PO12: Climate Change

Attached letter

See attached

New Local Plan Preferred Options Consultation
1. Thank you for your consultation dated 1 June 2012, which we received on the same date. Thank you for allowing additional time in which to respond. This enabled our submission to be compiled with the benefit of some input from locally based colleagues.

2. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Overview

3. There is much to commend within the consultation document in terms of protection and enhancement of the natural environment. We have relatively few comments to make but would like to raise a small number of potential areas of concern and possible improvement.

4. We assume the numbered preferred options presented in the mauve boxes foreshadow policies content rather than representing proposed policy wording. For that reason have not recommended any detailed changes to text but have confined ourselves to broader observations.

Detailed comments

Section 2.5 Strategy for the Future and Sustainable Prosperity of Warwick
District

5. We support the fourth bullet under "environment" and second bullet under "emphasis on infrastructure" which pick up on the importance of protecting and enhancing of the natural environment. It is important that the final version of the plan follows through on these important components of the vision. In line with the NPPF requirement (paragraph 157) that

Section 4.12 Enabling the district's infrastructure to improve and support growth

6. We welcome the reference (objective 14) to enabling improvements to be made to the built and natural environments which will help to maintain and improve historic assets, improve habitats and their connectivity, help the public access and enjoy open spaces such as parks and allotments, reduce the
risk of flooding, keep the effects of climate change (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles. This should help to translate the requirements of the NPPF into practice and is welcome recognition of some of the multiple ecosystem and other benefits that the natural environment and green infrastructure delivers for communities.

PO2: Community Infrastructure Levy

7. Natural England recognises that CIL has a part to play in providing the infrastructure that new and existing communities will need. Green infrastructure is a part of the essential necessary to support growth and we trust the Council will ensure that the need to make provision for key green infrastructure

PO3: Broad Location of Growth

8. Natural England is concerned that the overall level and spatial distribution of growth should be informed through detailed environmental testing. From that perspective we welcome the Sustainability Appraisal work undertaken so far and the fact that the allocations have avoided direct impact upon statutory biodiversity designations.

9. We do note that a number of preferred allocations (e.g. Whitnash East) incorporate, or are bounded by, Local Wildlife Sites and/or Local Nature Reserves and would encourage the Council to ensure that sufficient safeguards could be incorporated before confirming these allocations.

10. Similarly, a number of the preferred allocations (e.g. West of Europa Way) lie adjacent to Warwick Castle Park . This site is not subject to any natural landscape or biodiversity designation but is the subject of a Higher Level Stewardship agreement to maintain and improve its environmental value. We would like to ask whether the Council will consider the potential for indirect impacts on the Park (e.g. of increased recreational pressure) and degree to which these can be moderated before confirming these allocations?

PO10: Built environment

11. We welcome inclusion of the intention to protect, enhance and link the natural environment through policies to encourage appropriate design of the built environment. We also welcome the intention to set out a framework for subsequent more detailed design guidance to ensure physical access for all groups to the natural environment. The natural environment and access to it are important aspects of urban design that have been overlooked in some areas in the past.

PO13: Inclusive, Safe & Healthy Communities

12. The third and fourth bullet points are supported, provided a proportion of the new open spaces provided as part of new development are made up of accessible natural green spaces with all the associated health and wellbeing benefits. Natural England promotes an Accessible Natural Greenspace Standard1 that we encourage local authorities to adopt.

PO12: Climate Change

13. Natural England welcomes measures to tackle climate change which is the greatest long term threat to the natural environment. None the less, we look to plans to take full account of the local natural environment to accommodate such infrastructure. In particular, we encourage plan makers to identify areas for different forms of low carbon energy and to ensure that designated landscapes are fully protected.

14. The intention to require that new development is designed to be resilient to and adapt to the future impacts of climate change in welcome. We particularly support the reference to the use of greenspace and vegetation, (such as street trees) to provide summer shading and allowing winter solar gain.

PO15: Green Infrastructure

15. We support the preferred option relating to green infrastructure, which is consistent with the NPPF (paragraph 114). We particularly welcome the recognition that this exists and can be supported through planning at a variety of spatial scales.

16. We would expect the final pan to include more specific detailed policies on certain aspect of green infrastructure. For instance, we trust that policies for biodiversity will extend beyond offsetting to cover the landscape scale approach, net gain, ecological networks, designated sites and priority and protected species.

17. Similarly, the references to geology, soils and ecosystem services are welcome and we would expect that these matters will translate into robust policy content within the final plan.

PO16: Green Belt

18. We support the reference to positively enhance the beneficial use for the Green Belt, such as looking for positive opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity or to improve damaged and derelict land. This is an aspect of Green Belt that has not always been afforded an appropriate degree of attention in all areas.

Scanned representation

See Attachments

See attached documents

See scanned letter and response forms

Attached letter

Scanned representation

Attached letter

Attached letter

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
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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.
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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
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* 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
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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
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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
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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

See attached

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.

Policy PO12 of the New Local Plan Preferred Options document sets out the Council's preferred option for a framework to support the reduction of carbon emissions within the District and ensure that buildings are resilient to the potential impacts of Climate Change.
While we welcome the Council's commitment to sustainable development, a requirement in Policy PO12 to seek a 20% reduction in carbon emissions from developments of 100sqm or more, may not be the appropriate mechanism for achieving sustainability and energy efficiency within new developments.
Paragraph 95 of the NPPF states that "when setting any local requirement for a buildings sustainability, do so in a way consistent with the Government's zero carbon buildings policy and adopt nationally described standards".
The Government's Zero Carbon Buildings Policy is being implemented through the Building Regulations. Therefore in the absence of robust viability evidence to support a target for reduction in carbon emissions, adopting Building Regulations standards would be more appropriate as the local energy standard for carbon reductions. On this basis, the requirement in PO12 to seek a 20% reduction in carbon emissions should be removed.
Paragraph 158 of the NPPF clearly states that "each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence" and strategies should "take full account of relevant market and economic signals."
It is unclear as to how the 20% target for reduction in carbon emissions in Policy PO12 has been derived from the three separate evidence base studies. We would also highlight that these studies have been completed in advance of the NPPF and therefore does not consider the policies as stated in paragraphs 95, 158 and 173, nor do they consider the impact of significant changes to Building Regulations.
Paragraph 173 of the NPPF states that "sites should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened." We feel that in its current form, the policy could be overly onerous and could therefore threaten the viability of a development.
Notwithstanding the above, there is no indication within Policy PO12 as to what the baseline is for assessing a 20% reduction in carbon emissions. Whilst it is assumed that the baseline would be the existing 2010 Building Regulations, the council should be aware that they have no evidence to demonstrate the impact of a 20% reduction above this standard.
Furthermore, whilst Policy PO12 states that non residential developments will be required to meet BREEAM standards, no indication is provided as to what level of BREEAM standard would be sought. As with the target for reduction in carbon emissions, no assessment of viability within the supporting evidence base to qualify a requirement to meet BREEAM standards.

See attached representations.