PO14: Transport

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

See attached

1 Introduction
1.1 In its document Local Plan Preferred Options, May 2012, at para 3.3, the Council invites the views of all interested parties to help shape a draft Local Plan.
1.2 Here are the views of The Warwick Society. They refer to the Full Version of the Preferred Options and in some cases to some of the supporting documents made available on the Council's website. The Response Form, which we have not found effective for structuring our comments, uses the words 'support or object' rather than the Preferred Options' 'the Council is keen to hear the views'. While we have phrased our comments as views, it will be clear that many would be objections to firmer proposals, and will become formal objections if the next stage of the plan-making process does not respond satisfactorily to them.
1.3 The Warwick Society, the town's civic society, was founded in 1951, and has as its first aim to conserve, for the benefit of the public, or to encourage the conservation of, the natural, artistic and cultural amenities of Warwick and its neighbourhood. It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people.
1.4 Warwick is no stranger to development. The mediæval town was largely destroyed by fire in 1694, though many timber-framed buildings at its fringes survived. Rebuilding followed a plan to widen the streets and to improve fire-resistance with stone and brick walls. It took place at the start of the Georgian era. So the High Street, the Cross, Church Street, St Mary's Church and Northgate Street form an elegant and coherent architectural ensemble. It is the juxtaposition of the mediæval with the Georgian which makes Warwick distinctive. More recently, C19 industrial development based on the canal and then the railway has been followed by more extensive C20 sprawl based on the car and the road network. In the decade 2001-2011, the population of Warwick grew from 23,000 to 30,000, a rate of increase of 30%, among the very fastest rates of any town in the UK. Assimilating this growth and building new communities takes a generation.
1.4 The new Local Plan gives a new opportunity to make the town, and the district around it, a finer place, and a better place to live, be educated, and to work in. Its population may grow, because it is attractive, and well-located at the south-eastern corner of the West Midlands. Its future residents, and those who work here or visit, need a vision which ensures that it continues to be attractive, and to function well.
1.5 This means:
1 Developing the local economy sustainably, both facilitating growth in jobs and income and reducing the impact of climate change;
2 A pattern of development which reduces dependence on the car, congestion and pollution;
3 Transport and social infrastructure which enables people to live sustainably and economically;
4 Walking routes, cycle routes, schools, health centres and shops which allow people of all ages and capabilities easy and healthy access to them;
5 A mix of housing which meets local needs, especially affordable housing for families;
6 A rate of development which allows the towns and their communities to absorb change and make each a socially and personally contenting place to be; and
7 Protecting the natural and historic environment, especially the green hinterland of towns, green spaces within them, and the historic buildings which make them special places.
1.6 The Preferred Options fail by a long way to achieve this. The Issues [para 4.8] identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.7 In the following sections, we consider the three main ways in which the preferred options fail to meet the expectation of those who live in the District, and suggest changes which, if introduced to the draft Local Plan, could make it a very much better direction for the District to follow.

2 Population Growth and the Demand for Housing
2.1 The Preferred Options' emphasis on growth in jobs and housing, each matching the other [para 4.10], is founded on a circular argument and on mere assumptions.
2.2 The Strategic Housing Market Assessment [para 5.13] 'projects' (not forecasts) future growth in the District's population. It explains [SHMA figs 2.13 and A2.4] that 'in-migration' has been much the most important cause of population growth in the fifteen years 1996-2010. Of a total population increase of 18.9k (from 119.8k to 138.7k), 16.5k has been net in-migration, and only 2.4k the natural change. The report notes [para 2.33] that 'past migration trends will have been influenced in part by past levels of housing delivery.'
2.3 The SHMA assumes the average rate of in-migration of the last five of those fifteen years, 2006-2010, and projects it for the next twenty. There is no quantified analysis of the causes of the in-migration, nor any quantified forecast of its future level. It is simply an assumption.
2.4 The SHMA goes on to assume an age profile for the in-migrants, again basing its projection on neither evidence nor analysis, but on assumptions, in this case those of the ONS [SHMA para 2.17]. The projection of net in-migration is the difference between two much larger numbers, gross in-migration and gross out-migration, and the in-migration figure is produced only by adding that assumed net projection to the ONS assumption of out-migration. The projection is not a forecast, just an arithmetical exercise, and its predicted growth in population is no more solid than the assumptions and extrapolations on which it is based.
2.5 The extrapolations have as their base the after-effect of rapid housebuilding in the years before the market collapsed in 2008. All that they show - as described at the end of para 2.2 above - is that if houses are built, people will move into them; in a second circularity, if the mass housebuilders do not believe that their output will be sold, they build little. A third circular argument then enters the Plan as it stands: if the population rises, employment will rise, as those who buy and occupy the new houses are very likely to have jobs - without which they do not have the means to buy the houses.
2.6 We conclude that the preferred level of 'growth' is simply a bid for growth, rather than a forecast for which there is either evidence or action plan, other than almost free-for-all development with all of the negative impacts on existing residents and the environment that that will bring. The alternatives of more modest levels of growth, in both housing and employment, with much lower damaging impacts, would be equally valid for the Council to choose. We urge that it should reconsider its preference in the light of the absence of evidence in support of it, and take a broader view of both growth and all its consequences.

3 Infrastructure
3.1 The infrastructure proposals do not provide for sustainable development. The modelling of the existing network against possible locations for development consists only of modelling vehicle flows. It does not reflect the national polices and Local Transport Plan which require priority to be given to reducing the demand for transport, and to walking cycling, and public transport.
3.2 Except for the possibility of Kenilworth station (which would have a negligible impact on demand for road use in the peaks) all of the significant infrastructure proposals are for increases in the road network. They have been selected to deal with some of the local congestion created by increase in demand of the various housing site options. They do not provide a coherent transport network for Leamington, Warwick and Kenilworth, rather a continuation of the existing mismatch between traffic and the capacity available to accommodate it.
3.3 Good railway services are already provided at Leamington and Warwick Parkway stations. The level of service at Warwick station is significantly inferior to that of Warwick Parkway, even though it serves a much more substantial population within walking distance. Conversely, almost all access journeys to Warwick Parkway are by car. For journeys to and from work, Birmingham and London are significant destinations and there is some commuting in to Warwick and Leamington which is badly served by Warwick Parkway. The basis of a sustainable infrastructure plan should be to improve train services at all three of these stations, and especially at Warwick station, and to concentrate development close to them, minimising car use. This possibility does not appear to have been considered.
3.4 The conclusion of the modelling is that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, in particular to meet the Air Quality Management Area requirement to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings all require that the legal requirement to restore air quality should be given absolute priority.
3.5 Instead, the infrastructure plan proposes spending almost all of the potential developers' funding contributions on major expansion and 'improvement' of the road network. The lesson was learned decades ago that changes of this kind, increasing capacity on some congested sections, simply increases congestion on adjacent parts of the network, through the traffic that the improvements generate.
3.6 We are disappointed and concerned that the preferred options do almost nothing to allow transport demand to be met more sustainably, rather simply try to accommodate it at the expense of the environment and of existing residents and road users. We consider that the whole emphasis of the plan should be above all on sustainability of transport, not just for its environmental impact but also because the prosperity of residents of the district depends on accessibility to services without having to meet the increasing costs of car use.

4 Locations for Development
4.1 Much of the criticism of the Preferred Options has been directed towards the allocation of particular areas of greenfield land at the fringes of the urban area on which large-scale house building is proposed. These sites represent a major misdirection of development. We consider that, rather than the strategy of the Preferred Options, the pattern of development in the district should be dramatically different.
4.2 The total level of development should be substantially lower, of the order of 250 dwellings per annum, Option 1, which is sufficient to meet local needs and not to encourage in-migration.
4.3 Unbuilt existing permissions themselves provide nearly five years' supply to meet this level of requirement.
4.4 Beyond these absolute priority should be given to brownfield sites, as provided for by the NPPF. The Preferred Options propose only that brownfield sites should be used at the end of the plan period, the effect of which would be to consume greenfield sites rather than to bring forward brownfield sites by increasing their value. Some brownfield sites may provide for small numbers of dwellings, but these should not be dismissed: there are potentially many of them.
4.5 Brownfield development should include the intensification of existing development within the urban areas. We do not rule out 'garden development', which can often be in locations close to existing facilities and employment and easily served sustainably. There are extensive areas of development carried out mainly in the second half of the twentieth century where more intensive use of existing housing and employment land would be entirely feasible - were the market signals to encourage it. The proposals for much more intensive office use of the IBM/Opus 40 site on the north-west edge of Warwick go too far in this direction, but demonstrate that intensifying development on a site well connected to the transport network can be attractive to developers.
4.6 Only as a last resort should greenfield land be allocated. The suggestion that it can produce high-quality environments by applying the principles of the garden cities is spurious. The garden cities were planned around local employment and services (in the era before the car, competing supermarkets, choice of school admissions, and two-income households became the societal norm): that is not how we live now. All of the greenfield sites at the urban fringe would be largely car-dependent. As well as their damaging impact on infrastructure and on existing settlements, they would not produce stable, happy communities of their own. The rapid growth in population of Warwick in the last decade requires a period of much gentler growth while the new communities gel.
4.7 The allocation of land south-east of Warwick between the Banbury Road and Europa Way does exactly what the Preferred Options say that they wish to avoid, merging the built-up areas to their east and west. The northern part, north of Gallows Hill, would make Warwick, Leamington and Whitnash into a continuous, sprawling urban area. The southern part, between Europa Way and the Banbury Road would extend this sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would have a directly damaging effect on Castle Park, Grade 1 registered landscape.
4.8 The Green Belt was established to end the outward sprawl of the major conurbations. Circumstances change and there may be exceptional reasons for declassifying Green Belt land: the expansion of Warwick University may be a virtuous case of this. But it is essential that its edges should not be eaten into by extending urban sprawl, for example at Loes Farm and north of Leamington, in the opposite direction from that which it was originally intended to prevent. Similarly, when the Green Belt was designated land south of Warwick and Leamington was not seen as threatened by sprawl from the conurbation simply because the towns stood in the way. Now, that land requires the same level of protection as the post-war Green Belt gave to the edge of the Birmingham and Coventry built-up areas.
4.9 Instead, the Green Belt has become the guarantor of favourable surroundings for the few residents in and outside villages scattered across it. Given the severe damage to the existing urban areas that would follow from their outward extension, an entirely different approach is required to find acceptable greenfield sites. The possible 'Gateway' development around Coventry Airport is an example of this approach: it must concentrate employment and housing close to good transport links without creating undue pressure on the existing urban areas. Planned new or enlarged settlements outside Warwick, Leamington and Kenilworth, and in some cases outside the district - delivered through cooperation with neighbouring authorities - should also be preferred. The substantial employment at Gaydon is not matched by housing provision in the locality, rather met by car-borne commuting to it. Warwick Parkway station and the nearby A46 provide an opportunity not for an urban extension but for a new settlement outside the existing urban boundary, which would not damage what lies within it. Hatton and Lapworth, with existing railway stations, could also be the focus of much more extensive development than is proposed.

5 Conclusion
5.1 We have concentrated on the three main ways in which the preferred options would both worsen the quality of life of the district's residents and damage the historic environment.
5.2 In the copious supporting documentation, there are many more details of the proposed policies which we cannot support.
5.3 But we have limited our comments to these three main issues to try to persuade the Council that the eventual draft Local Plan must be very different from the Preferred Options now proposed.
5.4 We urge the Council to reconsider its preferences and to recognise its long-term responsibility to both the environment and the quality of life of Warwick district.

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.

Submission Attached.

See attached.

See attached representations.