increase the patronage of public transport and encourage walking and cycling.
The rules 1 to 3 above are preferred because of their (relatively) unambiguous meanings. There doesn't appear to be a good reason to deviate from the previous plan which seems to have protected our town's heritage quite successfully during the past 20 years.
2. Comment on LOCALPLAN Preferred Options Complete with....
Paragraph 4.11, first section, 4. Quote:" 4. Make sure that new developments are in place that will reduce the need for people to use there cars. This will improve air quality and help address climate change by reducing road congestion and carbon emissions, and will encourage people to live more healthy lifestyles by walking and cycling more." End of quote.
Comment on the above quote: BRAVO!
Final Comments: I do not find the Preferred Option Executive Summary acceptable in so far as it fails to mention the Localism Act. WDC is well aware that this new Act has an objective to genuinely involve all the interested parties in local issues, the interested parties being (to repeat): the elected representatives, the residents, the voters and the District Council (or its equivalent).
The Localism Act is referred to only in Para 5.12. of "LOCALPLAN Preferred Options Complete with....", but mainly only that part of it concerned with the removal of the regional layer of strategic planning. Thank you WDC for acknowledging one part of the other main purpose of the Act and for pledging in this Para 5.12 that the "Council will, however be consulting neighbouring authorities on its proposals".
For clarity, I would like to see contained in the final agreed Local Plan an independently prepared précis of the Localism Act 2012 and what effect it may have in local decision making.
It would be good also for WDC to provide a detailed explanation of what is meant by "sustainable" in the contexts in which it uses it. The effort made in Para 12.28 on this is appreciated.

Comments on Draft Infrastructure Plan re Leamington Fire Station.

There has been considerable public discussion recently on the possible relocation of Leamington Fire Station from Warwick Street. I would like to see a commitment in the Local Plan for the retention of Leamington Fire Station at its present Warwick Street site
The "Local Plan Preferred Options" seems to be advocating growth in such a way that growth may become inevitable. WDC envisage an increase in traffic between 6% and 13% for each of the four home growth areas identified in Para 3.1.2 or a compound traffic growth of 40% if they are all developed as outlined. Is it conceivable that satellite crews from out of town fire stations, struggling with appliances through our narrow streets during the rush hour against a 40% increase in traffic density over current levels, might just fail to reach the town centre in time to prevent our wonderful Regency style heritage from being razed?
In Para 4.6.17, it is reported that the Fire and Rescue Service acknowledges that although new development can impact on the level of risk, there is no direct relationship between an increase in population and an increase in risk. This curious and counter-intuitive denial (from whom it is not clear) then turns into a warning: An increase in traffic congestion could impact the ability of existing stations to meet standards of cover. Here we have a preferred plan which predicts an increase in traffic density of up to 40% and a proposition in Para 4.6.18 to remove the Fire Station to a satellite location.
Under the powers of the Localism Act, I would urge our elected representatives, the Leamington residents and the voters to press WDC for our Town's Fire Station to be retained at its present location. Perhaps WDC could resolve not to relocate our Fire Station?

In my opinion, without further explanation, the Para 3.1.24 (on innovative but undefined ways to overcome traffic problems) lacks credibility. Perhaps further explanation could be provided in the Plan? Any explanation may be crucial to the case for a re-location of our Fire Station.

See attachments for full text of representations.

Providing sustainable levels of growth :
The levels of growth envisioned are not sustainable- in that the level of infrastructure, its
distribution, housing location and jobs, do not match the population growth forecast.
A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause
immense damage to the the character of the County Town
Level of Population Growth and demand for housing assumptions:
These are flawed because:
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?
* Housing demand growth in England is from a combination of net immigration and
changes in household demographics towards smaller households.
* However the impact of a prolonged recession which the Prime Minister says could last
another decade, will impact on the ability of individuals to afford housing.
* This is manifest in the rapidly rising age of first time buyers and the profound
demographic change since 2008 in more young adults living at home with their parents
for much longer than in the past.
* So why is the plan still assuming a rapid increase in demand for single occupancy
households; when the actual demographic trend is away from this?
* Is the modelling based on current data, or is it simply looking at the demand during the
decade of rapid growth and easy availability of mortgage loans pre the 2008 crash?
* This in turn could mean that in fact far less individual units are required for the District
as a whole, but a greater emphasis should be given for multi generational living , with
semi independent adults?
Distribution of housing within the District
The plan talks about the need to distribute housing across the entire District , but then in fact does
not do this!
A starting point should be that EVERY ward has the same level of housing growth during the plan,
i.e. A 20% across the board increase.
* It appears that most housing will be again concentrated within Warwick and parts of
Leamington Spa, with very little in the large villages or in Kenilworth
* This is curious, as it also points out the lack of affordable rural housing but then basically
ignores any provision for it!
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* The inexplicable lack of housing growth in and around Kenilworth is most odd given that the
job growth is likely to be around the University and Coventry Airport, and the town already
has a lot of facilities.
* 830 houses over 15 years in the villages is clearly inadequate to meet their housing needs
or the lack of affordable housing, this is only 55 houses per year spread across a wide
geographical area.
* I suggest as a minimum 2500 of the 10800 houses in the plan be developed in the
village areas spread evenly across the district.
* This provision WOULD meet the need for affordable rural housing projected, at 55
per year if 33% was "affordable".
I suggest two areas which have been overlooked for large scale housing provision are Radford
Semile and Lapworth.
* Both are ripe for large scale "garden suburbs", supported by business parks. This would
support and make more viable their existing shops and schools.
* I suggest that at least an additional 1000 to 1500 houses are considered for each ward, and
therefore the significant benefits of population growth extolled by this plan are met, coupled
with local affordable housing and retail provision
* I note they both have existing primary schools, and good proximity to public transport and
roads, and Lapworth has a commuter railway station.
* There is also the opportunity in Lapworth to build a business park to tap into the proximity
to Solihull and at Radford Semile to build a business park dedicated to engineering to tap
into the expertise and supply chain associated with Ricardos.
* This in turn would mean much smaller developments around Milverton and Warwick would
therefore by required.
Transport
For the plan to be actually sustainable, there needs to be a lot more vision for integrated public
transport.
Cycle ways:
It would be a good objective to work with the County Council to ensure that EVERY community is
served by a dedicated cycle way, especially within the urban areas, where short lengths of cycle
way often just stop.
This should be funded by developers of the new housing as a priority via the Community
Infrastructure Levy
Commuter Rail and Bus Routes:
The plan envisions much new low cost housing, yet this is concentrated mainly around Warwick,
and the new job provision is in the north of the District.
HOW are those in low paid jobs who will presumably be the beneficiaries of the "low cost" housing,
be able to commute to where the jobs are if they cannot afford their own cars?
For the plan to be sustainable surely it would be better to have more smaller housing
developments within walking/ cycle distance of the new job provision; i.e. small estates near small
business parks?
* IF this is not possible a commitment to provide and subsidise long distance inter nodal
commuter bus routes is essential.
* Low paid workers will need to be able to commute quickly and cheaply to where the jobs
actually are!?
* This can be achieved, by developing inter town express bus routes to link together;
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Warwick, Leamington, Stratford, Coventry, The University, Nuneaton, Rugby, Kenilworth
and the larger villages; integrated with mini bus services which will THEN serve the local
housing areas. Funded by the Community Infrastructure Levy.
* NOT the farcical situation as now when it take between 90 and 120 minutes each way to
get between towns , which IF a direct town centre to town centre route could be achieved in
20 -30 minutes, (existing buses take very circular routes).
* This lack of effective public commuter transport compounds inequality and creates greater
dependency on state subsidies, as those able and willing to work cannot afford the
transport to get to the jobs, and the bus services are simply too slow and too infrequent to
be a viable alternative.
* Similarly regular local new commuter train services linking together ALL the major
Warwickshire Towns and Coventry should be a priority, funded by the Community
Infrastructure Levy,.
* The "virtual" park and ride scheme, seems like a lot of hot air political spin. Does it
effectively mean NO park and ride , but a slightly extended bus route?
Air Pollution
Parts of WDC already do not meet the Nox emissions EU Directive, including large parts of the
centre of Warwick.
This is likely to be tightened up in the near future with harder targets and lower permissible
emissions, possibly wit fines for non compliance.
It therefore seems curious 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?
Historic Distinctiveness
* I believe the plan should do more to promote good design in housing.
* It is should also seek to unambiguously protect the historic buildings in the area and their
settings, as this is one of the major "draw" factors for population growth and economic
vitality
* The plan has some very vague and bland statements, it needs a clearly articulated
"heritage vision", backed up with detailed planning guidance and then an appetite for
rigorous enforcement.
* Our towns are special, BUT only if the key historic and architectural elements and values
are protected, otherwise they risk becoming a sprawling new town reminiscent of Milton
Keynes.
* The existing open spaces, sports fields, allotments and parklands should unambigiously be
protected from development, including their settings.
Definitions of affordable Housing
I suggest that the definition of what is affordable housing needs broadening.
The plan highlights the need for housing for the elderly and the growth of the elderly as a % of the
population.
One solution to their needs and the obvious trends in semi independent adults living much longer
with their parents because they cannot afford to get on the housing ladder, would be to classify
"granny flats" or semi separated apartments within houses as going towards the "affordable
housing" targets.
Multigenerational living should be encouraged as it meets housing need, is sustainable and reflects
changing land-use patterns. There is the opportunity to boost this by incorporating it into the plan's
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housing targets and helps meet the need for "mixed" housing.
Gypsy Site:
I suggest the land adjacent to the Junc 15 of the M40 might be a suitable site.
There is little nearby existing housing, but a public bus service and good road access
Employment Land
I support the use of green belt land to expand employment opportunities on well designed business
parks at Stoneleigh and around the University. BUT there must be good public transport links to
allow potential workers to access these jobs from the existing WDC Urban areas.
HS2
HS2 could open up significant advantages for the West Midlands by improving links to London &
Heathrow, but more importantly Northern English cities and direct rail links with northern Europe.
I support HS2 and would suggest that rather than opposing a strategic transport plan which cannot
be blocked by WDC due to existing legislation, the Council concentrates in obtaining maximum
benefit for the District, by getting subsidies for improving the transport links to meet the HS2
stations.
Conservation Areas and Historic Environment
* WDC must commit to protecting the existing listed buildings, open public spaces and
conservation areas, from encroachment by development.
* Particularly as most development needs - as defined by this plan-will be met by building on
greenfield and brown field sites, there is therefore less pressure to damage the existing
historic town buildings?
* I suggest the English Heritage Guidance published in May 2011 in "Seeing History in the
View" should be incorporated into the plan.
Climate Change
Flooding and SUDS. Given the recent patterns of heavy rainfall and the long history of local
flooding, great care should be given to the sitting of all new developments.
Claims of 1000 year flood modelling should be treated with extreme scepticism as reliable data
only exists for the past 90 years.
Especially in existing urban areas a conservative approach should be given to any large new
buildings and their impact on surface water drainage.
Consideration should be given to more local flood defences and helping individuals to flood proof
their homes.
Fear of Crime
* No sex clubs or night clubs should be allowed near housing- they should only be built in
non residential areas.
* No new pubs, bars or hotels should be built or change of use in areas of predominately
residential nature, to protect existing residential amenity.
* There should be the presumption that in residential areas new businesses will not increase
the background ambient noise levels. If this cannot be achieved these businesses should
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be located in designated areas such as retail or business parks.
Good Design:
The plan highlights good design and sustainability, this should be supported but defined
All new housing should be built to Parker Morris standards
http://www.singleaspect.org.uk/pm/index.php
* These standards are based on ergonomics of the minimum space needed to meet "a
functional approach to determining space standards in the home by considering
what furniture was needed in rooms, the space needed to use the furniture and move
around it, and the space needed for normal, household activities."
As these were the minimum set for UK 1961 social housing it is not unreasonable that they should
be the very minimum acceptable in WDC for the next 15 years. OR we run the risk of creating
housing that CANNOT meet the needs of the occupants and risks becoming dysfunctional or
slums, which by definition is hardly "sustainable".
Public Space:
Existing open space, sports and recreational buildings and land, including playing fields, should
not be built on !
Any new developments should have additional public space.
Tourism
* Any new visitor accommodation -over a small number of bedrooms- should be examined to
see if it would have a negative impact on the existing providers locally as a material
planning consideration.
* Small independent providers of accommodation tend to support far more local jobs and
have a bigger local economic impact by their use of local suppliers.
* It is desirable to have a diversity in type and location of accommodation providers.
* New budget chain hotels which have a similar impact on existing hotels and guest houses,
to that of supermarkets on independent retail traders. They should only be permitted where
it can be demonstrated there is an unmet demand or capacity need. And there will not be a
detrimental impact on existing buisnesses.
Green Wedges
This seems to be a meaningless concept.

Thank you for giving the NFU West Midlands Region the opportunity to comment on the Preferred Options Consultation. The NFU is a professional body which represents the interests of 75% of all farmers and growers. Our views are on behalf of the farming and land management sector in general and follow discussion with local members.

It would be appropriate by way of an introduction to offer a few general remarks on farming and the planning system. Clearly food security is a key concern. On a global level it is of absolute importance that the world is able to feed itself; but it is equally important that food is produced in Warwickshire in order to meet our own needs.

The challenge in the 21st century is to increase productivity, maximise output, minimise inputs, achieve environmental sustainability and adapt to a changing climate - all of these challenges are ones which British agriculture is very well placed to meet. It is therefore vital that the planning system helps to ensure that farms can evolve and utilise best environmental practice in order to improve efficiencies and reduce carbon emissions. Our detailed comments on the consultation paper are set out below.

PO3 Broad Location of Growth
The NFU is very supportive of the policy of distributing growth across the District as it will facilitate some growth in smaller rural settlements in order that they remain viable and sustainable. We also welcome the assessment of the Green Belt. It is important to review the situation as the pressures and priorities for development do change. Altering the boundaries and removing some areas could have a positive knock on impact on the agricultural businesses located in these areas. It will give them more opportunities to evolve their businesses in order to remain viable into the future. We would like to enquire why the land south of Harbury Lane, Bishops Tachbrook has been designated greenbelt, as this will constrain the farmers business.

PO4 Distribution of Sites for Housing
We have not made a detailed examination of all the locations outlined in PO4. However, where sites are allocated for development the proximity of the land to existing agricultural business must be examined. Sites should not be allocated for residential development if they are found to be in near proximity to for example an existing livestock unit. We are keen to ensure that development in the countryside does not result in conflict between new residents and existing farm businesses.

The NFU welcomes the support in PO4.D. for rural workers dwellings and the conversion of rural buildings on the edge of settlements. When new dwellings are constructed for farm businesses it is important to ensure that they are able to cope with a range of functions. For example they will almost certainly require adequate space for a farm office and boot room. It is important to note that farming families do not have the option of moving house if they should outgrow their home and this must be recognised when planning new accommodation.

The reuse of redundant rural buildings is a key concern for NFU members. Many of these buildings are no longer suitable for modern agricultural uses for a range of reasons. Having no economic use often means that they fall into disrepair. Therefore in our view it is important that they are given the opportunity of a secure future through redevelopment for residential uses.

PO5 Affordable Housing
The NFU welcomes section B which will facilitate the development of affordable housing in rural areas.

PO8 Economy
The NFU welcomes policy that enables growth of rural businesses and supports the diversification of the rural economy. The NPPF states that "To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century". Paragraph 28 of the NPPF contains a very specific reference to supporting a prosperous rural economy; "Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development". It also states that plans should "promote the development and diversification of agricultural and other land-based rural businesses".

PO14 Transport
The NFU is supportive of the policies aim to provide affordable transport options in villages and rural areas. Unfortunately at the moment there is often no viable alternative to car transport for people who live in rural areas especially if they wish to take up employment.
When considering transport and infrastructure you should be aware that farms and rural businesses are totally reliant on HGV and car transport. Any decisions to target employment away from areas reliant on the road network may have a negative effect upon the rural economy and restrict farm diversification. Tourism also relies on access by private car and new tourism enterprises must not be limited to sites that are accessible by public transport routes.

PO15 Green Infrastructure
Farmers already undertake a range of conservation management measure in order to improve environment quality and enhance biodiversity. This on-going work must be taken into consideration when considering development on farms. Therefore concerns about Green Infrastructure and the creation of Green Wedges should not stifle rural and agricultural development. As we said in the introduction it is possible to increase agricultural productivity whilst continuing to reduce the industry's environmental impacts. By working with farmers and landowners even more can be achieved.
We are concerned by biodiversity offsetting where off site mitigation measures are required. We would welcome the opportunity to discuss how you envisage this working in Warwick District.

PO16 Green Belt
The NFU welcomes the support for farm diversification and rural affordable housing in Policy PO16. These businesses have an essential role in maintaining the local landscape by grazing livestock, maintaining hedgerows and participating in agri-environment schemes. Farms in Green belt areas may need to invest in new buildings or other infrastructure as animal welfare and environmental requirements change. They may also need to diversify their businesses, perhaps by supplying local produce through farm shops. We are also supportive of the flexibility demonstrated in this Green Belt policy as alterations in the boundary must be made in order to support rural development. These changes will help agricultural and rural businesses in the affected areas to develop and evolve in order to ensure their long term viability. However when considering boundary change it is important to safeguard productive agricultural land and it is usually preferable for grade 3 land to be identified for development.

PO18 Flooding and Water
The growth allocations outlined under PO4 will place additional demands on the natural resources of the county. Farmers have a particular interest in this issue as new development will impact upon the surrounding agricultural land. New development sites should have land earmarked for SUDs and green space so that runoff can be captured and managed. We therefore broadly welcome the policy but urge the council to thoroughly investigate these impacts to ensure that adequate water resources and drainage capacity is available to cope with the new demands placed on the District's natural infrastructure.

I hope that you find our contribution to the preferred Options Consultation useful. The NFU is keen to assist the council with the development of planning policy so if you require further information or clarification of any of the points raised in this response please do not hesitate to contact me at the West Midlands Regional Office.

-PO1 Levels of Growth
The WDC Housing needs assessment and inward migration figures appear incorrect, the arguments are flawed and the assumptions false. The Council must use due diligence to study the paper submitted by Ray Bullen from Bishops Tachbrook which re examines the migration and population data. It also provides updated figures using the newly published Census information which proves that the WDC conclusions are incorrect.
Mr Bullens report provides a much more realistic conclusion of only 5,336 houses needed over the plan period.

PO3 Broad Location of Growth
I am concerned about the over concentration of development in villages along the B4439 corridor to the west of Warwick. This proposal places far too much strain on this rural area and its infrastructure. Any attempt to 'improve' the infrastructure will adversely affect the rural character of this area. Why is development not being spread to also include villages to the East and North of the District ?

PO16 green Belt
I profoundly disagree with proposals to remove Green Belt status from certain villages.
The principles of creation of Green Belt land are still valid today and provide a valuable protection from inappropriate development.
There are many contradictions between the WDC plan proposals and the National Planning Policy Framework which says that Green belt must be protected unless exceptional circumstances exist. PO16 item B directly conflicts with PO16 item C. (page 17).

If any small scale development is allowed in village locations, the type of housing must not be dictated by developers. The local community must be able to determine what is required for local need.

Any development must be planned in a priority order using Brown Field sites first, secondly developing areas close to existing infrastructure, and only allowing any developments in rural and Green Belt areas as a last resort.

As scanned.

As scanned.

Attached

Scanned representation

Scanned representation