D. Development on Greenfield Land

Development on greenfield land is more acceptable the on Green Belt land and should be left open for future consideration.

Only very carefully chosen greenfield areas should be used for development and this approach will protect the rest of our greenbelt

It is important to allow in-filling and supportive development in rural communities, especially if it helps keep young families and skills in the countryside.

There can be no justification for building in the greenbelt. The Council has a responsibility to prevent urban sprawl. There are several other sites available.

The JPC broadly supports this proposal

a guarded nod of approval - provided the Council sticks to these stated objectives.

the proposals do not meet these requirements

I do not accept that it is on order to build housing on greenfield land ONLY if it is 'affordable' - what difference does it make a year later when the houses are sold to private ownership?

Makes sense - if some relinquishing of green belt is necessary these categories are justified

greenfield developments should be avoided in all cases

Preservation of greenbelt is essential to maintain farming communities. Farm sizes need to be large to be economic; continual erosion of agricultural land depletes farms - and farmers - of their livelihoods - resulting in more food being imported from outside the UK. This affects road traffic, the environment, food prices and quality of life. Building on greenbelt further risks established drainage and 'run-off' patterns, creating flooding risks and over-burdening of drainage channels. Lastly, we need countryside for our young people to walk and play in and to steward, to stop them becoming couch potatoes!

Housing Allocations.
We are concerned at the inclusion of Map 2 in the full document, which appears to include land not shown in the preferred options Map 4. Does this mean that sites shown on this map could potentially be reconsidered as development options?

South of Gallows Hill, west of Europa Way. Option 3.
This site bounds Warwick Castle Park along much of its eastern perimeter.
Development up to Banbury road would be extremely detrimental to the Grade I registered Warwick Castle Park. You will be aware of the history of Warwick Castle Park. The new line of Banbury Road, from the Asps into Warwick was constructed in order to enlarge the park, to enable the construction of the much larger lake, New Waters, which actually extended across the new road, but finally, it was part of the design of the park itself. The second earl, who was responsible for the enlargement of the park was working on his design for the approach to the castle from 1777. Instead of the town and castle coming into view all at once, as it had formerly done, the alignment and landscaping of the road produced a progressive unveiling, beginning with the spire of St Nicholas church which appears in the centre of the line of the road. Gradually parts of the town appear, and then the explosion of the view of the castle from the bridge. This magnificent effect would be irreparably damaged if development were permitted on the scale indicated and so close to the road. This is the setting of the park, the castle and of the town itself.

The eastern verge of the road is well treed over much of this length, but the views between the trees are long ones, as the land is comparatively high. The Technology Park is itself a regrettable but moderate intrusion and the recently constructed access to a caravan park which actually sits on part of the park, and about which we were never consulted, is visual vandalism. However, the existing small suburbs emerge discretely from the landscape and do not offer the visual competition that a mile of sprawling suburb on elevated ground would bring.

We therefore strongly recommend that this option be withdrawn or the boundaries be reconsidered, allowing the immediate view from the road to be rural in character and so respect the setting of the park.
Designating the edge of the development as "amenity" land would not be an acceptable alternative, as this would create suburbia just as much as houses would.

Loes Farm. Option 9
We observe that this proposed allocation has been reduced from the original, presumably to avoid inclusion of the registered landscape of Guys Cliffe. However, the setting of the landscape is wider than the designated area. Contrived views within and out of the gardens are a major characteristic of the landscape. The Register description enumerates the land acquisitions made by Bertie Greatheed in order to create small areas of parkland. Loes Farm was bought for this purpose from the Earl of Warwick in 1824. It gave him control of views to the west of the house, including of the Como Pit, and to Gaveston's Cross. The buildings of Loes farm are mentioned in the register description as an incident in the view.
The development of this part of Loes Farm would therefore have a detrimental impact on the historic designed landscape. It would impinge on important views, and would bring development right to the walls of the kitchen garden, which dates from before 1786.

We are therefore strongly opposed to the inclusion of this site within the preferred options for development.

Other sites
We hope to see more information about the proposals for infill sites in the towns and villages. As the proposals now stand there is the potential for damage to the character of neighbourhoods and adjacent sites. Examples are the well-treed Riverside House site which contributes substantially to the character of New Milverton, and the vague nomination of a hundred houses for Barford, where the locally registered landscape of Barford House is already under siege by a development proposal. We hope that this land will not be assigned for part of the allocation.

There are likely to be similar sites in the other named villages also exposed to damage. It is important that there be design guidance for the development of some infill sites in the towns and in the villages in order to achieve the best outcomes.

Policies
We are pleased to see the intention of excluding garden land from development.

We are also pleased to see the intention expressed in PO 11 to provide policies to protect the historic environment, though we are alarmed that the failure to include draft policies in the present consultation document may result in hasty and imperfect drafting at the next stage.

We hope that the policies that are produced will be at least as strong as those which currently apply. We appreciate that the present recommendations for integrated protection of heritage assets will require considerable re-drafting of the current policies. We also hope that adequate provision will be made for the inclusion of built structures in the local listing regime, as this could give protection to some garden structures which are currently vulnerable.

We represent the West Midlands HARP Planning Consortium which includes all the leading Housing
Association Registered Providers (HARPs) across the West Midlands. Our client's principal concerns are
to optimise the provision of social / affordable housing and to ensure the evolution and preparation of
consistent policies throughout the region.
PO1: Preferred Level of Growth
The preferred level of growth identified would fail to meet even the basic level of affordable housing need
identified in the 2012 SHMA of 698 affordable dwellings per annum. For this reason Preferred Option 1 is
not supported. Our previous representations to the 'Helping Shape the District' consultation indicated that
the preferred options should be based on a full, robust evidence base, and the Council now has this to
rely upon.
The decision to bring forward a very basic level of housing growth across the District is likely to result in a
much lower level of affordable housing being brought forward over the Plan period than is necessary due
to significant viability constraints on development. The SHMA notes:
"Given the viability of residential development within the District and the availability of funding for
affordable housing, it is unrealistic to assume that all housing needs can be met. ... the supply of
affordable housing is likely to fall short of identified needs. The Council should look to maximise provision
of affordable housing where possible, including in working proactively with developing RPs ...." [Our
emphasis]
The implications of providing just 4,320 affordable dwellings over the lifetime of the plan needs to be
considered as part of the wider housing target. This reduction in the general housing target, and
subsequent reduction in the deliverability of affordable dwellings is very significant and will have a further
detrimental impact on housing waiting lists and affordability across the district. A single affordable
dwelling was completed in the monitoring period 2010/2011. With significant uncertainty as to general
development viability and the Affordable Housing Viability Assessment indicating variable viability across
the district, it is important for the Council allow sufficient flexibility in the housing land supply target to
secure affordable housing.
The Local Plan should be aiming for a much higher figure to take account of the need not only for
affordable housing delivery, but also to plan for economic growth across the district. We recommend that
a minimum target should be that set out in the SHMA, of 11,900 dwellings; the SHLAA indicates a more
substantial 13,385 dwelling capacity across the District to 2029 which could accommodate that minimum
target.
Unit 2 Eclipse Office Park Staple Hill Bristol BS16 5EL
T: 0117 956 1916 E: all@tetlow-king.co.uk
F: 0117 970 1293 W: www.tetlow-king.co.uk
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PO2: Community Infrastructure Levy
We support the Council's intention to bring forward CIL.
PO3: Broad Location of Growth
We support the Preferred Option for growth. We do however recommend that the Council clarify that the
hierarchy will allow for development at smaller villages. The NPPF states:
"In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities
should be responsive to local circumstances and plan housing development to reflect local needs,
particularly for affordable housing, including through rural exception sites where appropriate. Local
planning authorities should in particular consider whether allowing some market housing would facilitate
the provision of significant additional affordable housing to meet local needs.
To promote sustainable development in rural areas, housing should be located where it will enhance or
maintain the vitality of rural communities. For example, where there are groups of smaller settlements,
development in one village may support services in a village nearby." (NPPF, paragraphs 54 and 55)
By the use of this minor textual change, the Council will signal flexibility to development at villages with
housing need but where there are no infill opportunities. As shown above, this approach is in line with the
NPPF and the Council's own commitment to meeting housing need across the district. The Council can
control the extent of development at rural villages by requiring this to be proportionate in scale to the
settlement size and housing need.
PO4: Distribution of Sites for Housing
B. Category 1 and 2 Villages
We support the establishment of new village boundaries to enable development to come forward at rural
villages. In addition to discussion with Parish Councils, Warwick District Council should also ensure
consultation with local landowners and developers, including HARPs, to support development in the most
sustainable locations. We support the removal of land within village envelopes from the Green Belt.
D. Development on Greenfield Land
We support the proviso that affordable housing development will be permitted on greenfield land.
PO5: Affordable Housing
A. Affordable Housing on Housing Development Sites
We support the Council's intention to seek 40% affordable housing delivery from new residential
developments, as this is supported by the Affordable Housing Viability Report. The thresholds for urban
and rural areas are also supported, as this strikes the right balance between seeking affordable housing
from a high number of developments, whilst still making allowance for viability considerations.
We note the Council's intention to require affordable housing be retained in perpetuity. The NPPF
requires only that affordable housing delivered on rural exception sites be subject to this condition and we
advise therefore that the Council adopt this approach.
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B. Affordable Housing on Rural Exception Sites
As per our comments above, we recommend a word change to state that rural exception schemes will be
permitted at village locations where housing development would not normally be permitted. This would
support the provisions already set out under this Preferred Option.
We strongly support the allowance of some market housing under this Preferred Option to support the
delivery of affordable housing. This is in line with NPPF definition of rural exception sites which states:
"Small numbers of market homes may be allowed at the local authority's discretion, for example where
essential to enable the delivery of affordable units without grant funding."
We are however concerned by the imposition of a 30% cap on the level of market housing to be permitted
to cross-subsidise affordable housing delivery. The reason for the level of the cap is not explained in the
justification section, nor is it discussed in the Affordable Housing Viability Report. It would be useful for
the Council to set out its reasoning for the cap figure as without this the policy is unjustified.
PO6: Mixed Communities & Wide Choice of Housing
B. Lifetime Homes
Whilst we support the Council's intention to seek a proportion of new residential developments as
meeting the Lifetime Home standards, a formal policy in the next draft of the Local Plan should recognise
the potential for those standards to change, as new standards could be implemented at a later date,
rendering the Local Plan outdated and ineffective.
C. Homes for Older People
We strongly support the Preferred Option for all strategic sites to include an element of Extra Care
housing. We also support the Council's intention to make allowance for Retirement Villages and
Continuing Care Retirement Communities (CCRCs). Locational factors, such as proximity to local shops
and public transport, should not be as strict as for general market housing, as Retirement Villages and
CCRCs typically provide a suite of on-site facilities which reduce the need for site residents to access
local services and facilities, as well as having a nil requirement for services such as local schools.
PO16: Green Belt
We support the Preferred Option for the Green Belt. The requirement however for affordable housing to
be brought forward "through a Neighbourhood Plan" removes the ability for development to be brought
forward on an ad hoc basis - for example where a community does not wish, or have the capacity, to
develop a Neighbourhood Plan. We recommend instead that a formal policy sets out the ability for
affordable housing to be brought forward, including through a Neighbourhood Plan, or otherwise where
there is evidence of need.

I write to register my objection to the Old Milverton and Blackdown development in Warwick District Council's local plan.

My reasons for objecting are as follows:

* The proposed land is designated as Green belt, and no exceptional circumstances have been demonstrated as to why the land should be encroached upon in such a manner as the building of several hundred houses.

* With the addition of hundreds of houses in one area, the inevitable concequence is double the amount of cars (each household will have up to or more than 2 cars). Simply building another road, over yet more greenbelt, will not syphon those cars away from the narrow lanes of Old Milverton and Blackdown. These lanes will become dangerous rat runs and take away the intrinsic peace and quiet of the area.

* There are alternative areas of land, closer to existing amenities, which would negate the need for an ugly and cramped housing estate, and would provide a way of making sure WDC fulfilled any need to provide extra housing. Why not build on these brown spaces and provide them with green spaces for leisure and relaxation instead of shoe horning yet more small boxy houses into a place already providing leisure and public access for hundreds of people.

* The Greenbelt also comprises excellent and productive farmland which has provided a living to families over the years. The compulsary purchase, or denying the farmer his rights to farm this land, would deny him the right to make a living, thus forcing yet another working farm to the brink of closure. Farming methods such as early crops under plastic would be the only profitable way to carry on, a method wich is not only pesticide and insecticide heavy, but an eyesore to look at. Productive farmland should never have to be sacrificed over more suitable land for the building of houses.

* Old Milverton and Blackdown are already satelite villages with little or no public transport, no shops, post offices, pubs, or facilities such as gas, fast broadband or cable. Nowhere in the plans does it say these issues are going to be addressed. Simply building hundreds of houses and putting a park and ride system outside the hospital will not make up for the fact that this scheme is simply an exercise in ticking boxes and riding rough shod over the views of local people who recognise the need to preserve greenbelt spaces for the important role they play in the wider community.


I am emailing a copy of this letter to my MP and I hope he will do everything he can to stop the proposed development here and direct them towards other areas which would welcome and be able to support such infrastructure.

2:2 - Why is the environment not listed as a key priority: without it, all manner of planning applications can be granted which are anti-environmental

Is leisure included in "Health and Wellbeing". If so, this should be made clear.

2:5 - As there is no way the economy can be predicted, there should be a commitment to responding to new opportunities and needs which arise

Can the areas mentioned as requiring regeneration be identified?

I am concerned about the second bullet point under Emphasis on infrastructure, as most areas of the countryside and of importance for wildlife need only a very light touch, if a touch at all. There should be a clear distinction between the approach to parks and managed open spaces, and to wilder areas (e.g. Welch's Meadow would be ruined by heavy handed management).

3:7 - there are elements referred to in this draft plan which need to be prioritised and policy made before March/April 2012; in particular a policy on the concentration of HMOs.

4:6 - the protection afforded to conservation areas should be strengthened, particularly as these cover apparently only 4% of the district

4:8, point 2 - It should be noted that one major contributory factor to the current lack of affordable properties relates to HMOs. The house next door to mine is an example of this. It was owned by an elderly lady who went into residential care. There was a large amount of interest in the property from people who wanted it as a family home, indeed so much interest that it was decided on sealed bids. Because the property needed some updating, and I met several potential purchasers who wanted to restore it to its former self, the highest bidder was, almost inevitably, a landlord who could easily find the finance and would easily recoup the investment by turning it into an HMO. I have seen this repeated time and again in my area of south Leamington where the gains from HMOs has pushed up prices beyond affordable for an individual or family: indeed a local couple I know has not been able to find an affordable small period house and, despite wanting to stay in Leamington, is having to move to Cheltenham to find such a property. In addition to the price problem, most often the conversion to HMO is the cheapest possible and degrades the period property.

4:10.2 - It is right to accommodate university students, but not at the expense of other "settled" residents. South Leamington is at a tipping point where the area could be completely dominated by students The advantages of a large student population tend to benefit the few - landlords and places selling cheap food and drink, whilst the cost and disadvantages are picked up by Council tax payers and local neighbours. It also means that businesses not directed at students tend to stay away. One south town resident recently pointed out that because Leamington is only a student dormitory town rather than a university town, we have generally ended up with all of the problems of a large student population and none of the advantages of the university culture which takes place on campus. I can see no reason why special consideration should be afforded to the University of Warwick in providing accommodation for its students.

4:11 - I agree with all these points, particularly endorsing numbers 7, 9 and 10. It is particularly important in any development not to let the developer be the tail which wags the dog, as the developer will inevitably want to take the easiest and cheapest route in contradiction to the area's best interests.

5-7 - Level of growth:
As forecasting population growth is a very inexact science, the Council should constantly monitor what is actually happening. If the expected population growth is not materialising, planned development should be scaled back accordingly. It makes sense therefore to insist on development of the brownfield sites before eating into Green Belt.

P04:D - Loss of green space should also be taken into account when assessing development of garden land. This space may not be directly accessible to the general public, but if it contributes to the overall feeling of green space which is enjoyed by the general public (e.g. with trees that can be seen from neighbouring streets), it is very important that it is maintained. It is also important for biodiversity and the environment, as gardens are now understood to be extremely important habitats for wildlife.

P06.D - It is most important to identify the locational criteria and to carry out a thorough survey of all HMOs and their residents, not just those which have previously had to get Council approval.

7.59 - We need this policy now!

P08 - We also need a firm policy now regarding the protection of existing employment buildings from change of use, as in my area I can think of several schemes either applyng for or already granted planning permission to change from commercial to residential use. The Plan already points out that f the area population is going to increase, then employment will need to increase as well and it is short-sighted to be allowing commercial property to disappear.

8:21 - Does the projection of additional job requirement take into account that the growth in the older population will automatically mean the release of the jobs these people were doing?

9: Retailing

It is a mistake to be led by the retail "experts" who push for constant retail development schemes in order to compete with neighbouring towns. There is a fine balance between having enough "High Street names" to serve shoppers and having so many that Leamington becomes indistinguishable from any other shopping centre - in which case, why would any non-residents want to come here? The success of the last major retail development - which seems dubious to me - (Parade to Regent Street) should be assessed before rushing into another similar development. Outside shoppers will travel to a shopping centre to find something different and it is this difference which needs to be identified and promoted. These major developments also seem to push up rents for retailers.

13: Inclusive, Safe and Healthy Communities

Developments should not be permitted which will downgrade and produce associated problems to an area, e.g. SEVs.

14: Transport

I suggest WDC promote a car sharing scheme.

P014: How can you plan a retail development in Chandos Street whilst aiming to maintain sufficient parking in town centres. Chandos Street is a much more popular car park than the multi-storeys.

15: Green Infrastructure

A relevant issue is that Network Rail is destroying, and has been for a long time, the natural environment and wildlife habitat along railway lines by felling all the trees and killing undergrowth every year with weed killer.

15:14 - Yes to urban tree planting; concern about messing with the River Leam borders unless already in a well-used managed area.

P017 - I agree with the continued support for the development of a cultural quarter

I believe that existing visitor accommodation should be protected from change of use.

18: Flooding

Planning permission should be sought by someone wanting to pave/concrete over a front garden, as I believe this trend has contributed to flooding problems.

Summary of major concerns

* Restrictions needed on HMOs
* Light-handed touch needed on non-parkland open spaces and riverside
* More creative study of retail demands and opportunities needed
* Although the Plan does seem to recognise this, the expansion of the district must avoid segregating areas into a single use, e.g. residential, employment, etc. Areas are much more interesting and attractive if they include a mix of residential, employment, cultural/leisure, etc. properties.

Scanned Representations

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.

See attached letter

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