PO10: Built Environment

Makes sense.

Provision of recycling bins on streets across the District's shopping and leisure areas shoudl be a priority

these are positive aspirations

Protect the Historic environment.
Norton Lindsey enjoys a historic hilltop setting with adjacent medieval ridge and furrow fields the village is sensitive to development due to the prominent location.It is essential that the nature and character of Norton Lindsey is not compromised by develpment which would increase the number of houses by 50%.
Design for safe communities and good access to services.
Norton Lindsey has a poor oad network, limited number of footpaths and no cycle paths.
The village is already a "rat run" morning and evening for people cutting through from Warwick to Stratford and vica versa.
There are no medical facilities or shops. The schol falls within the Stratford on avon district council and is fully subscribed.
Design to reduce carbon emmissions:- The location of the village means that only private transport can be used and therfore aditonal homes will produce increased carbon emmissions.Ther are only 4 buses a week 2 to Stratford and 2 to Solihull. Hardly ideal for commutors.

I support Paragraph 10.8 on Garden Towns, Villages and Suburbs,

Residents of Norton Lindsey are proud of the historic and attractive nature of the village and specifically the Conservation area. Development on the scale proposed in the Local Plan would severely impact on the historic environment.

Building 30-80 houses in Norton Lindsey will not protect its historic environment. It will completely change its character as a traditionally small historic village by increasing its size by over 50%

Proposing "good" design is laudable but relies on interpretation and delivery by developers. The impact of 2,700 new houses south of Warwick cannot be mitigated by cynically naming it a "garden suburb".
Chase Meadows ignored what people want, residents have at least 2 cars and want to park them in sight - see Secure by Design. Putting parking round the back increases the overall tarmac area. The roadways are narrow and very congested. 3 storey homes are only suitable in an urban environment and will not suit south Warwick.

Category 2 village, Norton Lindsey:


PO10 states the need to ' design for safe communities and good access to services; and design to reduce to carbon emissions'.
The road system in Norton Lindsey includes many roads that do not have pavements for pedestrian access and safety; in the conservation area of the village some of the roads are narrow, barely wide enough for 2 vehicles to pass safely. As such, the road network is neither safe for pedestrians nor suitable for any increase in traffic that would inevitably result from the building of new housing.
Norton Lindsey does not have a village shop, secondary school, health centre or other services and suffers from a very restricted bus service. It therefore does not have good access to services.
The lack of amenities in Norton Lindsey means that regular and frequent journeys by car have to be made by its residents to access everyday services. There are no cycle paths or other provisions for cyclists to access the village. Consequently, building more houses in the village would increase the number of car journeys being made to and from the village thus increasing, rather than reducing, carbon emissions.
As a result of these factors, Norton Lindsey does not meet the requirements of PO10.

Building 30-80 houses in Norton Lindsey will not comply with the specified needs as detailed in the plan to:
 "Protect the historic environment"
* Norton Lindsey enjoys an historic hill top setting with adjacent medieval ridge and furrow fields which will have previously provided food for the village - the village is very sensitive to development due to the prominent location. It is essential that the nature and character of Norton Lindsey is not severely compromised by development
 Design for safe communities and good access to services
* Norton Lindsey has a poor road network, a limited number of footpaths within the village and no cycle paths, additional housing requires an infrastructure which does not exist in Norton Lindsey.
* There are no shops or medical facilities within the village.
* The school falls within Stratford upon Avon District Council and is fully subscribed.
 Design to reduce carbon emissions
* The location of Norton Lindsey and the essential use of private vehicles will increase carbon emissions.
* Norton Lindsey has 4 buses per week leaving the village, 2 to Stratford and 2 to Solihull.
* There is no safe route to cycle from the village.

Building 30-80 houses in Norton Lindsey will not comply with the specified needs to protect the historic environment.

Norton Lindsey enjoys a hill top setting with adjacent medieval ridge and furrow fields the Village is very sensitive to development due to the prominent location. It is essential that the nature and character of Norton Lindsey is not compromised by large scale development which could increase the number of houses by more than 50%.

Norton Lindsey has poor road network and experiences serious accidents due to this poor narrow network, many I have witnessed. There are a limited number of footpaths within the village and no cycle paths, any additional housing development requires an infrastructure which does not exist is Norton Lindsey. There are no shops, medical facilities or within the village and any within the area are over subscribed and therefore now operating a capacity system which equates to a poor service. The school falls within Stratford upon Avon DC and is fully subscribed.

Norton Lindsey requires occupants to use private vehicles which will increase emissions and traffic flow. Norton Lindsey has only 4 buses per week leaving the village, 2 to Stratford and 2 to Solihull, therefore, public transport cannot provide the link to services required. There is no safe route to cycle from the village.

Building 30-80 houses in Norton Lindsey will not comply with the specified needs to protect the historic environment.

Norton Lindsey enjoys a hill top setting with adjacent medieval ridge and furrow fields the Village is very sensitive to development due to the prominent location. It is essential that the nature and character of Norton Lindsey is not compromised by large scale development which could increase the number of houses by more than 50%.

Norton Lindsey has poor road network and experiences serious accidents due to this poor narrow network, many I have witnessed. There are a limited number of footpaths within the village and no cycle paths, any additional housing development requires an infrastructure which does not exist is Norton Lindsey. There are no shops, medical facilities or within the village and any within the area are over subscribed and therefore now operating a capacity system which equates to a poor service. The school falls within Stratford upon Avon DC and is fully subscribed.

Norton Lindsey requires occupants to use private vehicles which will increase emissions and traffic flow. Norton Lindsey has only 4 buses per week leaving the village, 2 to Stratford and 2 to Solihull, therefore, public transport cannot provide the link to services required. There is no safe route to cycle from the village.

The District is justly proud of the excellent rural areas surrounding for our small towns. Therefore it is scandalous that this local plan seeks to build recklessly, and almost exclusively, on green field sites. This is entirely unnecessary for the following reasons:
* There is not a clear link between economic growth and housing (see response to PO8)
* Housing should be focussed on brownfield sites within urban areas
* More effort should be made to use currently vacant homes and retail/ office spaces, especially homes above shops
* Excellent residential schemes of up to 200 homes per hectare are quite common, so there is absolutely no reason to advocate 30 homes per hectare (note section 4.23 of the Strategic Housing Land Availability Assessment, SLHAA). As household size is tending to reduce, the need for small homes continues to grow, enabling much higher housing densities than proposed in this plan
* The SHMA report indicates that the majority of older people live in homes with 3 or more bedrooms and that over 40% of homes are under-occupied. Therefore a high priority is to set the conditions whereby high quality, attractive smaller homes are developed in all areas of the district to encourage those in under-occupied homes, particularly older people, to move into them. This has the potential to free-up enough homes to obviate the need to build any more
* Warwick University, along with other Higher education institutions around the country, have made the strategic decision to keep as much student money to themselves i.e. they are engaged in a major programme of building student accommodation on campus. This dramatic reduction in the number of students in the rest of the District is another reason why house building is unnecessary

Even if the council does not accept the full force of the above arguments, it should still be acknowledged that there is uncertainty in their prediction that so much housing is required. Therefore, it is imperative that there is gradual release of land for housing over the timescale of this plan, with the most suitable land released first e.g. only brownfield sites usable for the first few years, then selective low-grade agricultural land. Only when all other sites have been built upon, should the rest of the allocated land be released for development.

The Leamington Society supports the fourth bullet point of PO10
"Protect, enhance and link the natural environment through policies to encourage appropriate design of the built environment and set out a framework for subsequent more detailed design guidance to ensure physical access for all groups."

Specifically we would encourage WDC to put in place procedures to limit and reduce street clutter (A boards, unnecessary roadside signs etc.). Likewise, WDC should have the power to force the owners of homes or buildings to remove vegetation obstructing footpaths.

Warwick District Council enjoys some very attractive built environments including villages such as Norton Lindsey. Within the centre of the village there is an established Conservation Area with a number of listed buildings being set close to the road which creates an attractive environment for residents and visitors. Any increase in traffic would have an adverse effect on the village and is unacceptable as it cannot be accommodated. In addition introducing further volumes of traffic would have adverse climate change effects and runs against the established sustainability policy of Warwick District Council.

We support the Council's decision to take forward the NPPF's suggested approach that large urban extensions should follow the principles of garden cities and garden suburbs. Many of the garden city principles accord with our own ambitions for the kind of development we wish to see brought forward on land north of Gallows Hill/west of Europa Way. In fact in the interest of providing a high quality environment for its residents and engendering a sense of community, we are consulting with Bournville Village Trust over masterplanning considerations and long term stewardship of the site, and are keen to work with the local community and stakeholders to bring this exiting development opportunity forward.

The government has indicated that there will be consultation later this year about how local authorities and developers might apply garden city principles to new developments. It will be interesting to see what comes forward as part of this consultation and how the Council's own prospectus compares with this.

We acknowledge reference to the use of 'design codes' to also support the garden city initiative. It would, however, be helpful if the Council explained how it sees design codes being developed and brought forward. Is this something the Council will be undertaking itself so that there is a common approach to different types of development/ locations across the District, or is the Council looking for developers to prepare design codes themselves or in partnership? Furthermore, how is the design coding intended to link with requirement for Development Briefs as called for under Policy PO4? If the developer is expected to prepare design codes as an integral part of the development brief, then we feel that those promoting Phase 1 sites could be unfairly burdened with undertaking work which would likely be taken forward and applied by developers of the strategic site allocations phased later in the plan period.

Noted.

King Henry VIII Endowed Trust supports the Council's aspiration to apply garden city principles to new developments in the District. Many of the garden city principles accord with the Trust's own ambitions for the kind of development we wish to bring forward at Hampton Magna.

I am e-mailing to object totally to the building on the Green belt land
in the proposed new plan.

better use of of existing brown field land for housing instead out of more out of town supermarkets.

More apartments in the style of the town architecture and not blanket modern housing
changing the style of this lovely spa town.

My thoughts are: -

Let's assume that central government want you to produce a plan, and your proposed number of houses are to be built in the area: -

1. We don't have the transport infrastructure to cope and the 'improvements' you suggest will be insufficient. We have the Rivers Avon and Leam moving east-west through the district with inadequate crossing points. Building off the Banbury Road Warwick will require more vehicles to cross the current and old bridge in the town centre. This would need replacing at6 great costs and inconvenience before any building can take place. The idea that each new development will have its own industry seems wonderful but in the real world people don't and can't move when they change jobs or can't afford to buy houses where they work. Some commute into Birmingham or to London but are unable to get to Warwick station by public transport so are forced to drive to Warwick Parkway where more land is to be lost to a tarmac car park. THE TRANSPORT STRUCTURE CANNOT COPE NOW. DO SOMETHING BEFORE THE BUILDING STARTS!

2. Building the housing estates that we have seen in UK over the last 50 years, invariably creates ghettos of soul-less and character-less housing in the same style. Such developments can be seen throughout the country where you, the planners, have failed to lead. Warwick should lead by allowing private individuals to buy plots of land and build their own houses within planning guidelines. This way we will not suffer from the uniformity of style that we face wherever we go. Look around the district to see what's considered good and what's considered bad - Kenilworth has lost its identity long ago by developments of similar properties that have no connection with the old. The High Street once the centre of the town is now dead! A good street is Northumberland Road with individual houses on a wide tree-lined road. SMALLER INTEGRATED BUILDING BY INDIVIDUALS OR SMALLER DEVELOPERS. CREATE SOMETHING THAT IS GOING TO BE PART OF WARWICK AND NOT AN UNSIGHTLY GHETTO THAT HAS NO CONNECTION WITH THE TOWN.

3. Warwick will get the bulk of the houses. The county town does not have a fire station, a police station, or a decent library. Planners have destroyed much of it over the years by taking part of Priory Park for WCC car parking. You now talk of Park & Ride schemes when these should have been set up years ago for WCC staff. PRESERVE WARWICK AND NOT LET IT GET TOTALLY LOST AS A SUBURB OF LEAMINGTON.

4. And i haven't mentioned the risk of flooding caused by more hard surfaces giving instant run off. Currently drains overflow as they have not been maintained. Nor mentioned the state of the roads - will increased road surfaces mean even worse maintenance and pot holes. Will WDC & WCC staff not report them and the road signs covered in moss that they MUST see as they drive to their free car parks when you require the public to pay.

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

Thank you for your email dated 01/06/2012 inviting Warwickshire Wildlife Trusts
comments on the above development plan. The Trust welcomes the opportunity to
participate in the ongoing development of the Warwick District New Local Plan and
would like to submit the following comments and recommendations for your
consideration.
PO4. Site Allocations
Warwickshire Wildlife Trust believes that further information is needed to inform and
justify the preferred housing allocations detailed in the new local plan. We are
concerned that the current evidence base and assessment criteria has not fully taken
account of all ecological constraints and opportunities for each allocation and
therefore cannot identify and isolate those housing options that offer the greatest
benefits for, or least impacts on, the natural environment. We recommend that the
local authority undertakes the following:
Update the evidence base
It is recommended that the Warwick District Habitat Assessment is updated to include
the additional 3 sites that were not initially reviewed under the 2008 assessment.
These sites are the land at Blackdown, Warwick Gates Employment Land and a site
that forms part of the Thickthorn allocation. The habitat assessment should aim to
ensure that up-to-date information on habitats, local sites and protected species
considerations are available for these additional three sites at this stage of the
planning process so that the relative constraints and opportunities of all preferred site
allocations are available to inform decision making. The National Planning Policy
Framework (NPPF) requires planning policies and decision to be based on up-to-date
evidence about the natural environment of the area so that the sustainability appraisal
can 'consider all the likely significant effects on the natural environment'. Therefore,
without comprehensive data for all preferred site allocations, it will be difficult for the
local authority to justify the conclusions of the sustainability appraisal process and
thus the preferred options during examination in public.
The Trust is aware that additional habitat assessment is underway for the land at
Blackdown and the site at Thickthorn; however we also recommend this is extended
to the Warwick Gates Employment land. Whilst we acknowledge that this site has
been previously allocated as an employment site in a previous local plan, we believe
that the site is still a preferred option and therefore needs to be supported by, and
assessed against up-to-date ecological evidence to justify its inclusion in the local
plan.
Clarify the Sustainability Assessment Criteria
The Trust recommends that the Sustainability Appraisal (SA) includes greater
transparency about the criteria used to assess different options and site allocations.
At present, it is not possible to determine how each site allocation was scored against
the 16 sustainability categories, which in turn raises questions as to how these
conclusions were formulated. In particular, we are concerned that for category 6: To
protect and enhance the natural environment of the SA, almost all the site allocations
have scored either a negative or strongly negative scoring, implying one of the
following:
- All site allocations are highly detrimental to the natural environment, in which
case the preferred housing options are collectively not an effective strategy to
deliver sustainable development in the district
- The environmental gains and benefits that new development can bring to a site,
through for example the protection and enhancement of valued ecological
features, green infrastructure delivery or habitat management, have not been
factored into the scoring assessment.
- The current criteria used for the natural environment is not sensitive enough to
differentiate between sites that can, on balance, provide opportunities for the
natural environment and those that can't. This could have occurred for example
by strong weighting towards factors such as the loss of the green belt, which will
always score negatively where development in the green belt is proposed.
The Trust would therefore like to see more information in the SA to justify why the
preferred development strategy has consistently shown negative scores for the
natural environment and how this development strategy can in turn contribute towards
the pursuit of truly sustainable development.
We believe the SA should detail a standardised and objective criteria for which all site
allocations should be assessed. This will give relevant stakeholders the opportunity to
review and comment upon the factors that influence the scoring for each site
allocation; helping to differentiate between the sustainability of different sites and
giving greater weight to the SA process overall. Using this feedback, the local
authority can then be confident that their chosen strategy represents the most
appropriate strategy when compared to all reasonable alternatives.
We believe that any scoring criteria for the natural environment should be inclusive of
both constraints and opportunities. This would ensure a more balanced approach to
scoring the natural environment category as impacts of each site allocations can be
considered in the context of other benefits and wider contributions to ecological
networks and biodiversity targets in the district. This approach is also more consistent
with the NPPF which requires local authorities to plan positively for ecological
networks in order to halt the loss of biodiversity by 2020. Subsequently, when scoring
site allocations for the natural environment, we recommend that the following factors
are taken in to consideration.
- Does the site impact on statutory and non-statutory wildlife sites
- Does the site impact on Local Biodiversity Action Plan (LBAP) habitats and
species and other important ecological features such as river corridors.
- Does the site have potential to impact on populations of protected species?
- Is there an ability to provide ecological mitigation to avoid or reduce long-term
impacts
- Are there opportunities for habitat enhancement, buffering statutory and nonstatutory
sites or introducing a management plan for sites, features or species of
ecological importance
- Are there opportunities to create, link-up or restore biodiversity and green
infrastructure assets across the district?
The Trust recommends that the impact on natural resources and ecosystem services
should also be considered within category 5: to ensure the prudent use of land and
natural resources of the SA. Currently this category is understood to be scored only
on whether or not the site allocation is on greenfield or brownfield land. However, this
does not take into account impacts on soils, air quality, natural resources or
ecosystem services. Nor does it consider what opportunities are available to mitigate
and enhance current natural resources and ecosystem services within site allocations
and how proposals could contribute to national targets and ambitions, such as those
listed in Biodiversity 2020: A Strategy for England's Wildlife and Ecosystem Services
for maintaining healthy and well functioning ecosystems and restoring degraded
ecosystems services. The Trust believes the impact on natural resources and
ecosystem services is a significant consideration in choosing site allocations and if
inadequately assessed could compromise the ability to achieve key objectives in the
plan or even the effectiveness of policy provisions. We subsequently recommend that
the site allocations are reviewed accordingly to account for these points.
Review Conclusions of Sustainability Appraisal
In light of our concerns above, we believe the local authority should review the scores
and conclusions given for category 5 and 6 of the sustainability appraisal. To aid this
process the Trust has briefly summarised a number of factors which we believe
should be considered for each preferred housing allocation. This summary is included
in appendix 1.
PO8. Economy
Warwickshire Wildlife Trust believes that it will be important for the local authority to
explore the case for including the proposed Warwickshire and Coventry Gateway
development area in the local plan. We are broadly supportive of the approach
detailed in paragraph 8.33 of the consultation document to review the impacts of the
proposal and believe this work will be essential if it is to be a justified allocation in the
plan. The Trust also recommends that in reviewing the impacts of the scheme, the
local authority should also take full account of the environmental and social
implications of including the allocation in the preferred options so that the economic
incentives of the scheme can be considered in the context of wider sustainability
objectives for the district. The evidence base for the natural environment will therefore
have to be reviewed and updated in order to inform the sustainability appraisal for this
site and any other reasonable alternatives that come forward as part of this review
process.
When considering the implications of all potential employment sites it will be
necessary to consider both the constraints and opportunities for the natural
environment. Having engaged in discussions about the Gateway proposals so far, the
Trust has identified numerous adverse effects on ecological assets but have noted
that the site also offers opportunities to deliver environmental enhancements in
strategic areas for green infrastructure and biodiversity, such as the River Avon LWS.
We believe the local authority needs to acknowledge and balance these factors so
that the impact on the natural environment on all site options can be more accurately
determined and assessed within the sustainability appraisal. Criteria for assessing the
constraints and opportunities of employment scheme on biodiversity should therefore
refer to the detailed criteria outlined above for housing allocations.
Any policy that favours a potential employment site of regional importance should
ensure that the enabling provisions reflect and are supportive of other themes in the
new local plan. The allocation should therefore embody the principles of sustainable
development by ensuring it contributes to wider economic, environment and social
objectives jointly. This should include improvements to green infrastructure and the
natural environment that are equivalent to the site's strategic importance so that it can
be seen as an exemplar for sustainable design and construction within the plan. In
order to optimise the potential for high quality environmental improvements, the Trust
strongly recommends that the policy wording should seek enhancements in line with
the district's ecological and green infrastructure networks, LBAP objectives for priority
habitats and species and Water Framework Directive objectives.
PO10. The Built Environment
The Trust is broadly supportive of the preferred option for the Built Environment. We
welcome the acknowledgement of the need to protect, enhance and link the natural
environment and would further support policy wording that recognises and promotes
the benefits of incorporating green infrastructure and suitable features for biodiversity
in and around development proposals. We believe that including these provisions,
together with links to other themes within the local plan, will help to underpin the
delivery of the Garden Suburbs prospectus and thus secure the district's ambitions to
promote high quality and sustainable development through the local plan.
PO12. Climate Change
The Trust is supportive of preferred option PO12 and in particular the local authority's
commitment to include a policy that promotes climate change adaptation. We
recommend that in wording this policy, due consideration is given to ensuring
linkages to delivering green infrastructure, protecting and enhancing biodiversity and
ecological networks and supporting objectives for mitigating and enhancing flooding
and water quality as these will all support and provide a context for delivering climate
change adaptations through new development proposals.
PO15. Green Infrastructure
Warwickshire Wildlife Trust welcomes the local authority's commitment to protect,
enhance and restore the district's strategic green infrastructure (GI) network. We
believe that the supplementary work to identify the network and the subsequent GI
projects that have informed the infrastructure delivery plan, provide a strong context
for securing mitigation and/or contributions towards GI enhancement within the new
local plan. Acknowledging the linkages with other themes such as Flooding and
Water, Climate Change and the Built Environment, GI should be considered an
integral part of good design and so we recommend that this is reflected in the wording
of an overarching green infrastructure policy. This has already been reflected in part
under the 'Development Proposals' paragraph in PO15 which would in turn create an
excellent starting point for the policy wording.
The Trust is pleased to note Warwick District's intention to adopt the sub-regional
green infrastructure SPD. This provides an excellent opportunity to secure strategic
improvements to priority ecological networks throughout Warwickshire, Coventry and
Solihull which will in turn strengthen and compliment existing district wide and local
networks. Maintaining the reference to each level of the strategic green infrastructure
network will ensure that contributions to achieve these aims can be secured; thus
demonstrating the district's commitment to planning positively for networks of green
infrastructure. However it may be necessary to clarify how and when improvements to
the different networks will be sought and the mechanism that will be used to balanced
how these contributions are distributed between the local, district and sub-regional
networks accordingly.
Our concern with the preferred option so far is the coupling of a green infrastructure
policy with the protection and enhancement of biodiversity. Whilst we agree that sites,
features and corridors of wildlife importance do form an integral part of local, strategic
and sub-regional GI networks, we believe that a GI policy cannot deliver the robust
and objective protection for biodiversity assets that could normally be set out within a
specific biodiversity policy. The NPPF set outs a good criteria based approach for
protecting statutory and non-statutory sites. It requires policies to differentiate
between sites of national and local importance so that their protection is
commensurate with their status and the contribution they make to wider ecological
networks. For local sites this criteria based protection is essential as it clearly defines
the level for which it remains robust when challenged by development interests.
Conversely, the multifunctional nature of GI makes it difficult to specify a criteria
based approach for its individual components and so blanket protection must be
applied to safeguard all assets. Whilst in principle, absolute protection is an ideal; the
Trust recognises this is likely to be less effective as it makes it much more vulnerable
to challenges from development interests. Subsequently, whilst maintenance and
enhancement of ecological networks should still be pursued through a green
infrastructure policy, we believe that a specific biodiversity policy is also needed to
ensure a sufficient level of protection for sites, features and habitats of biodiversity
importance. Our policy recommendations for biodiversity are discussed below.
POXX. Biodiversity
Warwickshire Wildlife Trust strongly recommends that the preferred option includes a
policy to specifically outlining the protection of the district's biodiversity assets.
Referring to our comments above, we do not believe that a green infrastructure policy
in isolation can provide an adequate level of protection for individual biodiversity
assets within the district. A biodiversity policy, founded on the criteria based approach
detailed in the NPPF, is considered to be a more effective approach as it:
- ensures that protection is commensurate with the site or feature's status and
contribution towards wider ecological networks,
- provides greater clarity as to how impacts on biodiversity assets will be judged
therefore proving to be more robust when challenged; and
- can specifically promote the preservation, restoration and re-creation of priority
habitats, ecological networks and the protection and recovery of priority species
populations in line with national and local targets.
Ensuring robust protection for biodiversity assets should be considered as a priority
when planning positively for ecological networks. Statutory and non-statutory sites,
particularly Local Sites, provide the fundamental building blocks for establishing
ecological networks. With these sites only constituting approximately 3% of the entire
district area, it will be essential that these core features are effectively secured.
However, important biodiversity assets are not simply confined to these areas and so
it will be necessary to ensure that the policy outlines a degree of protection for other
important biodiversity features that do not benefit from a statutory or non-statutory
designation, such as wildlife corridors, LBAP habitats and species and linear features
such as hedgerows and watercourses.
The Trust therefore believes that the strong protection of statutory and non-statutory
sites and other features of ecological importance should form an integral part of a
biodiversity policy within the local plan. In order for this policy to be effective, we
support the criteria based policy approach detailed in the NPPF as this clearly
outlines the relative weight given to each site, feature and habitat so that protection is
commensurate with its status and the to the contribution it makes to wider ecological
networks. However, as the criteria must differentiate between national and local
designations we believe that the policy should include separate policy clauses for
sites of International importance (SAC, SPA, Ramsar), national importance (SSSI),
county importance (LWS, LNR) and features of district/county importance (LBAP
habitats and species, wildlife corridors).
Where impacts on features of nature conservation importance are identified, it will be
necessary to outline how impacts can be resolved to prevent a net loss of
biodiversity. Paragraph 118 of the NPPF provides a useful hierarchy of how impacts
should be dealt with in this instance. It requires that all adverse impacts on
biodiversity should be avoided first, then if impacts cannot be avoided, and the
reasons for the development demonstratably outweigh the nature conservation
importance of the site or feature, mitigation should be secured. Compensation should
only be sought as a last resort. The Trust would advise that this categorical approach
to dealing with biodiversity impacts is adopted into a biodiversity policy for the local
plan. We also believe that a reference to Biodiversity offsetting should be included at
this stage of the policy (As opposed to including it in the green infrastructure policy)
so that if compensation is sought for a development, then the district can demonstrate
that it has an objective mechanism for ensuring that the proposal will not result in a
biodiversity loss. References to the sub-regional and district GI strategies, together
with the proposals for a Nature Improvement Area or the results of any Biodiversity
Opportunity Mapping, should be included here to outline how the biodiversity
offsetting process contributes towards delivering strategic gains for biodiversity.
However, biodiversity offsetting is a means to quantifying biodiversity impacts that
cannot addressed on site and so it should be clearly outlined that this process is a
last resort where adverse impacts cannot be avoided or mitigation for on site.
The Natural Environment White Paper has outlined that the UK needs more, bigger,
better and joined places for nature to reverse the continual loss and decline of
biodiversity and essential ecosystem services. This policy should therefore form the
basis for securing biodiversity gains through the planning system in order to
contribute towards the Government's ambitious target of halting the loss of
biodiversity by 2020. To transpose these targets and policies in to the District's local
plan, it will be necessary for the biodiversity policy to also include some provision for
enhancing biodiversity as well as protecting it. This could be achieved, for example,
by promoting habitat creation, restoration, re-creation and/ or management of existing
features within all new development proposals. Whilst a green infrastructure policy
goes some way towards this provision, it is non-specific to biodiversity and cannot
guarantee that improvements to the network deliver these crucial gains for
biodiversity. The Trust believes a policy clause could be included in the biodiversity
policy as means to securing these aims.
Warwickshire Wildlife Trust would welcome the opportunity to input into, or comment
on, any policy wording that is developed for a specific biodiversity policy in the new
local plan.
PO17 Tourism and Culture
The Trust believes that policies that support sustainable tourism should be
encouraged providing that they truly reflect the principles of sustainable development.
New sustainable tourism developments should therefore be able to detail how they
safeguard and contribute towards the enhancement of biodiversity assets, the water
environment and green infrastructure whilst demonstrating high quality and
sustainable design and construction throughout. The Trust would subsequently
welcome a clause within a sustainable tourism policy linking it to wider themes within
the local plan to clearly define what 'sustainable' tourism should be expected to
achieve.
PO18. Flooding and Water
The Trust are broadly supportive of the preferred option for flooding and the water
environment; however we believe that PO18 is lacking in detailed provisions for
safeguarding and enhancing water quality and optimising opportunities to reduce
flood risk by linking with themes such as green infrastructure, biodiversity and the
built development.
The need for stronger controls on protecting and enhancing water quality is outlined
in paragraphs 18.12 - 18.14 of the consultation document. It details that only 11% of
water bodies in the district are at 'Good' ecological status and so the district must
employ an ambitious approach to tackling water quality issues within the local plan if it
is to achieve the objectives of the Water Framework Directive by 2015. Development
can contribute to towards improving water quality though a number of means such as
SUDS, buffering watercourses and reconnecting them with their floodplains, creating
new wetland habitats and retrofitting measures that assist with attenuating and
filtering surface water before it is discharged into water bodies. The Trust therefore
recommends that such measures are strongly promoted in all new developments so
that provisions to safeguard water quality are also pursued in tandem with
opportunities to mitigate and enhance them. Policy wording that would support this
approach would be strongly welcomed by the Trust
The Trust recognises and supports the district's commitments for preventing new
development within flood risk zones in order to reduce future flood risk issues.
However, we believe that this approach should be the minimum requirement for
reducing flood risk as there is also a need to mitigate against existing flood risks and
adapt to the to changes in river levels that are likely to occur as a result of climate
change. The Local Authority should therefore be planning positively for addressing
flood risk, promoting opportunities not only to incorporate SUDS but to reconnect
rivers with their natural flood plains and support the creation of new wetland and
riparian habitats thoughout the district. The Trust acknowledges and welcomes the
district's strategic green infrastructure proposals adjacent to the River Leam which will
ensure that contributions for new development can be strategically placed; however
these principles should be embodied into policy wording so that wider opportunities to
reduce flood risk can be pursued. Where possible, opportunities to reduce and adapt
to food risk should be included in the scoring criteria in the SA for flooding as well as
determining whether or not the allocations is within the flood plain.
I hope these comments are useful to you as you progress the development plan
through to the next stages. Please do not hesitate to contact me if you seek further
clarification on any of the above points.
Yours sincerely
Richard Wheat
Planning and Biodiversity Officer
Warwickshire Wildlife Trust
Appendix 1: Summary of factors that should be considered when scoring site
allocations against Category 6 in the Sustainability Appraisal
Site Name Summary of ecological comments for the scoring
criteria described above
Woodside Farm
(South of Whitnash)
The small section of broad-leaf woodland and the mature
hedgerows and trees are the key features of this site. However
there are opportunities to retain these features and enhance
them through buffering or new habitat creation which should be
reflected in the score for this site.
Whitnash East
(South of Sydenham)
Whitnash brook, which forms the eastern boundary of the site, is
an important watercourse and wildlife corridor that supports a
good variety of semi-natural habitats and connects to the
adjacent Local Nature Reserve in the north. The development
area also supports hedgerows which connect the feature to the
Railway cutting to the east which is a pLWS. The presence of
protected species will also need to be considered and so overall
this site could score unfavourably on these grounds. Scoring
should take into account that impacts on the brook could be
avoided and mitigated through a substantial buffer and the
hedgerows could be retained to maintain connectivity to the
adjacent pLWS. There is also an opportunity to extend the
existing LNR boundary south along the eastern boundary of the
site by buffering the brook and delivering further habitat
enhancement, creation and restoration on site.
Fieldgate Lane
(Whitnash)
Species rich hedgerows and the adjacent railway pLWS are the
key ecological features for this site. The grassland habitat that
constitutes much of the site contains ridge and furrow, but is
species poor and offers opportunities for enhancement. The site
offers excellent potential to buffer the railway pLWS and retain
the hedgerows which are confined to the site boundaries. It also
provides opportunities for habitat restoration and creation on
site.
South of Gallows Hill/
West of Europa Way
The linear belt of habitats following the Tach Brook is an
important and sensitive feature of the site. Some of these
habitats also form part of Nursery Wood pLWS and connect well
with New Waters LWS and so the site should score
unfavourably on these grounds. Numerous hedgerows and trees
are also present throughout the site, providing opportunities for
protected species such as otter. This will need to be reflected in
the scoring for this site. The Tach brook corridor with associated
semi-natural habitats could and should be substantially buffered
and maintained in order to retain this important connective route
throughout the site. Buffering along the Nursery wood pLWS
boundary to the west could also be achieved as part of any
landscaping proposals to maintain linkages. Hedgerows and
mature trees could also be retained although there is likely to be
some loss to provide access across the site. The site offers
good potential to deliver habitat creation, restoration and
enhancement particularly around the Tach brook area and
improve connectivity to surrounding sites, features and habitats.
Myton Garden Suburb
(North of Gallows Hill)
The presence of a biodiverse watercourse, veteran trees,
mature hedgerows, ridge and furrow grassland and a good
likelihood of protected species are likely to score this site
unfavourably. However, there are opportunities to retain
important hedgerows and trees and buffer and enhance the
watercourse as well delivering new habitat creation or
restoration on site. The watercourse could provide linkages to a
strategic wildlife corridor in the form of the River Leam
Loes Farm
(North of Woodloes)
The Veteran Oaks, watercourse and old semi improved
grassland with yellow meadow ants are important and unique
ecological features that according to the WDC Habitat
Assessment are a significant constraint to the development at
this site. As much of the site constitutes the old meadow it would
be impossible to deliver even small amounts of development
without adversely affecting these key features and so the site
should score unfavourably on these grounds. If impacts can be
minimised, there may be opportunities to enhance the
watercourse and the plantation woodland on site and improve
the current botanical diversity of the grassland
Red House Farm
(East of Lillington)
The Hedgerows are perhaps the key feature of the site, together
with the opportunities they provide for protected species.
However there are opportunities to retain the hedgerows as well
as potential to deliver habitat creation and restoration throughout
the site.
Land North of Milverton The brook corridor which is a tributary of the River Avon LWS,
the area of semi-improved grassland to the southeast and the
species-rich mature hedgerows and trees are all key features for
the site. The layout of the hedgerows would likely make it
difficult to retain the vast majority of these features and so
should be scored unfavourably on these grounds. Removal of
these features and the any associated mature trees would also
likely disrupt habitat opportunities for protected and noteworthy
species such as farmland birds and bats. Otters may also be a
consideration. There are opportunities to maintain and buffer the
brook corridor in the northeast of the site enhancing linkages to
the River Avon which is a strategic green infrastructure asset.
There are also opportunities for new habitat creation, restoration
and enhancement throughout the site.
Thickthorn (Inc Land
north of Thickthorn)
The section of Thickthorn wood LWS within the site boundary,
the adjacent Glasshouse Spinney LWS, the mature hedgerows
and trees and an area of semi-improved grassland are all likely
to be constraints to development at this site. There are
opportunities to retain and buffer these key ecological features
but there is a risk that infill development in this area will further
isolate or restrict connectivity to and between these features.
Scoring should reflect this cumulative impact. Opportunities for
new habitat creation could help reduce these impacts by linking
up the woodlands as well as contributing towards wider
enhancements to the Arden Landscape area.
More information is needed about the habitats north of
Glasshouse Spinney to provide a more comprehensive
summary for this site.
Land at Blackdown Up-to-date ecological data required
Warwick Gates
Employment Land
Up-to-date ecological data required

Scanned Response Form

Following a review of the Preferred Options, I believe that there are some fundamental flaws in the proposals.

Informing Residents

My initial concern is with the level of marketing surrounding the Preferred Options that has been undertaken. As a resident of Barford I cannot recall seeing anything in the local free press regarding this and merely stumbled across the current consultation process whilst talking to a neighbour. As you are no doubt aware Barford is a very vocal village on issues that will have a major impact on its future and so feel somewhat disappointed that the residents have not be suitably informed on such a major issue in order to shape the village as a whole.

Strategy

Distributed development across the District
Whilst it is acknowledged that a more distributed approach to development is preferable, the weighting of the proposals needs to be considered in more detail.

As a village, Barford's history and character is formed by its organic growth and the fact that it is surrounded by swathes of fields and green belt. Anyone who has had the pleasure of walking around the village and its periphery will appreciate how both interact with each other.

Any large scale development would undermine this character and would infact be detrimental to the area. Barford Village Design statement states that large scale development such as that found at Dugard Place should not be repeated again.

"While small infill does not threaten the overall character of the village, large scale development would be extremely harmful and inappropriate since it would place enormous stresses on the village infrastructure and distort the balance of the community.....Large scale development would be extremely harmful and inappropriate"

This is an adopted document and should be considered carefully when allocating the village a further 100 dwellings through the life of the plan. The village must currently stand at approximately 600 houses, therefore the proposed extension would be an increase of nearly 20%.

One of the aims of the Local Plan is to protect and maintain the character of the District and enhance the assets including the green belt, listed buildings and conservation areas, therefore it seems unreasonable that the Council are proposing a carte blanche for villages on where the development is allocated indeed removing all protection that the Green Belt is afforded whilst decisions are made as to where the preference is to develop further housing. By extending the village envelope and allocating such a large number of houses to the village it would be out of scale with the environs and will have a detrimental impact on the area.

The Green Belt study demonstrates that there are variations in quality of land in the Green Belt and so it would be assumed that these areas that can be found on the whole around the periphery of towns should be the focus of development over any development that is proposed in villages.

It must also be noted that Barford has a core Conservation Area. The 'Barford Conservation Area - Areas of Special Architectural or Historic Interest' document produced by Warwick District Council clearly states:

"Further infill of new dwellings within the Conservation Area should be strictly limited".

The document also goes on to say

"There are significant open areas within the Conservation Area which should be protected. These include.....the playing fields, open areas and grounds of Barford House".


Ensuring the Countryside and areas of Importance for Wildlife and informal Recreation are Maintained and Improved
As previously discussed, whilst the green belt surrounding the village forms part of the setting that provides Barford with its character, it also houses an abundance of wildlife along with offsetting the risk of flooding, which villagers would confirm has in the recent past been utilised on numerous occasions and has protected the village from flooding of the Avon. Barford is most certainly at a critical point whereby the pressure for development is threatening the natural environment.


Ensure that education is provided for in major new developments
Whilst I recognise that most residential developments will attract planning contributions either in the form of S106 payments or the recently introduced CIL. However the current village school is already at maximum capacity with no further room for extensions, therefore any additional residential development in the village would only seek to exacerbate the current situation. The Preferred Options talks about the importance of the existing community and facilities and services and whether they can meet current and future needs. If the proposed 100 houses are located in Barford, then it can be guaranteed that the services will not meet the locals needs, indeed it will be detrimental to the vitality of the community.

Sustainability
Over the past 10 years the number of dwellings in Barford has grown by in excess of 60 houses with the major input coming from the former Oldhams site. However conversely the provision for public transport has been on the decline. The village is on the whole composed of individuals that are reliant on their cars to go to town, to work and generally live their day to day lives; they do not and cannot rely on local transport. Whilst in theory it could be concluded that the proposed 100 houses would increase the use of public transport and encourage additional routes and frequency of buses, there is clear evidence to indicate that this is not the case. Therefore is should be questioned whether Barford should be considered a more sustainable location as any new homes in the area are likely to increase car-bourne journeys, congestion and pollution in the village.

It must be accepted that one of the attractions of living in Barford for those of a working age is that it is indeed only a mile from the M40 and the A46, with most surrounding towns being 10-15 minutes drive. Whilst it is accepted that there are some employment opportunities within the village, this is limited. The majority of the people are required to commute to the surrounding towns and cities. Therefore any large scale proposals such as this should be located in close proximity to the towns and larger conurbations to ensure that T2 of the WMRS is met, in order to reduce the reliance and use of cars, rather than in the outlying villages such as Barford, which encourages their further use.

Scale of Development
The Preferred Options has identified Barford as a Category 1 village which imposes 3 times as many houses on the village than a Category 2 village. However the categorisation of the villages is somewhat flawed. For example Cubbington has a substantial level of facilities in comparison with Barford, yet it is only required to allow for 30 dwellings.

CF2 of the West Midlands Spatial Strategy (WMRS) seeks to limit housing in rural villages to that which meets the local needs and or supports local services. Whilst it is recognised that a limited amount of affordable housing is required within the area, it cannot be accepted that development to such an extent is required to satisfy this requirement.

Conclusion

In conclusion, whilst it is accepted that additional dwellings are required within the District; too much emphasis has been put on the allocations of residential development in the surrounding villages. It is clear to any of the residents of Barford that the proposed figures that are being discussed would be detrimental to the village as a whole in terms of its character, its wildlife, it's conservation area and the community's services.

Therefore it is proposed that the distribution of the development is reviewed with further consideration and the Barford allocation is reduced dramatically to a figure that is more akin with the existing village and of appropriate scale.

See attachment

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

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

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

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

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

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

P05: Affordable housing - agree.

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

P08: see earlier comment

P011: see earlier comment re: County Courts

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

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

Document scanned

The group has 200 members and is locally active in promoting awareness about peak oil and climate change, and finding solutions.
We recognise that the Council is obliged to build more houses, however, we are concerned about the proposed encroachment upon Green Belt land when there is urban Brownfield land available which is vacant and / or derelict. These should be used as a priority and in preference to the Green Belt and Green Field options. WDC has not made a compelling case for the necessity for building on the Green Belt, which should be kept sacrosanct. Paragraph 84 of the National Planning Policy Framework states that in reviewing Green Belt boundaries, authorities should take account of the need to promote sustainable patterns of development. Sustainable development can be achieved by channelling development towards urban areas, avoiding the Green areas.
In 7.19 of the Consultation Document, the sustainability appraisal of the options showed that development which is not in the Green Belt or Green Field has clear advantages, such as the provision of sustainable transport options and reducing the need to travel. The carbon impact of increased vehicle travel from suburban developments will have a huge impact on local air and noise pollution levels and traffic congestion. Therefore the proposed developments fail the review criteria of paragraph 84 of the Framework. We would expect any new developments to accommodate cycle tracks with comprehensive connections to the town centres, and increased bike parking facilities. Development of vacant and derelict non-Green land in the South of Leamington and Warwick, and pockets within the town centres meets the review criteria both in offering more sustainable transport, services and utility options.
At Paragraph 80 of the Framework, five purposes of the Green Belt are indicated;
to check the unrestricted sprawl of large built up areas;
to prevent neighbouring towns merging into one another
to assist in safeguarding the country side from encroachment;
to preserve the setting and special character of historic town's; and
to assist in urban regeneration.
These considerations also apply to Green Field sites. Green areas around the towns conserve the open space between built up areas. Encroachment upon this land will negate this purpose, by reducing the buffer between them, leading the way to even further infringement. The reduction in the existing wildlife corridors will further lessen the opportunity of migration of species as the effects of climate change continue to effect flora and fauna. We need to protect and safeguard these areas in order to be provided for by them. At PO 10, Built Environment, the Council gives an objective 'to protect, enhance and link the natural environment', which these developments will seriously compromise. Bio-diversity studies need to be carried out to establish environmental impact on our flora and fauna, and to ensure that protected species are not endangered.

Transition Town Leamington is concerned about the environmental impacts of building works. Water supplies and ecological considerations need to be accommodated. In the Netherlands, all new developments need to ensure that water run off does not burden the drainage existing system, and that ground water is maintained. Planting trees is an important factor in retaining water in urban landscapes, thus helping to prevent flooding. Sewage can be dealt with in wet systems and reed beds, which increases biodiversity and reduces pollution. We note that some areas proposed for development, particularly south of Leamington and between Warwick and Leamington, are on flood plains, which is not wise.
The Garden suburb proposals do not address the rise in the price of oil as they encourage car dependency. Town planning needs to take into consideration climate change and the current energy crisis. Decreasing supplies of gas will also have a tremendous impact as prices rise, and alternatives for domestic use become more viable. If housing is built at a greater density, it will not encroach so much upon land, which can be used for growing food. The sites need to accommodate enclosed allotments, to prevent the possibility of future development.
The proposed increase of our local population will need food and services, and put more pressure on existing supply chains. Promotion and production of local energy and food sources needs to become a priority in the town planning department, which is not shown in the existing local plan. District heating systems and smallholdings would alleviate these issues.
Higher density will also allow for larger green wedges, which need to be instated to encourage communal areas for recreation and wildlife corridors.
We hope that these concerns will be considered useful in the re appraisal of the local plan.

See attachment

I wish to register my views regarding the WDC Local Plan - helping shape the district - Preferred Options in relation to Kenilworth.
PO1 - I feel Kenilworth is unsuitable for an increase in housing without a considerable amount of extra funds being found. Both medical centres are stretched and schools full.
PO3 - The preferred site for new housing and commercial development would be I believe on unsuitable green belt land. Acient woodland, trees with preservation orders, the noise from the nearby A46 and local road congestion.
PO4 - I fail to see the point of including commercial premises within the Thickthorn plan when the town was unable to get any interest in the empty site on the junction of Common Lane and Dalehouse Lane and it was made into housing.
PO7 - Kenilworth suffers from gypsies and travellers meetings and horse fairs at lease three times a year. The event is held on part of the proposed Thickthorn site. Chaos reins. The nearest pub to the gathering quite often has to close. I understand there is petty crime. The most police you will see in a year in the town appear. Normally there is a lack of police presence and there is no longer a police station in the town. I feel it would be hard to attract anything/one to come to Kenilworth if such a realatively small town had to accommodate such a site.
PO8 - See PO4.
PO10 - Let us hope that the proposed Thickthorn site does not consist of a large number of three story dwelling which would be totally out of keeping with the rest of the houses in the vicinity.
PO11 - Has the Grade II listed house and nearby ancient woodland and roman site been taken into account with the Thickthorn site? Other proposed sites seem to have been given more credence than they deserve. (Can you really see Kenilworth Castle from the proposed Rouncil Lane site?).
PO14 - I would suggest that building houses and commercial buildings on the Thickthorn site will greatly increase congestion in Kenilworth and on to Leamington. I would be interested in what plans could possibly improve situation which developes even before the traffic lights on the Warwick Road at Sainsburys. You can alter the island at the Jet filling station, widen the top of Birches Lane and alter the A46 island but whether you put a road out of the new development into Birches Lane or out on to the A452 Leamington Road it still doesn't alter the fact that there will be 770 new homes a good percentage of which will have cars who will be joining these roads.
PO16 - I feel strongly that it is wrong for WDC to alter greenbelt boundaries.