C. Homes for Older People

The population is aging and secure independent living will be a requirement for many citizens.

I support the requirement to provide homes for older people but these should be available in villages as well as in larger strategic sites.
This will not only enable older people to remain in the village that has been their home but release larger houses from single occupancy to make better use of the existing housing stock.

Given the proximity of the Exracare Charitable Trust - the pioneers of extracare housing it would be great if one of their developments were able to be included in the District.

Pleased to see inclusion of extracare facilities into each location. We really need Retirement Villages too which we would like to move to in time!
These schemes would reach their full potential if located in existing towns where residents could keep in touch with friends, get to familiar facilities and the schemes could offer outreach to elderly living in the community.

I think there is a case for 'up market' retirement complexes e.g. small one or two bedroomed bungalows on a gated community which suit those downsizing from substantial houses who don't want to live in a flat!

Only Part D of PO6 is not fully supported by the Leamington Society:

A. The Leamington Society fully supports the principle of mixed housing and varied types but the means chosen in PO10 will not achieve this:
Garden suburbs prescribes row upon row of uniform suburban plots and is too homogenous. Only a small proportion of the population wants to grow their own food and cultivate a big garden. Many have neither the time, energy nor inclination for this and would be happy with communal parks and gardens and playing fields, which have scale and variety and someone else does the maintenance.
To meet varied need, a wider and more imaginative mix of terraced houses, flats and maisonettes around courtyards, with off-road parking facilities for cars and bicycles and rubbish bins, would take up less land and be more appropriate.
We consider it very important to avoid high concentrations of student accommodation and HMOs to maintain a balanced community. We recommend the introduction of maximum percentages of such properties or populations within specified areas. The number of houses in multiple occupancy, whether by students or others, has reached extremely high levels in much of south of the River Leam in Leamington (often referred to as Old Town). WDC has mapped the density of registered HMOs; see Item 6 and Appendices at
https://estates3.warwickdc.gov.uk/cmis/Meetingdates/tabid/73/ctl/ViewMeetingPublic/mid/410/Meeting/225/Committee/29/Default.aspx

This high density places an enormous strain on-street parking space. Therefore the new local plan needs to
* control both the density of HMOs
* require reasonable levels of off-street car-parking in all new HMOs
* ensure these requirements apply to HMOs, student accommodation and student hostels irrespective of their designation.
The Council should decide whether some areas of Leamington have already reached saturation point, and look at how well located student hostels could help manage the problem of over concentration.

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.

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.

See attached

Scanned form

The three most important issues in Warwick are:

- all the empty buildings in the centre of Warwick
- traffic congestion
- need for sporting facilities for all

Park and Ride

To make any impact on congestion in Warwick there needs to be a Park and Ride on all 3 roads into Warwick.
- Birmingham Road, Banbury Road and Stratford Road.
- One Park and Ride into Warwick is not enough

If these 3 Park and Rides were in situ then all school children being taken by car to the private (in particular) and state schools should be encouraged to take the Park and Ride. Consultations need to take place at all the schools.

There is always so much talk about the traffic in the centre of the Warwick and anyone who lives in the centre of Warwick knows that the main cause is the school run.

Northgate Street

Old county education offices converted into luxury apartments with parking spaces. I think there are many older people in particular who would like to downsize from their large family homes into the centre of Warwick but they want to move into spacious and luxurious accommodation. It does not need to be sheltered accommodation.

On the county court side I would like to see this developed into a hotel. Warwick needs a good hotel in the centre.

One of the old courts could be converted into a new Registry Office for marriages. The present Registry Office leaves a lot to be desired. On busy Saturdays the guests are queueing up on the busy High Street. When you enter the present building the first sign you see is "Relate" for marriages in trouble. Hardly appropriate when you are about to get married.

Old Lugg and Gould Building, Fire Station, Leper Hospital, Masters House, Old Printing Works in Bowling Green Street

All empty and all need to be converted to houses/offices in the centre of Warwick.




Sporting Facilities in the New Plan

An Ice Rink built in the district for skating, ice hockey teams, curling teams etc. This would seem to be a good opportunity to put this in the Local Plan which would be of benefit to the whole of the Warwick District.

Tennis courts/netball courts - free to use - incorporated in all the proposed housing developments. Money to be set aside for an organizer/coach for coaching/playing activities for after school/school holidays and daytime activities for young children and adults/retirees.

Scanned form.

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

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


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

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


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

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

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


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

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

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

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

PO14 Preferred options: Transport

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

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


PO15 Preferred options: Green Infrastructure

The policies set out in PO15 are supported


PO16 Preferred options: Green Belt

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

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



PO17 Preferred options: Culture & Tourism

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

The low growth option makes that loss unnecessary.

PO18 Preferred options: Flooding & Water

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

See Attachments

On behalf of Barwood Strategic Land LLP and the landowners we write in support of their
respective interests at land 'south of Gallows Hill/ west of Europa Way, Warwick'. This site is
identified in the Local Plan Preferred Options as a location for growth delivering 1,600 dwellings
in phases 2 and 3 of the plan period along with employment land, open space and community
facilities.
Land interests within the proposed allocation are also held by William Davies and Hallam Land;
it is intended that all developers and landowners will work together to secure a comprehensive
masterplanning approach to the development of this site.
We respond to the respective policy areas and chapters below:
1. Part 1: Setting the Scene and Summary
- In setting the strategy, it should be made clear the time period that the plan is proposed
to cover. For example, at 1.2, there is reference to the next 15 years and only later in
the document is confirmed that that the plan period covers 2011 to 2029.
- It is noted that paragraph 4.2 makes reference to the fact that the District could grow by
as much as 15% over the next 15 years (from a current population of 138,800) - this
represents an increase of some 20,820 residents. We highlight that the 2008 based
household projections shows growth from 62,938 households in 2011 to 77,955
households in 2029. This represents an increase of 15,557 households. The 2006
based projections showed 17,110 households over the same period. The 2010 based
population projections show very similar population growth to the 2008 based projections
and although the latter remain the most up to date, it is expected that the 2010 based
CLG household projections will be very similar.
- Paragraph 4.10 should be revised to make reference to the need to ensure that Local
Plan meets the full, objectively assessed needs for market and affordable housing as
required by the NPPF.
2. Delivering Growth - Housing / PO1: Preferred Level of Growth
- The preferred level of housing growth is proposed to be 600 dwellings per annum
(totalling 10,800 dwellings) over the plan period, which when deducting commitments,
small SHLAA sites and windfalls results in a need to identify and allocate land for 6,986
dwellings. The Council have disregarded Option 2 (employment led growth and 700
dwellings per annum) seemingly solely on the basis that there is a lack of certainty that a
sufficient number of homes on strategic sites could be delivered within the plan period.
Using the Council's own calculations, delivering 700 dwellings per annum would result in
the need for an additional 1,800 dwellings to be found on allocated sites. Part of the
justification relates to the perceived lead in times for the delivery of the larger sites;
however the Council's own phasing programme is a self-fulfilling prophecy in this regard.
Phasing the larger allocations in Phases 2 and 3 (i.e. post 2019) could result in a
significant number of dwellings coming to the market at the same time and making it
difficult to therefore deliver an additional 1,800 dwellings in full within the plan period.
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We would suggest that the Council allows the market and the development industry to
regulate itself in respect of the phasing and the timing of the delivery of development.
To allow the larger allocations to make a start earlier in the plan period will ensure
steady delivery of housing over the life of the plan. It is not in a developer's own interest
to saturate the market however steady delivery on a number of sites over a number of
years will promote healthy competition and ensure sufficient time to allow such sites to
be built out in full. Furthermore, in doing this, there would exist the opportunity to
allocate land for the 'missing' 1,800 dwellings which would make a bigger step towards
meeting the Council's housing need.
- In addition, we highlight that the NPPF makes reference to development which is
sustainable going ahead without delay. It follows that in order for a site to have secured
an allocation in what will be an adopted Local Plan, that site must be sustainable and
therefore in accordance with the NPPF, there is no need for that site to be held back by
an arbitrary phasing policy.
- The Localism Act enshrines a Duty to Cooperate on Local Authorities when preparing
plans. In the event that Warwick District does not meet its own housing need in full, we
see no evidence of adjoining LPA's being prepared to take on and meet that need. The
District is bounded by the following LPA's:
- Stratford District: Latest draft Core Strategy did not propose to accommodate sufficient
growth to meet its own needs. No proposals to meet unmet need from Warwick District.
- Coventry: Latest draft Local Plan does not propose to accommodate sufficient growth to
meet its own needs. No proposals to meet unmet need from Warwick District.
- Rugby Borough: Adopted Core Strategy does not include any proposals to accommodate
unmet need from Warwick District.
- It is not therefore clear the way in which the Duty to Cooperate has been carried forward
or the way in which the District's housing need will be met in full, particularly given that
the household increase is projected to be closer to 15,557 households rather than the
10,800 households currently being planned for.
- Further justification for using lower housing targets is provided in paragraph 5.22 where
it is stated that using Option 2 would meet the projected change in employment between
2011 and 2031 as identified in the West Midlands Integrated Policy Model. However the
Council consider this to now be optimistic as it was carried out in 2010 and forecast an
increase in employment growth from 2011. We highlight however that throughout the
NPPF there is reference to the need to 'plan positively' and the need to stimulate and
secure economic growth. It would appear that the Council are revising their growth for
the period to 2029 (i.e. the long term) because short term growth has failed to
materialise. This cannot be said to be planning positively or assisting in securing
economic growth.
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3. PO3: Location of Growth
- The components of growth are reviewed below:
- Committed Housing Sites (1,224 dwellings): whilst clearly committed sites, we question
whether it is appropriate to include all of these sites and not include any allowance for
non-implementation. A 10% non-implementation rate is the industry 'norm' which we
consider should be applied here, thus reducing the commitments to 1,102 dwellings.
- Small Urban SHLAA sites (290): We seek clarification as to where these sites fall within
Table 7.2 of the Draft Local Plan (DLP).
- Other Windfall Housing Sites (2,300): Paragraph 7.25 of the DLP confirms that the
Council consider there to be a limited supply of land within the existing built up areas of
the towns. Windfalls can be included if the Council can demonstrate that such sites have
consistently become available in the local area and will continue to form a reliable source
of supply having regard to the SHLAA. The Council's SHLAA methodology confirms that
a minimum site size of 5 dwellings was used and that Officer's did not rely solely on sites
which supplied to them by developers or landowners but also conducted their own
research including reviewing areas currently in non residential use and looking at small
scale developments such as change of use of existing buildings. It would therefore
appear that the Council have had every opportunity to identify suitable residential sites
and include them in the SHLAA. With the removal of rear garden land from the definition
of previously developed land, we consider that the scope for new windfall development is
much reduced and that windfalls will no longer continue to make up a significant element
of future supply. Furthermore, under the banner of the NPPF and the requirement to
plan positively, windfalls should be seen as a 'bonus' rather than forming approximately
20% of the overall supply.
Land South of Gallows Hill
- The distribution of housing growth across the District is supported with particular
reference to Land South of Gallows Hill. It is noted that within the Council's Landscape
Character Assessment (February 2009), it is concluded that the study area is not suitable
and the rural character should be safeguarded from development. It is however clear
that this study has considered landscape character in isolation and this study should be
considered 'in the round' as is only one part of the evidence base underpinning the Local
Plan. The NPPF is clear that economic growth is a priority and that economic, social and
environmental factors have to be balanced against each other.
- The developers of this site will be commissioning technical and environmental work to
underpin the draft allocations; this will include detailed landscape and visual work to
demonstrate ways in which the site can be developed without adverse landscape impact.
- Whilst the developers will be working together to ensure a comprehensive approach to
the delivery of the site, we consider it important to recognise that within this should exist
the flexibility to ensure that each developer can bring parts of the site forward at their
own pace within an overall masterplanned approach. The delivery of large sites is often
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hampered by requirements to submit a single planning application which can cause
significant delays and is often to the detriment of the site itself.
4. PO5: Affordable Housing
- Whilst we do not object to the provision of affordable housing in principle, we do not see
any up to date evidence of the way in which the appropriateness of the target as been
assessed in terms of the financial viability of development in accordance with paragraphs
173 and 174 of the NPPF. Paragraph 7.43 of the DLP makes reference to a November
2011 document and an Addendum dated May 2012. The May 2012 document does not
feature in the Evidence Base on the Council's web-site and therefore we reserve the
right to make further representations in this respect upon publication of this document.
5. PO6: Mixed Communities and a Wide Choice of Housing
- We consider that sufficient flexibility should be included within any policy to ensure that
account is taken of up to date market demand in addition to the SHMA's. The latter can
become obsolete very quickly and clearly, if developers feel there is no demand for a
particular type of property then they will not build it, which can result in stalled sites and
lower rates of housing delivery.
- Lifetime Homes: there is no national policy which requires the provision of Lifetime
Homes and we see no justification which supports 25% provision.
- Homes for Older People: whilst the provision of extra care housing is supported, these
have very site specific criteria with operators having specific requirements in respect of
site location and suitability. A site which is suitable for market housing may not be
suitable for extra care housing and it is important to ensure that this policy is not applied
so rigidly so as to sterilise areas of land or stall sites.
6. PO8: Economy
- It is noted that the Council propose to consider allocating a 'proportion' of the site south
of Gallows Hill for employment. The provision of mixed use development is supported
although clearly further clarification is required on the definition of 'a proportion'.
7. PO10: Built Environment
- The Council's Garden Towns, Suburbs and Villages prospectus is supported.
8. PO12: Climate Change
- We have reviewed the Council's evidence base and do not see any case for the
introduction of a 20% climate change policy. We are also disappointed to see a
continued emphasis on renewable energy provision within new developments (when the
Council themselves acknowledge the disadvantages with some renewable technologies)
as opposed to the emphasis being placed on energy efficiency. If the overall aim is seek
a reduction in carbon emissions, we fail to see why this should be achieved through
renewable energy rather than energy efficiency measures.
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9. PO18: Flooding and Water
- Whilst the policy as a whole is supported it is noted that much of this replicates national
guidance and is therefore superfluous. Furthermore, the requirement that all new
developments include SUDS is unfeasible. There are some instances where SUDS
schemes are not feasible or viable and this should be recognised within the policy.
10. Draft Infrastructure Planning
- Whilst the provision of a draft Infrastructure Plan is supported to assist in providing
certainty to developers when bringing forward new sites, particularly in respect of the
larger strategic sites. We consider that further refinement of this plan may be needed.
For example, within Warwick and Leamington Spa, 6 new primary schools are currently
being considered at the same time as capacity in a number of existing schools is also
identified. It is noted that the NPPF advocates a CIL charging schedule being prepared
in tandem with a Local Plan if possible and we consider this may be appropriate in this
case to assist in determining the total cost of items identified in the Draft Infrastructure
Plan. This is of particular importance when reviewing the Strategic Transport
Assessment Overview Report which identifies a requirement of up to circa £5,000 per
property for transport infrastructure without taking into account any other infrastructure
requirements or planning obligations.

See attached documents

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

See attachment.

As scanned