PO5: Affordable Housing

Range of housing proposed not appropriate for areas planning to develop. Support idea of garden suburb but don't think dvelopers will allow this to happen in practice. Council seems unable to 'control' developers eg Trinity school, development,Warwick Gates. Once palnning is granted developers build to maximise their profits not what is in the best interests of loacl community

The Norton Lindsey Housing Needs Survey of November 2011, identified the need for 3 new affordable homes in Norton Lindsey. Taking the survey results and applying your requirement for 40% of new homes on developments of 5 or more dwellings in rural areas to be affordable housing, Norton Lindsey would require additional 7-8 new dwellings, significantly less than the 30-80 new houses proposed under the Local Plan. This is an indication that the village does not have the need, nor the capacity to cope with such proportionately large development.

The SHMA survey found a need for 698 Affordable houses per year but this exceeds the total number of houses to be built and is justly described as an unrealistic target by the Council. In 7.47 the SHMA suggests that about 77% of new homes being affordable will meet its needs but accepts that 30% is reasonable. We maintain that the SHMA survey is basically flawed.
A recent survey in Barford, Wasperton & Sherbourne has indicated that 10 Affordable homes are needed and that this number will satisfy the foreseeable need. Affordable housing is often only required as a starter home and becomes available for re-occupation after a short time. It is important that the occupiers of Affordable housing have access to good transport facilities to enable them to travel to work or to social activities. It is important therefore that Affordable Housing in Rural locations should be provided only for Local Need so as to minimise the requirements for transport, unless employment opportunities are available in close proximity to the rural housing location.
Local Housing Needs surveys should determine the level of Affordable housing required and a blanket allocation of 40% is likely to fail to provide Affordable housing where it is needed.
A provision in the plan to ensure that funds are available to provide Affordable housing could be made through the CIL so that developments in rural areas providing fewer Affordable homes can assist those in Urban areas who may need to provide a greater proportion of Affordable homes.

In general terms I support the provision of affordable housing.

Affordable Housing in rural areas should be provided - in perpetuity - for people with local connections. The two previous government administrations specifically helped to retain the community of old villages by
(a) limiting new building sites to numbers of houses for which there is a proven need rather than just building to make up national target numbers.
(b) promoting affordable housing so people could continue to live where they were brought up or where they work. The original policy was that these affordable houses would be primarily available for such people as first priority even for subsequent tenants - in perpetuity. This needs to be re-established. There is no good logic in providing additional affordable rural houses just to make up target numbers.

With regard to PO5 'Affordable Housing' we support the flexible approach and in particular the need to take into consideration the different nature of development sites and locations within the district. This approach is consistent with paragraph 50 of the NPPF, which highlights that affordable housing polices should be sufficiently flexible to take account of changing market conditions over time.

The council's own Strategic Housing Market Assessment (SHMA) suggests that if all affordable housing needs are to be met, about 77% of new homes should be affordable. Therefore, the council's lack of ambition regarding affordable housing is disappointing and suggests greater concern for developers than local residents who are in desperate need of suitable housing. The Council accepts the Affordable Housing Viability Assessment (AHVA) assessment that it is possible to have up to 50% affordable housing, yet it is not willing to take a flexible approach and categorise sites by level of viability i.e. insist many sites have more than 40% affordable housing. This is despite good work of the AHVA in setting out 3 categories of site. The Council should work harder to maximise affordable build and therefore should:
* Categorise each site by viability to maximise the number of affordable houses which it recognises are so badly needed
* Increase density of housing which will reduce the cost per home and therefore enable more affordable properties to be built
* Follow the advice in the AHVA, 7.49 and reduce the threshold for affordable properties to 7 properties in urban areas
* Seek independent opinion regarding the 20% of Gross Development Value (GDV) return figure in the AHVA upon which viability figures are based. This figure is not justified in the document and expected GDV returns are falling in the property industry e.g. see http://www.thepropertyspeculator.co.uk/tag/gross-development-value/ which suggests 15% is more realistic. LDZ who wrote the AHVA also work for developers and so potentially they have an interest in inflating this figure to the benefit of developers at the expense of local residents
* Demonstrate with detailed commitments how any remaining short fall in affordable housing can be met through innovative working with the private sector, so that the local plan is compliant with the National Planning Policy Framework (NPPF)

An objection is made to P05 in respect of affordable housing and the policy justification set out in paragraphs 7.43 to 7.50. There is a conflict between the 40% figure that is identified as part ofthe text of P05 and the reference in paragraph 7.47 which states that ' .... [the SHMA] accepts that a realistic proportion might be 30% or 180 per year '. Paragraphs 158 and 159 of The Framework refer to using a proportionate evidence base, with the SHMA providing guidance on the need for affordable housing. Notwithstanding the conclusions of the SHMA about what is realistic in terms of affordable housing the Council has opted for a figure of 40%.

The draft Local Plan also needs to clarify that the provision of affordable housing relates to the definition of affordable housing set out in Annex 2 of the Framework, in particular to confirm that there is no national policy requirement to provide all types of affordable housing as part of a single proposal. As stated in paragraph 50 of The Framework, local planning authorities should 'identifY the size, type, tenure and range of housing that is required in particular locations. reflecting local demand. .. '. In this context it is noted that paragraph 7.50 of the draft Local Plan seems to be at variance with The Framework in that' the Council is reluctant to adopt a different policy to suit different site types or locations '.

The Leamington Society supports the 40% requirement for affordable housing.

With reference to PO6 (Housing) WDC should also appreciate that HMOs now occupy many of the smaller and more affordable family houses, particularly in the south of Leamington (Old Town). The absence of any policy to restrict the many recent conversions to HMOs has aggravated the problem of affordable housing: they are so profitable for landlords that poorer families are priced out of the market.

The delivery of affordable housing is a key Government objective aimed at enabling everyone to have a decent home that they can afford. However, through the new Local Plan we believe the provision of affordable housing -linked to open market housing development- must be realistic with regard to economic viability and at the same time flexible to variations between sites and changes in market conditions over the plan period.

In the Council's Affordable Housing Viability Assessment (AHVA, Nov 2011) it is recognised that most residential developments are presently not only expected to provide affordable housing as part of Section 106 Agreements, but also to contribute to other costs imposed by the local authority on the development, such as highway works, provision of community facilities, education payments, etc. These additional development cost were therefore taken into account by factoring in an allowance of £6,650 per unit for S106 contributions under each the viability scenario tested; an average contribution figure on recently approved schemes in Warwick District. By comparison, in the Draft Infrastructure Plan we note that the total indicative cost for highway infrastructure alone is in the region of £48m or approximately £5,000 per new home.

At this time, therefore, while the full costs of infrastructure required to deliver the Plan and thus the CIL rate which the Council intends to charge remain unknown, we consider that it is premature for the Council to require any specific affordable housing percentage requirement. Furthermore, we note that the SMHA recommended an affordable housing target of 30%, while in the AHVA a 40% affordable housing target was only considered viable across the district under 'improved market conditions' i.e. similar conditions to those seen in early 2007. However, average house prices are not forecast to hit 2007 levels again until 2018 (UK housing market forecast, Knight Frank). The current downturn in residual land values will obviously have a considerable impact on the viability development schemes especially in Phase1 of the plan and this factor should be reflected in a revised policy PO5.

In response to these conditions, we believe to ensure that Policy PO5 is truly flexible the Council should:

* Set an affordable housing target which covers the lifetime of the Local Plan subject to monitoring of changing housing need and market conditions.

* Negotiate the overall quantity, type and tenure of on-site affordable housing on a site-by-site basis, having regard to scheme viability; viability assessments should not simply be based on addressing particular on-site constraints.

My only potential objection to this would be if having too many affordable homes detracts away from the current status/appeal/value of Warwick Gates.
You state that "this area is a very popular place to live and attracts people from other areas and regions as evidenced by higher than average house prices". Isn't that what makes this place appealing to those residents already here? You would not want to risk de-valuing houses in Warwick Gates and potentially losing those residents to other outside areas.
I would also be interested to know what proportion of your affordable housing plans will be social housing?

COMMENT

The delivery of affordable housing is a key Government objective aimed at enabling everyone to have a decent home that they can afford. However, through the new Local Plan we believe the provision of affordable housing - linked to open market housing development - must be realistic with regard to economic viability and at the same time flexible to variations between sites and changes in market conditions over the plan period. Until the full costs of infrastructure required to deliver the Plan, and thus the CIL rate(s) the Council intends to charge remain unknown, we consider that it is prepamture for the Council to require any specific affordable housing requirement.

Electronic attachment

General: The term "preferred options" implies that the decisions have already been made, and that there is little, if any chance of them being changed. This underlines the FACTS that the results of the previous "consultation" have been ignored, so leaving residents with the impression that this consultation will also have no effect.
PO1: 52% of the respondents to the previous consultation opted for the lower number of new houses to be built, on the grounds that this would meet the requirements of current residents and their families. It would not attract further influx of people seeking employment not available in the District, employment which they would only find outside it, further increasing the already unacceptable traffic problems. The Council decided to ignore this view and propose a much larger (100% larger) number of houses. We can only conclude that the Council is bowing to instructions /bribes from Westminster to allow more houses to be built by private developers, since there is no indication anywhere that the Council itself intends to carry out any of this housing growth.
PO2: The infrastructure levy is an essential feature of any increase in the number of houses built in the District. However, it must be levied and spent BEFORE the new housing is occupied. We have already experienced the problems which delaying this expenditure has created in Warwick.
PO3/PO4: There is clearly a preference for a high proportion (almost 50%) of the development to be located in Warwick. There seems very little proposed for the villages. Half the proposed housing development is on the south side of the district. Given that the bulk of the new employment opportunities will not be in the small area of the District, but in the larger employment proposals for Coventry, commuting through the towns will increase, not decrease.
PO5: The balance of the types of new housing should be very carefully scrutinised: too much of recent development has been of small properties and retirement flats, only suitable for short-term occupation by first-time buyers. More of the new housing must be for family use. The proposal that 40% of new housing should be "affordable" is essential, and must be maintained against developers' pressure for its reduction. A better definition of "affordable" is also required
PO6/PO7: Statements of the blindingly obvious.
PO8: The designated employment land must be maintained against the pressure which will be put on the Council by developers. We have already experienced in Tournament Fields the result of this pressure proving effective. There is no indication in the Plan of what percentage of the land will be designated as employment land.
PO9: We note that there will be "support for new retail investment on Leamington Town Centre". Why only Leamington? The other towns are equally deserving of support, though there is no indication that this proposal has any financial backing.
PO10: Forget the concept of "garden towns/suburbs". These were built in an era of weaker planning regulations and allowed a much larger area of land to be taken into use for housing. In the current climate, such land use is not acceptable to the general population. Planning law is about to be relaxed, and the Council must be vigilant in maintaining the quality of development.
PO11: This is a very weak section, "offering help and advice" is not very positive: more concrete proposals, including financial commitment is needed. This is repeated in PO17 where "support" and "seek contributions" are the key words.
PO14 (and un-numbered section following): The road improvements proposed would be of marginal value. The "improvements" to Europa Way and the junctions would be very expensive, and could use up a substantial proportion of the available infrastructure levy, to the detriment of more useful projects, such a schools, health centres and open areas.

Introduction

The Warwickshire Branch of the Campaign to Protect Rural England (CPRE) is a charity registered No 1092486 with over 700 members in Warwickshire. CPRE is very concerned about many aspects of the New Local Plan Preferred Options agreed by the Council on 21st May 2012 and now published for consultation.

Firstly we give our response to the main Preferred Options. We then examine key issues on the Vision, projected growth, population growth assumptions, the Green Belt, and the proposals for employment.


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

We strongly oppose the level of growth of 555 houses/year that PO1 proposes. The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and much of this is by windfall development within the urban areas.

The proposals to impose 100 houses on each of five villages would damage their rural character and unbalance their structure.


PO3 Broad Location of Growth

The proposal is 'growth across the District' including on Green Belt, and in villages. No direction of growth or focus on particular broad locations is proposed. This is contrary to the policy of previous Structure and Local Plans. Those plans protected Green Belt and identifed key locations while ensuring that urban land was re-used, and villages were only asked to accept limited new housing.

No clear reason for the change from past Local Plans has been offered. As those have been successful, the policies and patterns of development that they provided for should be maintained in the new Local Plan.
The extent of windfall development and use of brownfield land in Warwick and Leamington has been high for many years. There is no reason to depart from the practice of encouraging these forms of development.


PO4 Distribution of Sites for Housing

PO4 proposes a large number of greenfield housing sites which are currently Green Belt or greenfield. Most of these would not have been considered at all acceptable in past Local Plans, and we strong oppose the following sites, because they would require release of land from the Green Belt or would affect historic landscapes (such as the approach to Warwick around the east side of the Castle Park).

Sites:

3. South of Gallows Hill, west of Europa Way : harms setting of Castle Park and approach to Warwick from the south
4. West of A452 Kenilworth Road, between Northumberland Road and Old Milverton Lane - Green Belt, and essential part of the open countryside separating Kenilworth and Leamington
5. Blackdown - open countryside, which if developed reduces the separation between Kenilworth and Leamington by a quarter
8. Red House Farm, Lillington - Green Belt, visible land facing southeast
9. Loes Farm, Warwick - extends Woodloes Estate into Green Belt, and undermines tight planning control on north side of Warwick
13. 100 houses in each of 5 villages - this is an arbitrary imposition. Individual villages should be able to determine how much development they wish to accept.
14. 350 houses in smaller villages - there is no basis for such a figure, and most smaller villages should only accept 5-10 dwellings over 15 years if their rural character is to be ensured.

We also believe that Site 6 South of Sydenham, is too large an allocation and only a smaller development should be considered; that Site 2, Myton / West of Europa Way, is high-grade farmland protected from development under past Local Plans for its agricultural value, and its loss would be the end of the remaining green wedge left when employment land was developed east of Europa Way; and the scale of Green Belt release for Site 7, Kenilworth (Thickthorn) needs to be reduced. If these sites are released, this should be only after brownfield sites have been developed and windfall potential within the urban areas has been assessed.


PO5 Affordable Housing

CPRE supports the policy of 40% affordable housing which is carried forward from the 2007 Local Plan. It is strongly opposed to the part of the policy which would allow private sector developments in villages to fund affordable housing. If affordable (rented) housing is permitted in villages, this must be only following a sound assessment of local need, and should not bring with it housing for sale simply to provide funds for the affordable houses.


PO7 Gypsies and Travellers

CPRE supports finding an official site for gypsies. The numbers to be accommodated need reassessment against new policies: some gypsies have property elsewhere, and do not need to live in caravans. CPRE would propose that the gyspy site at Siskin Drive, just inside Coventry, be enlarged or re-sited in the Middlemarch employment area, so that part at least meets the needs of Warwick District.

PO10 Economy

CPRE opposes the provision of employment land north of Leamington on Green Belt. There is no need for major new employment land identification in the District. Surplus employment land and buildings in the towns come on the market continuously and can generally be re-used without any need to allocatec new greenfield land.

There is no shortage of employment land in Warwick District. In a recession, with economic difficulties meaning that land for employment becomes surplus, loss of existing sites to housing is more of a problem than any lack of new greenfield sites.

North of Leamington, proposed in PO8, would be an unsustainable location for employment development. It would be outside the town centres where the focus of employment is supposed to be; it would generate much car traffic; and the main transport routes through the District are south not northof Leamington.

The proposal for the Coventry Gateway around Coventry Airport has no economic justification: it would not be relevant as an employment site for most who live in Warwick and Leamington, is not easy to reach from Warwick District's urban areas, and would compete with the Ansty and Ryton employment locations nearby which are in Rugby District.

Established and new small businesses rarely need any planning permissions for their commercial activities.

Our conclusion is that no development of new employment land in the Green Belt is justified.


PO11 The Historic Environment

The existing (2007) Local Plan contains clear policies to guide conservation and decisions on developments that affect a Conservation Areas. This set of Policies should be generally carried forward, without any simplication (which can cause ambiguity).

A Policy to make the lengths of the Grand Union Canal and Stratford Canal in Warwick District into Conservation Areas is needed. Other Districts with extensive lengths of canal have created linear conservation areas.


PO14 Transport

The proposed new road links and road widenings in the Preferred Options would be harmful to the Green Belt and tend to encourage more car traffic. That would create unsustainable patterns of movement and increased car depenency. By contrast the proposals for the bus network are thin. They focus on Park & Ride provision which is not of importance to residents of the towns.


PO16 Green Belt

The Preferred Options would require major removal of land from the Green Belt for urban development. It would also require the removal of 'washed-over' status of some smaller villages which are currently covered by Green Belt designation. The very special circumstances required to be demonstrated if Green Belt land is to be released for building have not been shown to be justified.




The Key Issues


1. Vision and Growth

1.1 The key aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This reflects a current focus in national government thinking and speeches by Ministers. It fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years.

1.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

1.3 CPRE believes that there should be a much more careful balance between development and the environment than the Preferred Options would achieve. The proposed scale of development would risk being unsustainable and contrary to the NPPF policy that supports sustainable development.

1.4 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

1.5 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.


2. Sustainability

2.1 The National Planning Policy Framework (NPPF) at para 49 sets out the principles of sustainable development. The NPPF says that Sustainability has three aspects, environmental, economic and social. The Preferred Options pay little attention to the environmental aspects of sustainability.

2.2 The term 'sustainable' is used about 120 times in the full Preferred Options report, but this is mostly in relation to economic aspects of sustainability.

2.3 We do not believe that large-scale destruction of open countryside is sustainable development - it is unsustainable. Once lost it will never become available for future generations.

2.4 We acknowledge that a few mentions of sustainability in the proposal do relate to the social aspects such as providing sufficient of the right kinds of housing and facilities.


3. The Projected Housing Requirement

3.1 CPRE is strongly opposed to the proposed level of housebuilding advocated in the Preferred Options.

3.2 The justification for this level of housebuilding is weak, for the following reasons.


1. The ONS projections for Warwick District are arbitrary and probably overstated. They do not yet take account of likely reductions in net migration to the UK or the potential effects of the recession. They assume in-migration at recent levels although this is now reducing rapidly.

2. Projections for individual local authorities are notoriously unreliable because they do not take into account the implications of planning and other policies. Already the 2011 Census (issued in summer 2012) shows that the growth of population in the last decade given at para 4.2 of the preferred Options is nearly 50% too high. Population growth 2001-2011 was not 14,800. It was 10,000 from 2001 to 2011 (126,000 to 136,000).

3. House building rates in Warwick have been very low over the past five years and are likely to pick up only slowly. The rate of housebuilding proposed by Warwick DC in the Preferred Options is well above the rate achieved in the last 10 years and on current economic trends is unachievable.

4. The work by G L Hearn / JGC at Appendix 2 of the SHLAA does not lead clearly to any particular level of population, household or employment growth. Their projections are highly volatile, depending on a range of key assumptions.

5. From statements in the Preferred Options, and made at public meetings during consultation, it seems that Warwick District Council has decided to seek a relatively high level of housing development in the mistaken belief that it will help to boost economic growth. There is no overriding need for major new employment development. If population grows rapidly, it is more likely to result in a change in the balance of commuting, with more Warwick residents working outside the district.

6. The consultants' work on translating population growth into household growth is inadequate. It assumes too high a vacancy rate for new housing stock and fails to consider sharing and institutional population.

3.3 We have other major concerns about the population projections.

3.4 In its commentary on the projections, the Office for National Statistics says - 'Projections are not forecasts and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. They provide an indication of the impact that changes in demographic patterns might have on the size and age structure of the population in the future.' Therefore the projections should not be taken literally.

3.5 There are particular questions over two of the assumptions made in the national projections:
* Net international migration, which makes up roughly half the projected population increase, is likely to reduce in future, reflecting a tightening of government policy on this issue. This change will not yet have been picked up by the projections;
* Although there is little sign of this yet, birth rates may fall as a result of the recession and the slow recovery from it.

3.6 The Preferred Options forecast that Warwick District's population will grow by 21,600 between 2010 and 2026, and from this a requirement for about 9,390 extra dwellings is produced. (The average household size would stay at 2.3 persons.) This produces a rate of building of 587 dwellings per annum, not achieved in any past year for some decades

3.7 The suggested rate of building, at 550 dwellings per year, has not been achieved in the District for some decades, if ever. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The Government predicts only a slow recovery from the recession, with a gradual increase in house building rates. Therefore it could be many years before the Preferred Option's desired rate of house building can be achieved, and the past record suggests that it will not be achieved.

3.8 In an earlier consultation in September 2009 Warwick District Council asked for public views on three scenarios for numbers of houses. These were 200 per year, 500 per year and 800 per year. 51% of the public chose 200 per year. Despite this result the Preferred Options propose that over 500 houses be built annually.

3.9 The net in-migration element in the forecast housing requirement is large - 57% of the population growth forecast by the Council's consultants (in the SHMA) would be the result of net in-migration. However in-migration has fallen fast in the last 2 years and there is no clear reason why it should be provided for. If more houses are built, given the location of the District on the M40 and Chiltern Railway route, more inward migration will take place. There is not an objective need to provide for or seek inward migration.

3.10 We consider that the Preferred Options housing figures should be reduced substantially; the 2011 Census results and latest migration data be taken into account, and an objective need recalculated instead of assuming that in-migration should be planned for.


4. Proposed Locations for Housing


4.1 CPRE believes that a number of the major new housing locations proposed would be harmful. See response to PO4, Distribution of sites for housing.

4.2 The NPPF at para 109 states that "the planning system should contribute to and enhance the natural and local environment". This militates against development in the countryside and favours protection of landscapes, animal and plant life, public footpaths and Scenic Views. Further research would identify valued landscapes, geological conservation sites, soils ecosystems, impacts on biodiversity and ecological networks.

4.3 NPPF para 112 states that Local Planning Authorities should take into account the economic and other benefits of the best and most versatile agricultural land and should seek to use areas of poorer quality land in preference to that of a higher quality. Much of the land around Leamington is 'best and most versatile' agricultural land. This places a presumption against its loss to development.

4.4 Clearly any use of green land will require destruction of hedges, ponds and other habitats of animals and plants. It is likely to destroy public footpaths. It will certainly affect the views of countryside which are currently available to visitors, walkers and residents at the edge of the existing built-up area.

4.5 The area of the district which is not in the Green Belt is generally to the south and east of the built up area. While there are constraints here, and location (3) is wholly unacceptable, there is scope for some development at the locations previously considered in the 2009 Core Strategy.

4.6 Three pipelines run to the south-east of Offchurch, Radford Semele and Bishops Tachbrook, but not through the area of land adjacent to Europa Way or between Whitnash and Bistops Tachbrook, so do not appear to be a significant constraint.

4.7 There is some scope for more housing at Hatton Park which has been a successful development that maintains a 'washed-over' Green Belt status.


5. The Green Belt.


5.1 In para 79 of the NPPF, it is stated that "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."

5.2 Para 80 sets out five purposes of Green Belt. The West Midlands Green Belt to the north of Leamington and Warwick and the south of Kenilworth meets four of the five purposes:
* It prevents urban sprawl
* It prevents towns merging
* It is assisting in safeguarding the countryside from encroachment
* It assists urban regeneration by encouraging recycling of derelict and other urban land.

5.3 NPPF para 83 states that confirmed Green Belt boundaries should only be altered in exceptional circumstances. We are far from convinced by the arguments that the boundaries should be altered. The sole reason appears to be to spread the pain of development on greenfield sites across the District. This is not a planning justification which satisfies the need for exceptional circumstances.

5.4 NPPF 84 makes it clear that sustainable development to be channelled towards urban areas inside the Green Belt boundary and towards towns and villages inset within the Green Belt boundary or towards locations beyond the outer Green Belt boundary.

5.5 As in other parts of the report we see clear conflict with the Localism agenda of the coalition government. The Localism Act gives communities, including neighbourhoods, towns and villages, a procedure for determining for themselves what development should take place and where it should be located.

5.6 NPPF para 87 states "as with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".

5.7 NPPF para 88 states that "local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

5.8 Taking extensive Green Belt land out of the Green Belt and proposing it for housing is the opposite of a sustainable development policy.



6. Employment Land Proposals

6.1 CPRE supports a low-carbon economy; but it has a very long timescale, and must be developed but we are concerned that the proposed Preferred Options will not enable this. In particular, we question the proposal to "distribute development across the district". Established towns (and nearby cities) offer critical mass where homes and jobs can be developed in a balanced way supported by infrastructure such as public transport.

6.2 Substantial development in the countryside, such as the proposed major employment at the Coventry Gateway site, would increase the need to travel with the vast majority by private car. The Preferred Options recognise the importance of the need to reduce travel (e.g. in section 8.30) but do not seem to apply this principle consistently.

6.3 Major development in the countryside would make the principle of "developing an effective and sustainable transport package" very difficult to achieve and undermine the agreed principle of regeneration of urban areas. We support the preferred option (in PO3) to concentrate growth within urban areas but we are concerned about significant development in villages and rural areas.

6.4 We recognise the need to provide land for employment to meet proven local needs but are concerned about the proposed principle to provide land to "encourage the creation of jobs". Sustainable jobs are critically dependent on factors such as people, skills and finance, not just buildings or land. Increasingly, attracting skilled people and knowledge-based businesses to an area is dependent on the quality of the environment: somewhere people want to live as well as work. The social and environmental strands recognised in the NPPF are as important as the economic strand.

6.5 It is essential to keep employment balanced with housing: over-statement of housing numbers leads to over-statement of the need for employment land. We object to the over-allocation of housing (proposed in Section 7.22) to support the proposed Coventry Gateway, which has not been justified.

6.6 We note (from sections 8.21 and 8.22) that the Preferred Options propose some 66 hectares of employment land in the period from 2011 to 2026 and that 43 hectares have already been identified. For the remaining 23 hectares, we agree with the urban-brownfield-first priority and agree with the approach of locating employment with housing where new housing developments are really justified.

6.7 Compared to the remainder of 23 hectares of employment land over 15 years, the Coventry Gateway proposal amounts to over 97 hectares in one rural location in the early years of the strategy period. Such a volume of over-allocation would be indefensible and should not be considered as part of a balanced plan.

There is already a regional investment site at Ansty Park. It has fully developed infrastructure and yet currently vast tracts of empty land off blocked-up site roads. Empty buses frequently serve the mostly-empty site; it has excellent access to major highways but too few occupiers. The duty for local planning authorities to cooperate should mean that this site is supported by WDC rather than undermined with a competitive development in the Green Belt just 8km away.

6.9 Recent planning studies and processes have concluded that there is no need for more employment land in Green Belt. The Inspector's Report for the Examination in Public of the Coventry City Council Core Strategy (April 2010) concluded "There is no current need to allocate any additional employment land outside the city boundary, over and above that available at Ryton, to meet the overall economic objectives of the CS".

6.10 The Warwick District Employment Land Review of April 2009 concluded that "there is an oversupply of land suitable for the development of general industry/distribution that is already committed/allocated in the current Local Plan to accommodate demand in these sectors". The Addendum dated January 2011 noted a continuing decline in demand for B2 and B8 floorspace. While the 2009 Employment Land Review did identify a potential deficit of land suitable for office development, it identified "the area around south west Warwick and Leamington as most attractive both in market and planning terms". The 2011 Addendum noted decreased demand overall but also decreased completions, recommending further study. The earlier preferred development directions remained unchanged.

6.11 These plans and studies confirm there is no need for development of Green Belt land for employment. The plan numbers are backed up by experience on the ground, where for example the ex-Peugeot site at Ryton-on-Dunsmore has been vacant for 6 years and Ansty Park has struggled to find occupiers. We recognise that the Ryton site is in Rugby Borough but paragraphs 178 to 181 of the NPPF make it clear that local authorities must cooperate when drawing up Local Plans. The NPPF confirms that the Government attaches great importance to Green Belts, supports 'brownfield first' and reasserts that inappropriate development should not be approved except in very special circumstances. Need for development has not been proven and there is no evidence of valid special circumstances that would justify development in the Green Belt.

6.12 The Preferred Options consultation document picks up the claim that the Gateway "has the potential to provide in the region of 14,000 jobs" (section 8.33) even though this number is not justified and falls partly within Coventry. There are many examples of large, speculative developments where job creation assumptions are inflated and over-optimistic. New developments can remain half-finished for many years because demand proves to be far lower than anticipated. That would be a particularly damaging outcome for a large development with a devastating impact on the Green Belt to the south of Coventry. The number of jobs 'created', put forward by developers, cannot be relied upon as a measure of sustained economic benefit.

6.13 There are better ways of achieving more and better-quality employment. This is to put the emphasis on technological advance and the proposed "Emphasis on infrastructure": investment in communications technologies for rural areas in order to support small businesses and home offices. Broadband for rural communities continues to fall behind urban areas so rural businesses are increasingly uncompetitive. A well-wired rural community would help achieve both the low-carbon economy and the rural economy objectives. It would also make the district a better place to live and work for knowledge workers.

6.14 Finally, all the evidence indicates that in Warwick District no new development of employment land in the Green Belt is justified.

Letter and representation form attached electronically.

Scanned Response Form

PO1 Preferred Level Of Growth

In summary we agree with the option for the Local Authority to go for a moderate growth. There may be evidence to suggest that higher growth is required but in these challenging economic times and the practical and political pressure the Local authority will be under in making this decision, we believe the moderate growth option is a more realistic and such a pragmatic approach is likely to be achievable.

PO2 Community Infrastructure Levy

We support the idea to bring in a CIL.
One item that is missing from the document is any indication towards New Homes Bonus. This is something we would support as a revenue stream and serve to reinforce your support for Affordable Homes (paid on non s106 schemes only). Again the NHB could be shown to assist in the provision for extra care (under PO5)

PO3 Broad Location of Growth

We support the Preferred option for Growth.

PO4 Distribution of Sites for Housing

We support the establishment of new boundaries. RSL's would like to be involved in discussions with Parish Councils from an early start to dispel the myths around affordable housing and this could assist the provision of housing in these areas.

PO5 Affordable Housing

We agree with the 40% affordable housing on new residential developments with the exception where the scheme is to be delivered as a 100% affordable housing scheme, in these cases the properties can be dealt with under a separate planning condition .
We agree with the housing being held in perpetuity but we would draw attention for a balance. In many cases RSL's will need to show a level of asset churn. The asset however can be ring-fenced to be used soley for the provision of future affordable housing in the district.

In rural terms we support a certain level of market housing but it should be on a case by case basis given the likely high land and sales values generated in many of the District's villages

There is no reference to new Affordable rents. The document does refer to affordability however, but with no mention of the level of affordable rents and with many areas of WDC the level of rents can vary greatly within a 1 mile radius (Micro Markets) Therefore we would recommend some primary data in the document to support your arguments.

PO6 Mixed Communities & Wide Choice Housing

Employment is very high on everyone's agenda currently and there are many threads that tie housing/ construction to this. There are opportunities through apprentices and other work opportunities that can be brought about by new housing and this could be a opportunity to ensure this happens on future sites.

Homes for older people and the link to the Extra Care rented opportunities will remain difficult to deliver with the decline in grant funding form the HCA, & Warwickshire CC .

PO16 Greenbelt

Again we support the option for Green Belt but we would like to be involved in any discussions with parish councils or other interested parties to outline what is affordable housing and dispel any myths.

scanned submission

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
2
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.
3
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.

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.

Any large development should include "green channels" such as persists on the Woodloes park. As well as enabling rented apartments and local shops, to facilitate attractive areas to live in, a wide social mix and reduced environmental impact of shopping trips.

Warwick Town should encourage shops, whilst at the District level expansion by the BIG retailers should not be encouraged.

Existing wild places should be kept, particularly the river side walk between Warwick and Leamington. Potentially the path behind Tesco's could be enhanced from a mud track to a gravel path, similar to that in place where the path passes on the South side of the river by Edmondscote running track.

The plan has several areas shown as Confidential. This is clearly unhelpful from the point of view of commenting on specifics. If the land of or around Jephson Farm (between the river and Myton Road) is proposed to be developed this would be a significant diminution of amenity, and more "paving over of Warwick".

Whilst the plan proposes utilising the Regency Terrace opposite the old Council Courts in Warwick, there appears to be no plans for the Courts themselves? Surely there is scope for, say a Museum of Justice to keep these fine buildings and their historic interior, as well as adding to the vitality and attractiveness of Warwick.

Taking the sections in the plan:
P04: am surprised at just how far you plan to expand Warwick South! At this rate Warwick Castle Park will be a green island ? Assuming you are serious then it is behold that the Castle Park be available as an amenity, to enable the expanded population a proportional access to quality green space/park

P05: Affordable housing - agree.

P06/7/9/10/13/15: agree

P08: see earlier comment

P011: see earlier comment re: County Courts

P012: whilst agreeing climate change is real and has to be addressed, I'm unclear on what 20% reduction means. 20% of what ? will this be an annually revised value? (20% in year1, year2 = 20% of previous year etc, presuming each year is an improvement on the previous)

P014: use of public transport is as much a financial decision as access to it. If it's unaffordable to many it won't get used. By ignoring HS2, does that mean any costs associated with it WILL be met by Central Government then? I don't understand (and you don't explain) the risk of ignoring HS2 (or conversely) the risk/downside if you did plan for HS2.

Attached

The County Council, under the Localism Act 2012, has a "duty to co-operate". The duty to co-operate requires councils to 'engage constructively, actively and on an on-going basis' on issues relevant to statutory plans. Therefore, we will assist in the plan making process and infrastructure planning on an on-going basis.

We welcome the vision and direction of the local plan to create sustainable communities and a quality environment for all those who live and work in the District.

As well as our statutory duties our view is also set out in the context of the County Council's vision contained in the "Going for Growth" paper approved in April 2012. The purpose of this paper was to identify how the County will embrace the coalition government's twin primary aims of reducing deficit and securing growth in this challenging period of public sector austerity. The "Going for Growth" paper sets out how we will assist in stimulating and influencing the business and economic environment (with the necessary educational, skill development and community ambitions) to deliver 'growth' for Warwickshire.

In respect of indicating support for any particular development Option: our view is that there should be a right balance of sites that support growth. Therefore, it is a matter for the District Council, to satisfy itself and strike the right balance, in respect of deliverability, viability and sustainability and supporting infrastructure required to deliver each option.

The planning issues and policies contained in the "Preferred Options of the Local Plan" will impact at differing levels on the County council's corporate responsibilities, particularly economic, transport, support for the elderly and extra care housing, library services public health, gypsies and travellers and education. The Director of Public Health has already responded directly to you on the consultation and evidence.

The key values contained in the "Going for Growth" paper are stated below in emboldened text and their implications for planning and landuse policy is explained in the embolden text below:

* Our social investment will contribute to a county where the will compare well to other British communities.

We will look for planning policies that support technological Infrastructure and in particular in rural areas. We will support the strategic employment sites of the strategy.

* With a sense of mutual ownership of public services (the Warwickshire Shareholder).

We will support positive planning policies that embed co-location of services with the voluntary sector, private sector providers and other public bodies.

* We will achieve a discernible reduction in inequalities in social, economic, health and well-being regardless of age disability or culture.

This applies to access to goods and services for local residents including adequate provision for gypsies and travellers.

Planning policies on extra housing and affordable is provided with the necessary long term supporting services. We will support proposals and policies for co-location of services.

* A vibrant economy will produce high quality job offers in Warwickshire, raising the skill levels in the overall workforce so that we are as productive and competitive as the best in the Country.
* Warwickshire will be a place which looks actively at the best practice from other places - international as well as national - to develop innovative and entrepreneurial solutions. Our economic well-being will be measured by international comparison not simply against "West Midlands" regional standards. Our urban town centres will punch above their weight when compared with similar sized English town centres and our rural infrastructure will be amongst the best in the Country.

We will support planning policies that support a competitive economy for inward investment.

Warwick and Stratford upon Avon are international destinations and make a significant contribution to the economy of the region and sub region.

Therefore, we will support planning policies that support and sustain the key town centres.

* Our growth plan will attract people to live and work in Warwickshire as a specific choice. There will be a strong brand image, underpinned by a recognition that this as one of the best places in the Country to live and work.

Our strategic policies contained in the Local Transport Plan and Growth strategies support the improvement and the provision of strategic infrastructure such as junction improvements to strategic highway network and provision of new railways stations.

* There will be a strong Health and Well-being ethos about the quality of lifestyle we are encouraging.....where the brand "Warwickshire" will be directly associated with a health-focussed lifestyle supported by the health infrastructure to match.

The National Planning Framework requires Local Plans to include policies for health and well-being. The County Council is also responsible for Public Health and we would seek overarching planning policies in the Local Plan that support health and well-being as part of new developments in the District.

We are committed to delivering the best possible health and wellbeing outcomes for everyone, helping people to live Warwickshire.

Planning for health is important not only from a legislative perspective, but
also in relation to costs. Promoting healthy lifestyles, avoiding health impacts
and tackling health inequalities throughout the planning process could result
in major cost savings to society. There is significant evidence on the effect that spatial planning has on community health and well-being and spatial planning policies can address local health inequalities and social exclusion. Some local authorities have adopted planning policies to promote the health and well-being of residents through development management. The Local Plan can contribute to health and well-being in the following way:-

* The quality and opportunities of the local environment is a contributory factor in shaping health.
* Transport and traffic, access to public transport, lack of open space and where we shop for food are just a few examples of how the built environment influences our physical and mental health.
* Planning can positively affect the health of residents by shaping and influencing the layout and the open spaces in between developments and securing investment for the public realm.
* For example, planning policies can include; design requirements for housing layouts to encourage safe and pleasant walking short distances to amenities and services.
Developer obligations can be used to build infrastructure such as healthcare facilities, parks or cycling routes. There should be an overarching policy that promotes health and welling for communities in the District area. Spatial planning policies can promote and provide opportunities for healthier lifestyles.

It is against the above background that the comments are made to the specific questions. This letter contains an amalgamated response from various services. Whilst we have endeavoured to bring together as many responses as possible to assist you in the development of your Core Strategy, please be aware that there may be other services that may have comments to make at subsequent consultation periods as the process moves forward.

We wish to make detail comments on the Infrastructure Delivery Plan by mid-September. However, our general comments are set out below:

Comments in relation to adult social care and specialists housing needs.

Preferred Option 6 (PO6) Mixed Communities & Wide Choice of Homes

Para 7.5.3.
C. Homes for Older People should also include homes that include the needs of local older people, adults and children with disabilities and other local vulnerable people who need care and support. Therefore, this policy should include provision for; extra care housing and supported living accommodation suitable for adults/children with disabilities.

Para 7.5.8.
The Local Plan should provide clarity on the difference Use class C2 and C3 Usage Class. All too often we are seeing the C2 Usage Class applied to individual dwellings, which seem to become institutional if they are providing independent living solutions to vulnerable adults, e.g. McCarthy Stone development in Southbank Road, Kenilworth.

Extra care housing and use class C2 and C3

There is currently some uncertainty about the precise the definition of the different care market sub sectors, including that of 'Extra Care'. Extra Care may be defined as a scheme where occupiers have their own self-contained apartment or living space(s), and generally do not wish to live entirely by themselves without access to care, but do not require either, constant care. Such occupants would have the option of purchasing, as their needs require or are determined varying degrees of domiciliary care.
In terms of which use class order Extra Care falls within, its widely recognised definition, particularly regarding the varying degrees of care provided to residents, has led to debate over whether it comes under C2 Residential Institution or C3 Dwelling Houses.

The issue here is that care homes and extra care housing - both offer long term care solutions - but the preferred model (and this is the view of older people) is independent living (use class C3) with access to 24/7 care rather than admission to residential care (use classC2). We are seeing the market over providing ie residential care homes delivered ahead of extra care housing. If the number of residential care beds introduced to the market hits the predicted number of overall required care places (extra care housing and residential care), planners are likely to argue that there is little need for extra care if the residential care market has already delivered the required/reported numbers

Housing polices within the Local Plan should, therefore, clearly set the distinction between the class uses and also address how those needs will be met.

Demand for Extra Care housing
Based on the 2001 census Warwick District Council will need to provide 1197 units of extra care housing of which 299 should be "social rented" extra care housing. The latter figure should be form about 10-15% of the affordable housing numbers for the District.

Draft Infrastructure Plan
4.4.1.
The first sentence could be re-written to read as "Adult Social Services are mainly concerned with adults and older people with physical and/or learning disabilities and/or mental health problems"

4.4.4.
The last sentence should read as "Residential care accommodation is..."

4.4.5.
May be better to refer to "older people and adults" rather than "...elderly and non-elderly people..."

4.4.6.
This needs to reflect the current 50/50 service model promoted by the County Council, i.e. a model where 50% of people who would normally go into residential care are diverted into extra care housing.

4.4.13.
The suggestion that "Housing accommodation...for people with learning or physical disabilities will be met as the need arises" needs to be clearer.

At present only a limited number of people with learning disabilities are afforded the opportunity to live independent and meaningful lives with choice and control over where and who they live with. Instead, many have their lives constrained by having to live in residential care where individual outcomes do not generally improve. With approx. 300 people with learning disabilities currently living in residential care in Warwickshire, the overall programme intention is to deliver no less than 200, 1 and 2-bedroomed apartments that are suitable for adults with learning disabilities, including an initial short term target of an average of 25 apartments per annum between 2011 and 2015 in line with the County Council's Transformation agenda.

There are about 227 people with learning disabilities in the Warwick District, some are living in extra care accommodation and the others with their main carer (this could be parents or partner). Some residents are living in "hard to let" properties and can be victims of abuse and hate crime. These specialists accommodation would provide suitable and safe accommodation for these vulnerable residents.

General comments:
The District Council needs to include both anecdotal and specific needs analyses from a range of partners, such as local GPs, CCG, NHS Warwickshire and WCC. All these partners directly support and commission services for vulnerable people with a range of health and social care requirements, and these factors need to be considered when looking at overall housing provision.

Development Management and the consideration of planning applications for Care homes.

It is the joint view of the South Warwickshire Clinical Commissioning Group and the County Council as the Public Health and Adult social care providers that the District Council should consider bringing forward a Supplementary Planning Documents ( SPD) to secure the proper distribution of housing and the implications the potential residents have for supporting care and clinical services.

We are therefore request that a moratorium on C2 applications placed. We also recommend that there should be an introduction of a two-stage process to assess planning application on behalf, i.e. a preliminary panel at Pre-Application stage. This could be made up of WDC, WCC, CCG (inc. local GPs) and NHS to consider any specialised accommodation, particularly as the District continues to attract interest from private developers who are seeking to provide specialised accommodation clearly geared to attracting the private pound and/or an imported population. This has implications for both Health and Social Care as follows:

1. NHS Continuing Health Care budgets are being used to fund services for an imported population rather than local residents. These new (and expensive) care homes or housing developments provide an attractive solution to meeting the needs of the private funder, however, we are still seeing those who cannot afford these prices being moved away from their local communities to where services are available. There will also be a drain on local GP and Nursing resources as these new and sizeable care homes come on stream.
2. Extra Care Housing delivery is complex and continues to struggle when reaching planning and enabling stages as it becomes embroiled in local policies. Therefore there should be planning policy guidance to create the proper balance of C2 and C3 housing for the District.

Subject to the input from the "specialist care and clinical services" panel, a development proposal could then progress to formal application for planning consent.

Heritage and Culture matters

We support the District Councils Local Plan direction in safeguarding and enjoyment of our natural and historic environment together with the district's rich heritage and visitor economy. Our specific comments are:-

Section 4, we would welcome specific reference to the interdependency between the district's tourist offer and the safeguarding of its natural and historic environment, and the provision of heritage and cultural activities and venues.

Section 7, we welcome reference to the need to maintain and develop the heritage and cultural infrastructure to support the needs of new residents and to support new communities in developing a sense of identity and social cohesion.

Section 10 tourism and the quality of the built and natural environment are linked, therefore, the contribution of the high quality of the environment should be specifically stated in any policy to maintain the role of towns as visitor destinations.

Section 17, we feel that the introductory list of cultural venues should include museums and archives. The paragraph on "Seeking contributions" should include heritage and cultural facilities; as communities grow, the cultural infrastructure and activities programme needs the opportunity and financial framework to grow accordingly.

Archaeology
We welcome the acknowledgement given to the importance of the District's historic environment in para. 11.1. However, archaeology and the historic environment in some cases should be joined up.

The document refers to the 'built and natural environment', (e.g. para. 4.11.7, 4.12.14, 10.4, 10.6, 11.2). 'historic areas' or the protection of 'historic assets', these terms appear to be used interchangeably. We recommend that the references to 'built and natural environment' throughout the document be re-worded to reflect that the historic environment is made up of a wide range of different types of heritage assets (including archaeological features, historic landscapes etc), rather than just historic structures.

Para. 11.1 describes the historic environment in terms of statutory protected, designated sites, such as Listed Buildings, Scheduled Monuments etc, and locally important historic assets. There are also a number of archaeological sites across the District that are of national or regional significance but may be undesignated and the local plan should also recognise this
There are also several instances where references to the protection of historic structures (such as the references in PO11 to the submission of nationally important historic assets for listing, and the bringing back of Listed buildings into use), could be expanded to take into account other, non-built, heritage assets. For example, PO11 could be expanded to include the putting forward of nationally important archaeological sites for protection as Scheduled Monuments, not just historic structures for listing.

Further clarification is needed in PO11 by "support the understanding of the significance of Heritage Assets, by: There should be provision for appropriate research for all applications relating to the historic environment".

Further clarification is needed about the reference to the Planning Authority undertaking research for all applications relating to the historic environment, or reference to requiring any planning applications relating to the historic environment to be accompanied by an appropriate assessment of the likely impact that the proposal will have upon the historic environment, as per para. 128, of the National Planning Policy Framework (NPPF). We recommend the re-wording of this section of the document and assistance from the County's specialists can be provided.

Further clarification is needed about the term 'locally designated historic assets' in PO11. It is not clear whether this is referring solely to designated historic assets such as those included on 'Local Lists', or whether this is also referring to historic assets recorded on the Warwickshire Historic Environment Record (HER). We would recommend that reference is made to appropriately considering (and protecting if appropriate) all heritage assets as part of the planning process, whether designated or not, and that reference also be made to heritage assets recorded on the Warwickshire HER. We would also recommend that this policy acknowledge that there may be as yet unidentified heritage assets across the District which may be worthy of conservation, and which may also require protecting during the planning process.

The terms 'heritage assets' and 'historic assets' are used interchangeably throughout the document. We would recommend that the term 'heritage assets' be used in preference to 'historic assets' as this is the term used throughout the NPPF and other policy documents.

We support the reference in PO11 to the use of Article 4 directions to help protect the historic environment.

PO11 proposes protecting the historic through the submission of nationally important historic assets for listing. Not all heritage assets of national importance are listable, some may be better protected by being statutorily protected as Scheduled Monuments or included on the English Heritage 'Register of Historic Parks and Gardens of special historic interest in England'. This policy should reflect this.

We also suggest that indirect impacts of development on heritage assets should also be added to any criteria based policy, for example, the impact that a proposed development may have upon the setting of a heritage asset which may be outside of the planning application site. Whilst there is reference to setting in para. 11.9, this is only referring to the setting of Conservation Areas.

Chapter 11, Para. 11.6 should read 'putting them to viable uses consistent with their conservation'

We also note the intention to draw up Local Lists of heritage assets (PO11); There should be clear methodology for identification of appropriate sites on the basis of our Historic Environment Records data. There should be acknowledgement throughout the Local Plan that open space can support conservation of the historic environment as well as the natural environment.

The list of areas of historic or environmental importance in the District should include reference to "41 Scheduled Monuments". We would also recommend that reference be made to the significant number of undesignated heritage assets within the District which are recorded on the Warwickshire Historic Environment Record.

We welcome that Chapter 15: Green Infrastructure makes reference to the Warwickshire Historic Environment Record (including the Historic Landscape Characterisation and Historic Farmsteads studies) (para. 15.21), however, it is disappointing that no reference is made to these within chapter 11, which specifically deals with the Historic Environment. It should be noted that whilst para. 15.21 states that the District Council has the Historic Environment Record

Proposed development sites
The Strategic Housing Land Availability Assessment (which has informed the choice of preferred development sites included in the proposed Local Plan) should also assessed the impact that the proposed development of these sites could have upon the historic environment.

Whilst the assessment has identified statutorily protected sites on and within the vicinity of the potential development sites, however these have not considered a number of known un-designated heritage assets which the Council may also wish to consider. . These undesignated, heritage assets are of national significance and worthy of conservation. The assessment should also consider the historic landscape character of these areas.

In addition, as noted in our previous responses to the earlier Options paper of July 2008 and the 2009 "Proposed Submission Core Strategy" consultation, there will also be archaeological sites as yet undiscovered which will not be recorded on the HER, and even in areas where no archaeology has been recorded, evaluation may be required to confirm the presence/absence of remains. Consultation on a site by site basis will remain the best means of identifying archaeologically sensitive areas on the basis of current knowledge, as well as areas where archaeological potential will need to be assessed through more detailed work.

Since the individual allocations will need to take account of the impact upon historic environment we recommend that further work be undertaken to identify the issues in respect of the historic environment.

The selection criteria for the major development sites should also include for a thorough consideration of Historic Environment, and proper appraisal is undertaken and allowance made where necessary for preservation of sites of national Importance (in the sense of the 1979 Ancient Monuments and Archaeological Areas Act and the National Planning Policy Framework). We perhaps need a separate meetings to work on a systematic assessment of potential sites being put forward.

Tourism policy - general comments
We support the tourism policy of the Local Plan. Tourism is a significant sector of the overall economy within Warwick District and is recognised as a strategic priority within WDC's emerging Economic Development and Regeneration Strategy, it is recommended that Local Plan polices. Therefore, the District Council should also consider to referencing tourism as part of policy no P0 8 Economy and vica versa.

PO 8 Economy
We support the preparation of the Economic Development and Regeneration Strategy to provide a clear direction for growing and sustaining the economic position of the District Council area.

PO 17 Culture & Tourism
Rural broadband policies and policies for Culture and tourism should be cross referenced to promote the quality of the offer in the District.

It is therefore recommended that an introductory statement along the lines of Weston-Super-Mare might be more suitable:

"The Council will work with partners to support the development and retention of new and existing tourism facilities, for both business and leisure markets and promote their sustainable expansion across the District, whilst maximising their co-locational and cumulative benefits to:

* assist in regenerating our town centres by supporting growth of their retail, evening and night time economies by offering facilities and functions that could encourage spending within the wider areas;
* assist with development of green infrastructure corridors linking destinations and attractions for the benefit of both residents and visitors;
* improve the range, quality and distinctiveness of the District's tourism destination;
* provide high quality hotels and serviced and non-serviced accommodation formats and conferencing facilities;
promote the image and reputation of the District to attract visitors and secure investment."
Town centre tourist accommodation
We support the "town centre first" sequential approach for the further hotel accommodation. To support this and as an alternative, it is recommended that the Council consider the following policy wording:

Within the existing urban settlements of Warwick, Kenilworth and Leamington Spa, proposals that would result in the change of use hotels and tourist accommodation will be permitted unless:
* the proposed use or uses would reduce the overall capacity and attractiveness of Warwick, Kenilworth and Leamington Spa as tourism hubs and result in the loss of an otherwise viable hotel or tourist facility which would consequently harm the provision of tourist accommodation;
* the proposed use or uses would be incompatible with the surrounding area and businesses and would harm the character of the town centre;
* there would be no clear, additional benefits from the proposal in terms of improving the character of the area, the vitality and viability of the town centre and the economic and, cultural and environmental impact on the town as a whole.
Applicants seeking change of use away from existing hotel or tourist accommodation use will need to submit detailed evidence relating to the viability of the business and details of how the business has been marketed.

Rural accommodation

We support tourism in rural areas and we recommend that the Local Plan should have a specific policy to address expansion and re-development of existing tourism accommodation and tourism facilities within the Green Belt.

Accommodation not in permanent buildings
The District Council may wish to consider an additional policy to cover accommodation not in permanent buildings (i.e. camping, caravan and chalet parks). This type of accommodation can be damaging to the character of landscapes, and in rural areas the added light pollution can be intrusive. It is recommended that small scale developments should be supported in areas of open countryside or next to small settlements provided they are not prominent in the landscape and have high quality landscaping. The policy may choose to exclude locations in sensitive landscapes and areas prone to flooding.

Ecological & Geological
We welcome and support the strategic direction outlined in the Preferred Options document in relation to the Natural Environment and would like to make the following suggestions:

4. Spatial Portrait, Issues and Objectives
4.7 - Sites of Importance for Nature Conservation are now referred to Local Wildlife Sites. It is suggested that Local Geological Sites are also listed. You may wish also to consider using the Habitat Biodiversity Audit and the State of Biodiversity Report to provide a Spatial Portrait of the District's Biodiversity.
4.8 - You may wish to add climate change as a pressure in bullet point 9

7. Housing
7.5 - You may wish to add within the important issues a reference to the natural environment such as "Maintain access to the natural environment in both urban and rural settings to reap social, economic and well-being benefits".
PO4 Distribution of Sites for Housing: (A) Allocated Sites - we are aware of the habitat evidence submitted for the previous work on the local plan, but would suggest that a new model has been produced to measure Habitat Distinctiveness and Connectivity throughout Warwickshire, Coventry and Solihull. This approach is placed at the heart of the National Planning Policy Framework as a way to indicate 'sensitivity' of habitats within potential allocated sites and how the site acts within the ecological corridors. We would recommend that this approach is investigated as partners to the Habitat Biodiversity Audit with the knowledge that the habitat data is current and sound.

PO4 Distribution of Sites for Housing: (C) Development of Brownfield Sites - we welcome the comment relating the development having 'no serious impact on the amenity and environment of their surroundings'. However, brownfield sites can be e very important ecological sites in their own right so suggest that this aspect is noted in the future policy.

8. Economy
There is no reference to the relationship between a healthy environment and the economy. It is suggested that this link is made in the introduction to add weight and substance to subsequent paragraphs within the policy such as 8.15. For example a statement could be, "There are proven links between the natural environment and economics (National Ecosystem Assessment, 2010) through an Ecosystem Services approach. It is essential that these links are maintained and enhanced through both the placement and setting of commercial activities coupled with the retention of agricultural and silvicultural practices." Further pictorial reference to explain Ecosystems Service can be found in the National Ecosystem Assessment documentation.

9. Built Environment
We support the 'Sustainable Garden towns, suburbs and village' design guide as well as the Relevant Issues and Strategic Objectives.

10. Climate Change
It is recommended that more be added in relation to Climate Change Adaptation within the introduction to support the last bullet within the box titled PO12 Climate Change.
12.25 - 12.26 These paragraphs outline the impacts and issues relating to Climate Change Adaptation, however, it is felt that this topic could be expanded upon within future documents, e.g. an addition Supplementary Planning Document or equivalent. This additional document could promote green roofs, green walls and other ways to promote urban cooling etc. WCC Ecological Services is able to signpost you to a couple of other Local Authority documentation on this topic.

11. Transport
It is recommended that reference be made to the Natural Environment White Paper (2011) and the importance of transport networks and ecological connectivity assets.

12. Green Infrastructure
In our opinion we suggest that this chapter is well balanced and support its approach. It is suggested that additional references to Ecosystem Services, the Warwickshire Biological Record Centre and the importance of using up-to-date ecological and geological / geomorphological data is used is the assessment of development proposals. These should be added to the future policy and the Ecological Services are able to assist you with this advice, subject to resources.
By the time the future policy is formed the Sub-regional Green Infrastructure Strategy will have been produced for consultation and can be more fully referenced as a mechanism to deliver your objectives outlined in this chapter.

18. Flooding and Water
In relation to ecology it is recommended that there is future referenced to the safeguarding or promotion of natural flood alleviation areas at strategic sites within the district as short, medium and long term aspirations to assist with flood risk measure. We are aware that this may form part of the Catchment Flood Risk Management Plan (18.9) or fall within the Sustainable Urban Drainage Approving Body's remit, but would suggest that these strategic potentials should be particularly noted within the future policy. These sites could then be potential delivered through the biodiversity offsetting metrics (15.16).

It is also recommended that a further discussion be held regarding the assessment of allocated sites using latest modelling of habitat data.

Comments regarding minerals safeguarding
Para. 143 of the National Planning Policy Framework (NPPF) requires that in preparing Local Plans, local planning authorities should define Minerals Safeguarding Areas and adopt appropriate policies in order that known locations of specific mineral resources of local and national importance are not needlessly sterilised by non-mineral development, whilst not creating a presumption that resources defined will be worked; and define Minerals Consultation Areas based on these Minerals Safeguard Areas.

The British Geological Survey's 'Guide to Minerals Safeguarding in England' (October 2007) provides the following advice:

"A district DPD could include policies that set out the general approach the district will take when determining proposals for non minerals development within or close to MSAs or existing mineral workings. Such policies should acknowledge the procedures for consulting the MPA on the existence and extent of mineral resources present and considering the case for prior extraction of mineral where appropriate."

In June 2009, the British Geological Survey (BGS) completed a piece of work to delineate Warwickshire County Council's Mineral Safeguarding Areas (MSAs)/Minerals Consultation Areas (MCAs). The BGS identified the extent of individual mineral resources in Warwickshire and these, in turn, were used to develop safeguard areas for each mineral. WCC would suggest that these MSAs/MCAs are either identified on WDC proposals maps and/or a link is provided in the Local Plan to Warwickshire's Minerals Safeguarding webpages. This will help to ensure that minerals implications are taken into account as part of decision making for District planning applications.

We would request that where certain applications may potentially sterilise minerals deposits within an MSA, the District Council consults the County Council. If the County Council concludes that minerals reserves may be sterilised, the applicant may be required to submit a Minerals Survey to establish whether the reserve is economically viable. In some cases, the County Council may insist that prior extraction of the minerals is undertaken prior to the non-mineral development being carried out. It is considered that the inclusion of this procedural information will improve the effectiveness and deliverability of the policy.

In assessing the Preferred Options, it is noted that there appear to be sand and gravel deposits under the 'Whitnash East', 'West of Europa Way' and 'South of Gallows Hill' sites - see attached map (appendix A). It would be beneficial if a minerals survey was undertaken by the developer to determine the quality and depth of the resource and to establish the feasibility of prior extraction.

Waste
Policies for the development of major residential development sites should include waste management issues as part of the overall design of larger residential/retail developments. For example, provision for waste recycling/composting on site will ensure that waste is managed in accordance with the principles of proximity, self-sufficiency and the Waste Hierarchy. Furthermore, there is a need to provide adequate waste facilities for flats and apartments - see WRAP's 'Good Practice Guidance - recycling for flats' WRAP, available at http://www.wrap.org.uk/content/recycling-collections-flats.

It should also be noted that policy CS8 of the Warwickshire Waste Core Strategy (due for Submission in September 2012) seeks to safeguard existing waste management sites. At this stage, it is considered that none of the preferred option sites are likely to prevent or unreasonably restrict any waste sites. However, if necessary the Council may object to other proposals which may sterilise important waste facilities (e.g. those delivering significant waste management capacity to meet the County's landfill diversion targets). To prevent this, WCC intends to supply each District/Borough Council with its latest waste site information, possibly in GIS format, so that the County Council can be consulted on any proposals within reasonable proximity (e.g. 250m) of existing waste management facilities.

Customer Services/One Front Door/services that support communities and families.

The County Council is open to co-location, co-access, and co-servicing of support services including support for the elderly, vulnerable adults, and families , however, these services should be located or are accessible to communities they serve. Further for new development these key services should evolve with the phasing for large developments. One solution could be providing lay-bys with " electric hook up points" for mobile services (including a mobile shops) this would build up sufficient demand before most of the dwellings are built. Consequently, make communities and developments sustainable.

Transport and Planning matters
The key transport strategies are contained in Warwickshire Local Transport Plan 2011-2016. The County Council is already working with the District Council to assess the transport impacts of various development scenarios as part of our Strategic Transport Assessment work and will be responding directly on this and other relevant transport matters. The key matters are access and sustainability of the pattern of development for homes and jobs.

We support the direction and economic strategy of the Local Plan and we need to undertake further work on some key matters ie transport, archaeology and ecology matters.

See attachment

Thank you for the opportunity to comment on the consultation for the aforementioned document. As the market leader in the provision of sheltered housing for sale to the elderly, McCarthy and Stone Retirement Lifestyles Ltd considers that with its extensive experience in providing developments of this nature, it is well placed to provide informed comments on your 'Local Plan Preferred Options' insofar as it affects or relates to housing for the elderly.

McCarthy and Stone are satisfied that the Local Plan Preferred Option's report indicates that there is a 'need to provide more housing to meet people's needs in the future, particularly those of older people', and that this is clearly identified as an issue within the District. They are particularly pleased that the Local Plan aims to provide 'sustainable levels of growth in the district' by allowing 'providers to meet the special housing needs of the growing number of older people'. However, we are concerned with the distribution of housing, and would strongly encourage policy to express support for the re-development of urban brownfield land. My Client would stress that policy should give brownfield sites precedents over Greenfield sites / edge of settlements.

Furthermore, McCarthy and Stone commend the Local Plan's recognition of the 'need to provide more housing to ensure that the needs of current and future residents are addressed, particularly those of older people'; indicating that the 'the highest rate of projected population growth in the future is expected to amongst those aged 65 and over'. Furthermore, My Client is also pleased that the Local Plan quotes the SHMA's estimation 'that 18.7% of future need is likely to be for specialist housing'.

My client supports the proposed policy PO6: Mixed Communities & Wide Choice of Housing, which states that 'all strategic sites will include Extra Care Housing schemes located close to local facilities'; and that all 'proposals for Retirement Villages and Continuing Care Retirement Schemes will need to meet locational criteria and be accompanied by evidence that the homes/bed spaces meet the needs of the community'. However, McCarthy and Stone would stress that the policy should take into account general sheltered schemes, which will widen the housing choices available for older persons within Warwick District Council

The need for specialist housing for the elderly is expressed within the Strategic Housing Market Assessment (2011), which 'indicates that 9% of market demand (37 homes per annum) will be for specialist housing, particularly for older people'. Critically, the SHMA states that 'around three quarters of older person households are outright owners', and that older households are 'very likely to under occupy homes, with two-thirds living in homes with three or more bedrooms'. The SHMA also stipulates that 'there may be potential for policy to seek to reduce under-occupation by providing support and incentives to households to downsize. This may help to release larger housing for family households in priority need'. This is supported in the SHMA through a later statement that 'over the plan period to 2031 there should however be some potential to release supply of existing family housing by supporting downsizing of older households and providing specialist housing to meet their needs'. Additionally, the SHMA also states that 'the Council should consider inclusion of specific policies for specialist housing within the Local Plan on this basis. McCarthy and Stone would support this and encourage the Council to review and strengthen the policy for specialist housing for the elderly.

Despite the above, McCarthy and Stone is concerned that the draft Local Plan does not provide for the delivery of actual policies. There is clearly an existing and growing elderly population and a need for specialist housing. This is supported within the Local plan which states 'the SHMA estimates that 18.7% of future need [for market housing] is likely to be for specialist housing, of which 9.7% is likely to be for affordable specialist accommodation'.

It is therefore vitally important to address this need, as encouraged in the National Planning Policy Framework (NPPF). McCarthy and Stone would urge that a specific policy for elderly housing be introduced within your Local Plan.

McCarthy and Stone suggest that the following be introduced to positively support the delivery of specialised accommodation for older people including sheltered housing:

"Development proposals for accommodation designed specifically for the elderly will be encouraged provided that they are accessible by public transport or a reasonable walking distance to community facilities such as shops, medical services, places of worship and public open space."

The National Planning Policy Framework
It is necessary to consider the National Planning Policy Framework (NPPF) adopted on March 27th 2012. The NPPF states that at the heart of national policy is 'a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking'. The Ministerial foreword acknowledges the challenges the country faces in accommodating the growing elderly population, emphasising 'we must house a rising population, which is living longer and wants to make new choices', and 'development that is sustainable should go ahead, without delay - a presumption in favour of sustainable development that is the basis for every plan, and every decision'.
Within the 'three dimensions of sustainable development' (economic, social and environmental), the NPPF stipulates that the planning system should be 'supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations' [emphasis added]. The NPPF calls for local planning authorities to seek out opportunities 'to meet the development needs of their area', and emphasises that 'the Planning system should be pursing sustainable development through widening the choice of high quality homes'.
In addition to this, the Framework highlights the need to 'deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities. Local planning authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community...such as older people' [emphasis added].

To ensure that the Warwick Local Plan is delivered in line with the NPPF, it is important to acknowledge the NPFF's statement that 'local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market'. Reviewing the evidence within the Local Plan Preferred Options report, there is a clear market need for specialist housing for the elderly within Warwick. The Framework advises that:

'local planning authorities should have a clear understanding of housing needs in their area', and that policy should 'identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which meets household and population projections, taking account of migration and demographic change and addresses the need for all types of housing...including housing for the elderly' [emphasis added].

Furthermore, the Framework stipulates that local policy should cater for 'housing demand and the scale of housing supply necessary to meet this demand'.

It is therefore considered that much needed housing for the elderly should be encouraged, and that appropriate planning policy should play a part in delivering specialist housing to meet an evident housing need.

Policy PO5: Affordable Housing

In response to Policy PO5: Affordable Housing, and the fact that the policy will apply to 'developments which contain self-contained units of accommodation including specialist homes for older people', my Client would highlight paragraph 7.56 within the Local Plan Preferred Options, which stipulates that '18.7% of future need is likely to be for specialist housing...This type of housing is most likely to be for older households'. Therefore, the Local Plan recognises the need for specialist accommodation for the elderly.

A recent report "Housing Markets and Independence in Old Age - Expanding the Opportunities", by Professor Michael Ball of the University of Reading, which was presented at a House Commons launch event in May 2011, should be reviewed. This report, suggests that private sheltered housing for the elderly could be given an enhanced planning status, similar to affordable housing, to encourage sufficient levels of delivery from the private sector to meet existing and future demand, stating that:

'to improve the supply and lower the price of owner occupied retirement housing (OORH), this type of housing should be redefined as the equivalent of affordable housing in terms of negotiations with builders over development charges. Treating all OORH as a form of affordable housing in planning terms, because of its significant personal and community benefits, would help reduce prices and increase availability. However, to impose price or quality caps on part or all of it would damage supply. Rather this proposal suggests that all OORH new build should be given enhanced planning status alongside low-cost home ownership for younger households, which is already treated as a form of affordable housing' (emphasis added).

PO12: Climate Change

McCarthy and Stone are concerned about the inclusion of Policy PO12, and the viability of specialist housing for the elderly if this is enforced. McCarthy and Stone are particularly concerned with the 'requirement that seeks a 20% reduction in carbon emissions from development to include a contribution from renewable and low carbon technologies'. This 20% reduction is not in line with Building Regulations and national policy, which suggest a 20% reduction is only achievable by 2020.

Conclusion
The provision of owner-occupied specialised housing for the elderly will widen the housing choices available for older persons within Warwick District Council. It will allow the local elderly population to move into accommodation that enables them to remain living independently within the community and out of institutions, and therefore continue to contribute to the community, whilst enjoying peace of mind and receiving the support that they need.

McCarthy and Stone stress the need to consider addressing the current and future housing needs of older people within your Local Authority, and for your 'Local Plan Preferred Options' to further acknowledge the role that owner-occupied sheltered housing play in meeting older person housing needs, as well as Extra Care schemes, and in providing housing choice for the wider community by freeing up valuable, under-occupied family homes in the local area.

The Town Council of Royal Leamington Spa broadly welcomes the Plan, and below gives a more detailed response on particular items of the Plan. We expect to incorporate our vision for Leamington Spa into a Plan for the Town in due course.

Delivering Growth (PO1 & PO3)

We welcome the broad location of growth. We agree that an annual average increase of 600 new homes for the next 20 years is a reasonable and fair target. Many of the Wards in the Town are already densely populated, and we note that the Plan anticipates some growth in these areas.

Affordable housing (PO5)

We approve the requirement that 40% of new homes on developments of 10 or more dwellings, and 5 or more dwellings in the rural areas, should be affordable housing.

Mixed communities (PO6)

We approve the option for a mix of housing, and note that strategic sites will include Extra Care Housing. We believe in a balanced and mixed population and welcome families and single people in all our Wards.

Whilst the Town Council is proud of the diverse population in Leamington, we would request the District Council introduce a policy to restrict the number and density of Student Houses and Houses in Multiple Occupation to ensure that they do not adversely impact on the character of neighbourhoods to the detriment of family households. The Town Council requests close involvement in the input into the policy on mixed communities.

We would also welcome developments that demonstrate a more imaginative provision for students, that are not simply converting existing family housing.

Economy (PO8)

We welcome the proposals to ensure a wide range of employment. We particularly support the regeneration and enhancement of existing employment areas.

The Town Council believes that the Local Plan needs to encourage the continuing growth of the already successful Computer Games industry and the further development of Silicon Spa as the primary UK centre of excellence for the industry. The Local Plan also needs to support further growth in the innovative automotive industry much of which is based in the District or on the edge of the District as this is likely to provide future employment in the Leamington and Warwick conurbation.

Retailing and Town Centres (PO9)

We welcome the support for Town Centre retailing and a Town Centre first message. We believe that the `Town' includes the whole town, and that developments should be considered in the area south of Regent Street, in the Parade and in Old Town.
The Town Council believes that we should promote and support Fair Trade initiatives.

We are committed to strategies that promote the town for retail provision, leisure, entertainment and eating establishments. We can promote our parks and green spaces as important attributes of the Town Centre.

However, we see that `shopping' also includes local shops. The Town Council would prefer there to be a policy on where supermarkets should be located, and that local communities should be consulted about any new proposals for supermarket development.

Historic Environment (PO11)

We welcome the intention to protect the historic environment. We see that this includes the historic areas of the Old Town, and would be pleased to work with the District Council in listing the historic assets, and reviewing the Conservation Area. We are pleased to note the District Council's encouragement of regeneration of appropriate sites within the historic environment. We strongly affirm that the historical integrity of the area is threatened by sex entertainment establishments and oppose any such establishment, which we see as an inappropriate development.
The Town Council supports the Blue Plaque scheme, and the Guild of Guides Walks.

Climate Change (PO12)

As a Transition Town, the Town Council welcomes the intention to include a policy on climate change.

Transport (PO14)

We support the option to minimise the need to travel, and to promote sustainable forms of transport. In addition to the proposals in the Plan, we believe that a higher priority should be given to cycle provision, and to ensuring that all new developments encourage ease of access by bicycles between areas of the District. This includes cycle lanes and provision to park cycles.

Residents should also be encouraged to travel by bus for work and leisure with the encouragement of more quality bus routes into and across Leamington.

Encourage the co-ordination of different forms of transport to encourage more residents to travel by foot, bus, train and bicycle.

Green Infrastructure (PO15)

We welcome the intention to protect and enhance the assets as identified in the Plan. We are pleased to see the introduction of "Green Wedges" as an alternative to areas of restraint.
We would also be in favour of consideration of a policy that considers garden preservation. We support greener neighbourhoods through our tree planting scheme, and through our support of Allotment Societies.

Culture and Tourism (PO17)

We support the intention to develop this appropriately and would welcome opportunities to share ideas on promoting the cultural facilities of Leamington. We believe there is scope for improving the visual impact for visitors to Leamington who arrive by rail or canal.

We are proud of the assets of the Town and are committed to maintaining them as welcoming and friendly venues for residents and visitors.


ADDITION

Evening Economy

The Town Council is concerned that the District Council's Policy on the Evening Economy has not yet been completed and so is not available for consultation. The evening economy is important to Leamington, but unless it is carefully considered it can produce public dangers, so it is important to the Town that there is a well-considered policy in place that takes account of the needs of residents, visitors, the businesses and public safety.

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On behalf of the Federation of Small Businesses in Coventry, Warwickshire and Solihull this paper responds to the consultation on Warwick District Councils Local Plan.

The FSB is the UK's largest business support organisation with 200,000 members nationally and 3,000 of those members in Coventry & Warwickshire.

FSB Warwickshire & Coventry response:
Despite the economy falling back into recession small business confidence levels remain positive, but we aren't out of the woods yet. Small firms still face challenges from weak demand and rising costs. In spite of these challenges, many small firms want to grow. Warwick District Council must put long-term measures in place to instil this optimism - in turn the economy can grow.

Planning:
The planning system is a constraint on small businesses. Unlike major infrastructure providers or large businesses, they often need only minor changes to their premises in order to diversify and grow. Almost half of our members have found the planning system complex and difficult to understand, while nearly 40 per cent said that it was a costly process. So, the planning process must be made much simpler, quicker and cheaper for small firms. This must be complemented by robust protections for businesses in existing town and commercial centres. We welcome Warwick District Council's commitment to a strong expression of 'Town Centre First' policy and recommend that;

* Planning policy must take into account the needs of small businesses.
* There should be a range of affordable local business premises available, both to encourage new enterprises and allow existing businesses to grow.
* Measures are needed that would allow planners to refuse any out of town application that would draw business activity away from the town centre.
* Planning permission should be designed to positively encourage development of appropriate business premises in town centres.
* Provide timely advice for businesses wanting to build or expand their premises. Obtaining planning permission is often a minefield.

Housing
The provision of affordable housing in order to help address skilled labour market concerns should be central to the council's local plan.

The costs of housing, transport and daily life are often higher in rural areas, and in some places the presence of a disproportionate number of retirees and properties used as second homes have exacerbated this situation, causing house prices in rural areas to rise. Yet this has not been met by corresponding rises in rural wages, which are often lower than in urban areas. This has led to a serious labour market imbalance in some areas, which needs to be addressed. Your housing policy must redress the balance and secure a bigger supply of affordable properties as a priority.

Broadband:
It shouldn't matter where a business is located. With the technology we have today all firms should be able to trade overseas, throughout the UK, and from town to village. However, our research shows that six in 10 (63%) of small firms are suffering with the speed of their broadband. Another 34 per cent are unhappy with the reliability of their connection and a quarter (24%) with the value for money. This blocks the growth of businesses. Rural firms and households have had even longer problems with accessing broadband and slow speeds. To close the digital gap between rural and urban firms, we feel 20Mbps superfast broadband should be available across the countryside. Warwick District Council must consider fast and reliable broadband within their development and growth plans for the District.

Rural Economies:
Our rural economies have the potential to make a huge contribution to economic growth, but only given the right conditions. The rural economy is dominated by small businesses but they struggle against the odds of poor communication, unreliable broadband services and patchy transport services. These exacerbate the distance they are from their markets. Rolling out broadband in all rural areas and looking strategically at transport will ensure that these businesses can grow and prosper home and abroad.

Market towns and village centres have also declined with the closure of anchor businesses such as the village pub and post office. Warwick District Council must consider the community infrastructure when developing new housing sites and how they will be integrated with the business community.

Transport & Parking:
The provision of suitable public transport links is crucial to helping small businesses access markets. Reliable and frequent public transport makes it practical for employees to seek work in the local community without having use of a car. Likewise, frequent rail and bus services bring customers and tourists to local businesses such as shops, hotels and B&Bs.

Those living and working in rural areas face a far greater challenge getting from A to B than their urban counterparts. Indeed, on average, people living in the most rural areas travelled 45 per cent further per year than those in England as a whole and 53 per cent further than those who are based in urban areas.

The need to travel greater distances means efficient transport links and infrastructure is essential to realising the potential of business economies. It is crucial that firms are served by a transport network that allows both individuals and small businesses too effectively and efficiently move goods and people, both within rural areas and, importantly, urban areas where larger, more diverse markets often lie. The added benefit of good transport services is that it will attract additional visitors and their spending power to local economies. Warwick District Council must consider suitable public transport links when developing new housing & business sites.

There is a clear correlation between short term revenue driven parking policies and the closure of businesses on the high street. Therefore parking should be seen as a vital service which is an integral part of transport policy not as a quick means of raising revenue. Parking policies are all too often a short-term revenue grab, to the detriment of business and the wider community, and ultimately lead to longer term decline in revenue generation for local authorities.