PO9: Retailing & Town Centres

My husband and I had a double shock this weekend; firstly we were amazed to find out that the Ford site is going to be home to yet another supermarket . How many large supermarkets can you squeeze into a 1/2 mile radius?? We thought with the reported housing shortage, this would be an ideal spot for some affordabe housing, and well suited to people without their own means of transport. Instead, it seems that the decision was based on who can offer the biggest financial sweetener, with little thought to what the local community actually needs.

Whilst this grumble was still fresh on our lips, we decided to have a nice country stroll at the end of Guy's Cliff Avenue, and discovered the various campaign leaflets informing us that the council has now decided that the green belt is now fair game for housing developers.

We are angered by the apparent disregard for our few remaining areas of countryside and feel that a clear message should be given to the individuals that think the rules protecting the flora, fauna and rural life in these areas can be changed at a glance based on a short-sighted whim of a few narrow minded individuals. These areas cannot be replaced.

1. Introduction & Background
We act as planning consultants for Barclays Bank plc ("the Bank") in respect of the Local
Development Framework (LDF) for the District and this letter forms the Bank's response to
the above consultation. As a long-established business, the Bank has made a substantial
contribution to the vitality and viability of the District's town centres over the years that it has
traded and as a significant stakeholder it is therefore concerned that development plan
policies should not fetter the important contribution that it makes to the vitality and viability of
those town centres. Through high attraction of footfall, financial services retailers generally
(and the Bank in particular) play a key role in promoting town centre health and as a result,
the provision of financial services should be allowed to improve and evolve alongside the
improvements to shopping provision envisaged over the proposed plan period. Banks should
not be subject to outmoded restrictive controls on their location, particularly as this is not
supported by Government policy or by any evidence, so there is therefore a need to review
existing policies that restrict such A2 uses in designated frontages or the Council will risk the
plan being found unsound.
2. Representations on the current consultation
The Preferred Options document sets out the Council's 'Strategy for the Future and
Sustainable Prosperity of Warwick District' (Paragraph 2.5), highlighting several 'Key
Principles' which include "facilitating the growth and development" of the local economy to
support a "dynamic, flexible" economy and "a commitment to maintain and promote thriving
town centres". Paragraph 4.8 refers to "the threat to the economic strength of the town
centres of Warwick, Leamington Spa and Kenilworth from retail and leisure developments
elsewhere", a matter highlighted in the 2011 consultation which also set out the Council's
intention to facilitate a level of retail and leisure growth that will meet existing and future
needs and "maintain and improve the vitality and viability of existing town and local centres".
P-07-289- Warwick LP PO Page 2 of 5 June 2012
Paragraph 4.10 sets out the Council's Objectives to address the identified Issues including
the intention to meet people's existing and future needs and maintain and improve the vitality
and viability of existing town and local centres. However, whilst the Council intends that the
Local Pan will identify the role of each of the town centres and plan for their future
management and growth, the plan omits a firm intention to review existing outdated local
plan policies. The Bank objects to that omission as it will result in a plan that is unsound,
particularly as the Plan acknowledges the need "to respond to the rapid changes taking
place" in the economy (Paragraph 8.5), emphasises the need for growth and flexibility
(Paragraphs 8.6 & 8.7) and recognises the requirements of the NPPF to plan proactively and
flexibly to respond to changes in the economy (Paragraphs 8.11 and 8.12). The Plan refers
to the Council's draft 'Economic and Regeneration Strategy' which identifies 6 priorities
including attracting investment and the growth of businesses (paragraph 8.17) and also to
the Key Ambitions of the 'Coventry & Warwickshire LEP' which include creating an
environment where businesses can thrive (paragraph 8.18). Section 9 on 'Retailing and
Town Centres' confirms the need to "maintain the economic strength of the town centres"
and the need for "a strategy for future management and growth of the town centres to meet
future needs". Despite this, Policy PO9 fails to facilitate either, compounding this by saying
nothing at all about reviewing existing outdated town centre policies.
The Council's background technical paper (March 2011) relating to 'Retailing and Town
Centres' refers to national planning policy in PPS4 and the need for enhanced consumer
choice through the provision of innovative and efficient shopping, leisure, tourism and local
services in town centres. It highlights the concerns in Leamington Spa about decreasing
levels of pedestrian footfall and the limited amount of investment that has resulted in the
town "losing its competitive edge". The paper notes that in Warwick there has also been a
decline in pedestrian footfall and a limited degree of retailer interest, resulting in a less than
vibrant and robust centre. In the current Warwick District Local Plan 1996-2011 Policies
TCP4 & TCP5 place arbitrary restrictions on non-A1 uses in primary and secondary
frontages but these measures have clearly failed to prevent the decline in footfall and the
consequent detrimental effect upon vitality and viability. The focus should be on the quality
of the occupier, not on maintaining an arbitrary level of a particular use class. The Bank
considers that the omission from the Preferred Options of a firm intention by the Council to
review out of date policies relating to shopping frontages is unsound, particularly as those
policies are in conflict with Government policy. We set out below the national policy
background that necessitates such a review if the Council is to produce a Development Plan
that is sound.
The National Planning Policy Framework (NPPF) re-emphasises the requirement for a
Development Plan to be "sound" when it is submitted for Examination and that in order to be
so it must be "Positively prepared, Justified, Effective and Consistent with National Policy".
The Government expects the local plan process to consider alternative strategies before
deciding upon the most appropriate, that decision being based on evidence to support the
choice (paragraph 182). The NPPF is clear that each LPA should "ensure that the Local Plan
is based upon adequate, up-to-date and relevant evidence" and that their assessments and
strategies "take full account of relevant market and economic signals" (paragraph 158).
On the matter of policy formulation the NPPF states that for plan-making:
* "local planning authorities should positively seek opportunities to meet the
development needs of their area"; and
* "Local Plans should meet objectively assessed needs, with sufficient flexibility to
adapt to rapid change" (paragraph 14).
P-07-289- Warwick LP PO Page 3 of 5 June 2012
The Government is clear that there should be a positive attitude to "proactively drive and
support sustainable economic development" and to "respond positively to wider opportunities
for growth". Plans should "take account of market signals" and the needs of business
communities (NPPF paragraph 17). "Planning should operate to encourage and not act as
an impediment to sustainable growth" and "significant weight should be placed on the need
to support economic growth through the planning system" (paragraph 19). Local Planning
Authorities "should plan proactively to meet the development needs of business" (paragraph
20) and "Investment in business should not be over-burdened by the combined requirements
of planning policy expectations" (paragraph 21). In drawing up Local Plans, local planning
authorities should set out a clear economic vision and strategy which "positively and
proactively" encourages sustainable economic growth; and should "support existing
business sectors, taking account of whether they are expanding or contracting". The NPPF
confirms that "Policies should be flexible enough to accommodate needs not anticipated in
the plan and to allow a rapid response to changes in economic circumstances" (paragraph
21). In his Foreword to the NPPF the Minister for Planning is very clear that "Development
means growth" and that "Sustainable development is about positive growth", emphasising
that "Planning must be a creative exercise in finding ways to improve the places in which we
live our lives". This reflects HM Treasury's commitment that "the default answer to
development is yes" in its ongoing 'Plan for Growth', which was launched at the time of the
Budget in 2011, reinforced in the 2012 Budget and now underpins the NPPF.
Keeping significant generators of footfall out of primary frontages will actively work against
the achievement of the Council's strategic objectives and is inconsistent with national policy.
The Council should recognise the positive impact that financial service retailers such as the
Bank have upon vitality and viability. The review of the local plan provides an opportunity to
examine new evidence and to revise out-of-date policy, particularly if it is not consistent with
national policy. Limiting certain Part A uses in the primary frontage undermines the Council's
intention to attract private sector investment in the town centre. The implication that only A1
uses are appropriate derives from very outmoded and discredited thinking that other uses
such as banks detract from the vitality and viability of town centres. By definition, uses that
fall within Part A of the Use Classes Order are appropriate in town centres as they are
"shopping area uses" and are acceptable without any need for restriction or qualification.
This is particularly the case for the financial services sector. ODPM Circular 03/2005
"Changes of Use of Buildings And Land" which accompanied the last major revisions to the
Use Classes Order specifically states in relation to the A2 Financial and Professional
Services use class (which was created to separate those uses "serving the public, from other
office uses not directly serving the public" - paragraph 32), that the Class is also "designed to
allow flexibility within a sector which is very much a part of the established shopping street
scene, and which is expanding and diversifying". The uses within Class A2 are noted as
being those "which the public now expects to find in shopping areas" (paragraph 38).
The wider role played by town centres than a pure shopping function has been recognised
throughout Government policy on town centres. Government Policy in PPS6, PPS4 and now
in the NPPF particularly emphasises the importance of economic growth and the promotion
of town centre vitality and viability. Paragraph 23 requires that "Planning policies should be
positive" and states that local planning authorities should "promote competitive town centres
that provide customer choice" and allocate a range of sites because it is important that
needs for retail, leisure, office and other main town centre uses "are met in full". The clear
message is that "local planning authorities should plan positively for their future to encourage
economic activity". In fact there is nothing in Government policy that recommends or
supports imposing restrictions upon acceptable town centre uses at all and indeed, as noted
above, paragraph 21 of the NPPF requires flexibility in policies in order to allow a rapid
response to changes in economic circumstances. It is therefore essential that Development
Plan policies should facilitate the positive approach required by the NPPF.
Promoting vitality and viability in town centres are objectives of the Government and the
Council. To succeed, town centres need to provide a full range of services and these often
need to be located in ground floor premises in accessible locations. Indeed, Class A2
retailers such as the Bank routinely experience very high levels of customer visitation,
contributing significantly towards pedestrian movement and therefore the vitality and viability
of town centres. The Bank has undertaken a number of comparative footfall surveys in
connection with its current acquisitions programme at its branches in various towns and
cities in the UK (copies are attached). These conclusively show that the level of footfall
associated with Bank branches is commensurate with, and often higher than, the best known
national multiple Class A1 traders.
Banks also have moved away from the traditional style of frontage, preferring to have an
open, visually interesting and attractive face to the 'high street'. The Bank has become
increasingly retail in its presentation and has introduced an innovative 'flagship' branch
design, which has been developed in association with its customers, to transform banking
into what it terms as "a retail focused experience". The Bank estimates that some 10 million
customers use its branches each week and through listening to their feedback, a design has
been developed that meets their requirements for modern banking and provides branches
similar in appearance and in operation to retail shops. This is an example of the "changes in
economic circumstances" that the NPPF recognises and to which all Local Plans must
positively and flexibly respond. Whilst the design of every new branch has to be flexible in
order to be sensitive to the requirements of each building occupied, the aim is generally to
ensure that over 70% of the internal space at ground floor is accessible to customers. The
Bank's managers regularly report that upon the opening of a 'flagship' branch the customer
visitation levels significantly increase and thus the level of activity helps to underpin
pedestrian flows to the benefit of surrounding traders. It is therefore important that planning
policy recognises the benefit of bank uses in fostering footfall and pedestrian activity and
that it should not resist much-needed investment by financial service retailers.
The Bank's footfall surveys have been a key element in helping to change attitudes towards
the presence of banks in core shopping areas and primary frontages. Even planning
authorities that once strongly resisted Class A2 uses in their primary areas have granted
permission for Barclays 'flagship' outlets. Examples of authorities that have recognised the
wider benefits of the 'flagship' design (following receipt of applications which have been
supported by evidence of high footfall), include Southampton, Reading, Manchester, Milton
Keynes, Romford, Southend, Leicester, Plymouth, Sheffield, Kensington & Chelsea and
Cambridge. Follow up surveys were carried out in 2010 at Milton Keynes, Southend,
Reading and Southampton (copies are attached). In every case the new 'flagship' branch
significantly increased footfall, confirming the Bank's beneficial effect on vitality and viability.
The Council's objectives will require major commitment and substantial investment by the
private sector. Pursuing restrictive policies to keep significant generators of footfall such as
the Bank out of primary shopping frontages will actively work against the achievement of
those objectives and is an outdated and discredited approach. The Bank therefore considers
that, in the light of its evidence, it imperative that the Council revises existing policies such
as TCP4 and TCP5 as they are neither consistent with National Policy nor Justified.
Proposed Policy PO9 does not do so and the Council's documents show no indication that it
has gone through an objective process and audit trail of assessing alternatives to those
existing policies, or that alternatives have even been considered at all. That is unsound.
3. Draft Infrastructure Plan
The Council has also invited comments on the Draft Infrastructure Plan as part of the current
consultation. As this document evolves into an Infrastructure Delivery Plan, the Council
should consider very carefully the balance between seeking contributions towards
infrastructure from proposed development and threatening the viability of that development.
P-07-289- Warwick LP PO Page 5 of 5 June 2012
The NPPF is clear that "Investment in business should not be over-burdened by the
combined requirements of planning policy expectations" (Paragraph 21) and that
development proposals "should not be subject to such a scale of obligations and policy
burdens that their ability to be developed viably is threatened". To ensure viability, any
infrastructure contributions sought should still allow for "competitive returns to a willing land
owner and willing developer to enable the development to be deliverable" (Paragraph 173).
4. Closing Comments
The Government has confirmed its commitment to HM Treasury's 'Plan for Growth' and it is
clear that the Council's objectives will require major commitment and substantial investment
by the private sector. In the light of our Client's evidence and the Government's
determination set out in the NPPF that planning policies and their implementation must
facilitate economic investment and growth, it is imperative that the Council uses the
opportunity of the preparation and revision of its Development Plan to ensure that its
planning policies in respect of bank and building society uses in designated shopping
frontages are consistent with National Policy and fully justified by robust evidence. Up-todate
development plans are an essential element in providing support for economic growth
and in taking Policy PO9 forward the Council must revise its current Local Plan retail policies
TCP4 and TCP5 to provide that support for investment by stakeholders such as our Client
and to ensure that the plan is sound. We trust that the Council will indeed take on board the
Bank's objections in the light of it being "keen to hear the views of all interested parties to
help us shape a draft Local Plan" and the confirmation that these Preferred Options "are not
a final set of proposals for the Local Plan" (Paragraph 3.3).
The Council's recognition of the need for significant private sector investment in the town
centres means that policies in the replacement local plan must give greater encouragement
to appropriate Part A uses to invest and to improve the quality of their representation.
Restrictive planning policies designed to keep significant generators of footfall such as the
Bank out of primary shopping areas will actively work against the achievement of the
Council's objectives and is inconsistent with national policy. The Bank's evidence of how it
increases vitality and viability in primary frontages shows that there is considerable benefit in
seeking to attract those A2 users such as banks who provide a high level of investment in,
and maintenance of, their premises resulting in active and attractive street frontages. This
will foster very significant footfall and pedestrian activity and attract investment by others,
helping to provide the confidence and commercial viability necessary for any programme of
regeneration and investment. To be Justified and Consistent with National Policy the
emerging Local Plan must review existing out of date policies that restrict the presence of
financial service retailers such as the Bank in designated frontages. If this is not done, the
Council will risk the DPD being found unsound. Policy wording should make it clear that
uses such as shops, banks and building societies which contribute to the vitality,
viability and diversity of town centres will be encouraged and that such active ground
floor uses will be appropriate in all designated retail frontages without restriction.
In view of the requirement for improved provision of banking services in Warwick District the
Bank would like to confirm its continued interest in the Local Plan process and in that regard
we shall be grateful if the Council will continue to notify us of the progress of this document
as well as details of any other emerging LDDs.

Attached letter

I wish to object most strongly to the proposals in the new local plan to develop green belt land to the north of Leamington. The whole point of the green belt is to retain open land, and prevent urban sprawl and the merging of adjacent built up communities. Visitors from the USA have often commented to me how brilliant it is that we have designated green belt areas, which preserve the countryside from destruction and prevent the wholescale urban sprawl found in many parts of their country. If this planned development goes ahead, not only will it destroy a significant area of open countryside, it will bring the built up areas of Leamington and Kenilworth very close together. This will, in future years, make it harder to defend the green belt which remains, and will inevitably lead to Leamington and Warwick becoming merged with Kenilworth, and via Kenilworth with Coventry in one vast conurbation. The ultimate fate of Warwick District, then, would be to be absorbed into the city of Coventry, as many parts of the county already have (and as, for instance, Sutton Coldfield was absorbed into the City of Birmingham in 1974). I am sure this is not something which local residents or councillors wish to see happen.

I like the suggestion in the local plan of designing 'garden' areas where development occurs, but it seems to me pointless to go to this trouble while at the same time destroying beautiful countryside we already have to enjoy.

I would also like to see more joined up thinking in local planning desisions. It is obvious that our shopping habits have changed and as a result we are seeing pressure on local shops and town centres. This needs to be acknowledged in the local plan - we may not have enough houses but we certainly have too many shops. While I applaud the council's decision to allow no more out of town retail developments, it seems that permission is still being given for supermarket developments in redundant commercial premises which could have been used for housing, and which then have a detrimental effect on existing shops. Two examples are the Lidl on Myton Road which was formerly a garden centre, and which would have made a good quality canalside housing development, and now the enormous Morrisons on the Ford site, which could have been a really attractive, all residential, area. Yet, despite these additions, more supermarkets are still being proposed, for instance on the site of the Oak Inn on Radford Road, and the Total garage on Rugby Road, both of which could be used for housing. All that will happen is that existing businesses will be affected, after all, how many supermarkets can one town possibly need??!

So please:

a) No development of the green belt
b) No more supermarkets
c) All redundant commercial or retail premises to be considered for housing development before any other use.

See attached

Scanned representation

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.

scanned form

See Attachments

See Attachments

Letter attached

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Scanned representation

Whitnash Town Council respond to each of the Preferred Options in turn, and
make comments in respect of the Vision and Objectives.
Vision and Objectives
We broadly support the Vision and Objectives for the Local Plan, but reserve
our position on the level of housing supply, for the reasons set out in our
response to PO1 below.
PO1 - Level of Growth
In principle we agree that sufficient housing should be provided across the
District to meet future housing needs. However, we are unable to comment on
the proposed level of an average provision on 555 per annum on allocated
sites, plus windfalls, as housing numbers are an immensely technical issue.
Notwithstanding this, we are very concerned that Warwick District and
Coventry City Councils are failing to exercise their statutory Duty to Cooperate
under the Localism Act 2011 by not addressing the important matter
of cross-boundary housing need.
We are concerned that, in its current state, the proposed strategy will be
found to be "unsound" by the Inspector at the eventual Examination. This
could well result in additional housing provision having to be made, and this
would have clear implications for non-Green Belt areas, such as those
surrounding Whitnash.
We therefore urge the District Council to effectively exercise the Duty to Cooperate
with Coventry in respect of cross-boundary housing provision at this
WHITNASH TOWN COUNCIL
Franklin Road Town Clerk
Whitnash Mrs J A Mason
Warwickshire Email: jenny.mason@whitnashtowncouncil.gov.uk
CV31 2JH
Telephone and Fax: 01926 470394
2
stage, therefore preventing the danger of the Local Plan being found
"unsound" in the future and the Council having to consequently revise its
strategy and land allocations.
PO2 - Community Infrastructure Levy
We fully support the District Council in seeking to introduce a CIL scheme as
the Town Council considers it vital that full and appropriate infrastructure
provision is made, in advance of development wherever possible. It is
essential, however, that the funds raised are used to develop infrastructure in
the areas where the impacts will be felt, irrespective of Town and Parish
administrative boundaries.
We look forward to seeing and commenting upon the Infrastructure Delivery
Plan in due course.
PO3 - Broad Location of Growth
We support the strategy to make Green Belt releases to the north of
Leamington. For the first time in many years, this will allow a spatial
rebalancing of the urban form and provide for significant development in areas
away from the southern edge of the Warwick/Leamington/Whitnash urban
area.
Apart from relieving some of the development pressure on the south, it also
represents sensible planning practice by creating a more rounded and
balanced urban area, enabling greater accessibility, especially for the town
centres, and should enable more effective transport planning through
maintaining a more compact urban form with Leamington and Warwick Town
Centres as two central hubs.
Past development allocations had resulted in Leamington Town Centre
becoming increasingly less "central" to the urban area as development
extended to the south. The proposed strategy ends this practice and is
therefore welcome.
PO4 - Distribution of Sites for Housing
At this Preferred Option stage, we do not have detailed proposals for any of
the sites covering, for example, access arrangements, amounts of
employment land, types and forms of community facilities to be provided, and
such like.
Therefore, we wholly reserve our position in respect of objection to, or support
for, any of the sites and we will make strong representations in this respect at
the Draft Local Plan stage.
However, we have a number of concerns in respect of several of the sites. We
draw these to the District Council's attention at this stage so they can be
addressed in formulating detailed proposals.
3
Education Provision
A general comment we wish to make is that it is critical that detailed
consideration is given, up front, to the level and location of future school
provision, both Primary and Secondary.
In Whitnash we have suffered from the lack of provision of a Primary School
at Warwick Gates. The draft Development Brief included a school, but this
was subsequently deleted as the County Council, as LEA, took the view that a
better option was the expansion of the existing three schools in Whitnash. As
this was, in planning terms, "policy neutral", the District Council amended the
Development Brief accordingly and deleted the school site.
This has led to problems for the residents of Warwick Gates and we would
seek to ensure that such a situation does not arise again through this Local
Plan process.
Our comments on education more specifically related to individual sites as
follows.
Sites 2 and 3 - if these sites progress, these should be seen as incorporating
a possible location for a Secondary School.
Site 6 (Whitnash East) - we understand that access could only be achieved
through the Campion School site. We are concerned that the school should
remain viable and continue to be located where it is.
Site 10 (Warwick Gates Employment Land) - consideration should be given to
siting a Secondary School on this land, given its advantages in terms of
accessibility from across the south of the urban area. The opportunity should
also be taken to explore the siting of a Primary School on the site, to meet the
needs both of existing Warwick Gates residents and also the needs arising
from any additional housing, on the site itself or in the vicinity.
Site 2 - Myton Garden Suburb
Our concern in respect of this proposed allocation is that its development will
result in the coalescence of the three components of the urban area, Warwick,
Leamington and Whitnash. We consider that this will result in a loss of
individual identity for the three towns.
Site 3 - South of Gallows Hill
We raise the following concerns in relation to this site:
* The land is extremely prominent in the landscape and will be highly
visible when entering the urban area from the south
* The site does not represent a logical extension of the current urban
form. It is in no way "rounding off" and would constitute a "peninsula" of
development extending to the south
4
* It would have a negative impact upon the setting of Warwick Castle
Park
Site 6 - Whitnash East
We raise the following concerns in respect of this site:
* We are not convinced that access to the site is feasible. Our
understanding is that the South Sydenham development constituted the
maximum number of dwellings that could be accommodated off a cul-de-sac.
Given that access to the site via Church Lane or Fieldgate Lane is clearly not
feasible, access would have to be achieved via land within Campion School.
As this would involve relocation of school buildings, we are sceptical that the
number of houses proposed could fund the necessary works required to
achieve this solution
* Given the above issue, and our earlier comments on the wider subject
of education provision, we do not wish to see the future location of Campion
School prejudiced by this development
* There are, in the immediate vicinity of the proposed site, substantial
areas of both historical and nature conservation interest. Any development
must not have an adverse impact on any of these cultural, historic and natural
heritage resources
* In the event that the site is developed, we would wish to ensure that
sufficient community facilities are provided within the development and also
that adequate footpath and cycleway links are provided between the
development and the existing community of Whitnash
Site 10 - Warwick Gates Employment Land
We raise the following concerns in respect of this site:
* The site appears to be proposed for development at an extremely low
density. We make this observation elsewhere in respect of other proposed
allocations. We are concerned that, to accommodate the projected housing
need, land is allocated at appropriately high density, thus reducing the overall
level of new land that is needed
* This site is currently a high quality employment land allocation and we
understand that a reason the land has not been developed is landowner
aspirations, rather than demand for such a site. It is essential that the Local
Plan provides a balanced supply of employment land to meet all sectors of
demand, if economic growth and prosperity is to be fostered. There is
currently no other site in the urban area that offers this amount of land area in
such an accessible location. We are therefore concerned at its proposed
reallocation from employment to housing
5
Site 11 - Woodside Farm
We raise the following concerns in respect of this site:
* We fail to see how two access points could effectively be achieved to
this site. We do not consider access from Harbury Lane to be feasible due to
the existing road alignment. We doubt whether access could be achieved
from Tachbrook Road due to the proximity of the Ashford Road and Harbury
Lane junctions to the north and south of the site respectively. Construction of
a roundabout at the Tachbrook Road/Harbury lane junction would offer
potential for one access point, but we are concerned about the impact of such
construction on the important oak trees in the vicinity
* We also doubt whether the development could carry the cost of such
highways works. The option of gaining access via Landor Road is utterly
unacceptable due to the road alignment and lack of vehicle capacity.
Furthermore, it appears that physical access could only be gained through
demolition of existing buildings
* In the event that a single access point was sought, we consider that
this has the potential to isolate the housing from the existing community and
also lead to unnecessary and unsustainable vehicle movements
* The site would be highly prominent in the landscape - there is
therefore a concern about visual impact
* The presence of underground High Voltage electricity cables will limit
the site layout
* There is considerable local opposition to the proposed allocation of the
site. It is our duty as a Town Council to inform you of this high level of
opposition
Site 12 - Fieldgate Lane/Golf Lane
The raise the following concerns regarding this site:
* We consider there to be fundamental access problems and have
concerns about the capacity of the Coppice Road/Morris Drive and Whitnash
Road/Golf Lane junctions to accommodate the additional movements
generated by the development, especially at peak periods
* We are concerned that, at a proposed level of 90 dwellings, the site
density is too high. This would be a prestigious site and the proposed density
should reflect this. Our argument does not run contrary to that made in
respect of other sites, where we consider the density to be too low, as
provision needs to be made at varying densities to reflect different sectors of
the housing market. This includes provision of sheltered housing and singlestorey
dwellings on appropriate sites. This may or may not be the case at
6
Fieldgate Lane, but should certainly be considered across the portfolio of
proposed housing allocations
PO5 - Affordable Housing
We support the provision of appropriate levels of affordable housing but would
seek this to be distributed across all sites to ensure the development of
socially balanced communities
PO6 - Mixed Communities and a Wide Choice of Homes
We support the Preferred Option PO6.
PO7 - Gypsies and Travellers
Given that Whitnash has experienced particular problems through unlawful
traveller encampments in recent years, we support the principle of the
Preferred Option of proper site provision
PO8 - Economy
We support the principles of PO8. However, we reiterate our concern that
appropriate levels of employment land should be provided, in the right places,
and this should constitute a balanced portfolio of sites to meet as wide a
variety of needs and demands as possible
PO9 - Retailing and Town Centres
We support the principles set out in PO9
PO10 - Built Environment
We support the principles set out in PO10
PO11 - Historic Environment
We support the principles set out in PO11
PO12 - Climate Change
We support the principles set out in PO12
We will seek to ensure that any future development in Whitnash seeks to
reduce the Town's overall carbon footprint through the application of
sustainable development and design principles
PO13 - Inclusive, Safe and Healthy Communities
We support the principles set out in PO13
7
PO14 - Transport
We support the principles set out in PO14 with the exception of the section
relating to High Speed 2.
Whitnash Town Council neither objects to nor supports HS2
We urge the District Council to ensure that the final Infrastructure Delivery
Plan takes full account of public transport needs and the principles and
policies set out in Warwickshire County Council's Local Transport Plan 3
PO15 - Green Infrastructure
We support the principles set out in PO15
PO16 - Green Belt
We support the limited release of Green Belt sites as set out in PO16 as this
will create a more balanced and sustainable urban area and urban form
PO17 - Culture and Tourism
We support the principles set out in PO17
PO18 - Flooding and Water
We support the principles set out in PO18

See attached

See attached

Scanned representation

I am writing in response to the above publication issued by the council to object to what seems to be ill thought out scheme. It would appear that the aim is the development to provide a vibrant and thriving town where people want to live, work and relax which at first glance seems to be a good idea but in the current economic climate (which I see extending well into 2015 and beyond) I think this could be misguided when money is tight. We need to extract maximum gain for minimum outlay.
You aim is for 555 home per year but there is little information contained within as to where this figure has come from and what the make of the proposed resident taking up these homes? When I'm out and about in Leamington it seems to me that the population is aging or old judging by the number of care homes in the district, has your proposal considered this and their requirements as it's a well-known fact that we are all living longer? With the on-going lack of finance to purchase these properties is the council proposing some sort of assistance? Or are we going to end up with ghost estates? The old Potterton site has been re-developed and a good proportion of that is still empty and unsold from what I can see.
Following on from this as a landlord I know in certain areas these empty properties are been taken on by housing association to provide affordable housing but depending on the number this could result in a highly desirable estate being tainted and the home owners losing out big time as a result. So again this could deter people from relocating to Leamington
You say that you want 40% of the housing to be affordable but go into no detail on how you intend to achieve this as this is one of the most expensive areas to buy property? And more importantly keep them affordable long term? Will you ensure all such residents have covenants that prevent tenant ownership and if so how would you enforce it?
Is the council intention to ensure that these new developments have been designed to promote a safe environment and reduce any policy costs going forward?
What steps have the council taken to assess the effects that the proposed Milverton development would have on the water levels in the area considering this area is surrounded to the north and west by the river?
Going by the contents of the summary I do not see any exceptional circumstance to warrant the destruction of the green belt, which once gone cannot be replaced and is conytrary to the National Planning Policy Framework. To the north of Leamington these is limited local amenities. And I know from my daily walks with my dog the vast range of wild life that exist in the proposed Milverton area from bats, newt to a vast array of birdsong which lifts my heart every time I hear it regardless of the weather. I also know the vast number of dog walkers, runners, cyclists and ramblers from around the district that make use of and enjoy these limited facilities
Also by the fact that you have identified non Green Belt land that could be used, and that developers probably already have options on, and that you have discounted then I am certain that owners of this land in conjunction with developers will gain planning permission on appeal resulting in a vast over provision of land to the detriment of the town and its residents
You state that you want to ensure that people who work in the district have the opportunity to live here but what has this decision be based on as I suspect judging by the morning jam that the majority of residents actually work in the surrounding district or further afield judging by the station platforms for the rush hour trains to Birmingham and London
You state that you want to reduce through town traffic, this I am sure is of concern to existing traders in the town centre and likely to deter any new venue looking for a location as this is likely to reduce footfall and likely income
What is the situation with empty properties within the district? What percentage are empty? What steps are being taken to get them back in to use, is the council using any incentives?
To my mind from the above points the starting point in developing a local plan would be to look at the logistical issues inherent in the district which I see as
* Leamington is split in half with a band that covers the river, canal and railway line - with only 4 historic crossing points
* The vast majority of the Leamington trading and industrial estates, that will form the majority of the employers locally are south of this divide
* To the west Leamington butt up against Warwick so the scope for doing anything in this area is limited, especially as the division is again reinforced by the river
* The ultimate boundary to the north is fixed by the A46
* The ultimate boundary to the south is fixed by the M40
* The vast majority of the out skirts of the town to the north and east areas are bound by green belt
* There are only two routes between Leamington and Warwick that are divided by the river

Bearing the above points in mind any plan should to my way of thinking:
* Be geared to address the bottle neck in getting around in the district so to this end it should be to improve the means of negotiating the river/canal/railway line with consideration to
o introducing a crossing to the east of the town and a ring road joining Heathcote Whitnash and Cubbington and improving the West Hill Road out to where it joing the A452
o introducing a link across the river to link the two roads between Leamington and Warwick to provide more travel flexibility
o improving the capacity of the fossway to provide an alternative transport path with the introduction of roundabouts at dangerous crossing point
o improving the A452 so that it provides a main transport path as it "A" rating denotes rather than being controlled by feed from minor roads at Shires Park and Chesford Bridge
o improving transport paths in Kenilworth to provide ring road to the west
* improving the local rail infrastructure to provide an alternative means of getting between Leamington, Warwick and Kenilworth say the introduction of minor stations at milverton, sydenham, whitnash, emscote, hospital/race course with regular service supporting these stops are peak hours
* Improving bus service by proving circular routes rather than the usual star systems
* Ensuring that it does not exacerbate current transport aspects within the district developing north of the river when industrial and trading estates are south of the river is simply not logical
I my view the proposed introduction of a northern relief road through Old Miverton will not achieve the desired result as it will simply put more loading on the Old Milverton Road (which is not included in your proposal for upgrade).and the A445. Also are residents going to take a 5 mile roundabout route when they only want to go 0.5 mile up the road?. The introduction of this road will also result in the destruction of Old Milverton and be the start of the coalescence of the urban area between Leamington and Kenilworth.
I'm not convinced either that a park and ride scheme is the right way forward and would like to see what basis the council has for this and its cost effectiveness. I know when I pass the one in Stratford (which is a location with far greater attractions and hence visitors) always seems to be empty.
The first time I used the A46 after the M40 junction was modified to improve traffic flow I was elated until I arrived at the roundabout which to my mind will simply backup the congestion to that point . Why this roundabout wasn't situated below the road with slip roads to it I simply can't understand. So let's try and do better going forward.
Finally one area that I see as missing from you plan is an ECO goal, I know that you mention climate change, reducing carbon emissions and the like but I think the council should be championing measures well beyond anything given in national sustainable construction. There are a number of developments around the country when innovative design has been applied providing high density housing whilst still providing tenants with the same levels of outlook on a normal estate. Again I was excited when it was announced that the old Potterton site was to be redeveloped but I am ashamed every time I drive past as it could have be used to provide an indication of a forward thinking council.

We feel that the initial process for determining the location for the new housing is fundamentally flawed. Where the housing and employment land is needed and most appropriate should have been decided first and then the land acquired not building where land has been offered. The document states " make sure new developments are in places that will reduce the need for people to use their cars".

PO 12 also states that "transport is the biggest contributor to carbon emissions" yet all the proposed sites outlined in the plan will lead to more car journeys. It is difficult to imagine that there will be enough CIL money to develop the public transport measures needed to tempt people out of their cars.

It would make more sense to build around Warwick Parkway Station and the proposed station in Kenilworth.

In determining the number of houses needed little heed seems to have been taken of the housing stock being released by an aging population. It is difficult to see how anything in this plan has much economic benefit for Warwick. The SHMA says that employment will drive demand for housing and that 526 houses per annum are needed to achieve employment growth of 10% and forecasts employment growth of 11,860 jobs over years 20l1-203l.It is difficult to see where these jobs will come from unless the jobs created by the Coventry and Warwick Gateway scheme are included and what benefit will that bring to Warwick. The document says "need to provide employment land in and around the Districts main towns to meet local needs and encourage creation of jobs". All the employment land options are outside Warwick and there is no mention of employment opportunities within the town centres.

RefP09
*
It is hard to justify "specific support for a major new retail development in Leamington Town Centre" as how will Warwick and Kenilworth prosper? We would like to suggest that the phrase "strongly resist any out of town centre proposals" be replaced with "not allow any out of town proposals" if WDC is serious about ensuring that" our town centres remain successful". There is no mention in the plan of the effect of cyber retailing and where are the plans for Wi Fi in our town centres? There are few firm proposals in this document or the draft infrastructure document for the plan to bring people into the town centre eg public transport, parking and ,particularly for Warwick, coach parking.

RefP017
There is nothing in the plan as to how WDC will "support visitor accommodation
in town centres"

RefP018
We suggest that "ensure that new development can be provided with adequate
water supply" should read "sustainable water supply".

With reference to the Green Infrastructure plan. Why are the four future opportunities not included in the plan.

Warwick Chamber of Trade are disappointed that there appears to be little of benefit to the town and hopes to see some improvements in the final document.

Submission Attached.

See attached representations.

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details: