PO16: Green Belt

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The Parish Council support the Local Plan in principal; we have made reference as detailed below to the areas we feel directly impact our Parish.

The Parish Council would request the housing demand produced by the original survey be revisited to take account of the latest data available, such as the 2011 census results, the later figures from the births and deaths register and inward migration figures.

Also the Parish Council would like WDC to reconsider whether they have given sufficient weight to the unprecedented development in the area over the last few years, which, would make extrapolation of recent figures unreliable.

Comments on Preferred Options

P05 Affordable Housing
The Parish Council are unaware of any demonstrable need for local affordable housing, we do not have an infrastructure to support this type of development, such as public transport and community facilities, however, we are in the process of compiling a Parish Plan. With survey results from the local community imminent, we would wish to revisit our comments should results show otherwise

P07 Gypsies and Travellers.
The District Council has to identify a site for travellers within the district, which it has not yet done.
We currently have one unauthorised traveller site within our Parish, which is subject to an enforcement notice, the unauthorised site does not meet the specification laid down in the new Planning Policy Framework, nor does it meet any of the criteria set out in the Preferred Options. We need to emphasize this point so the Kites Nest site, does not become the default option for WDC in the absence of another site being identified. The Parish Council take the view that the whole area, including Coventry and Rugby, which currently have underused Traveller capacity, is taken into account in identifying potential Traveller sites.

P08 Economy
The Preferred Options has identified the old Honiley Airfield as an employment site; we would insist any new development be restricted to the existing planning consent - potential for currently 2,000 jobs.
We request WDC in analysing the need for employment development consider the recent changes at Haseley Manor, which as an employment site could not attract business to the area and is now in the process of being redeveloped as housing.

P01 Greenbelt
The whole of our Parish lies with in the Greenbelt and we would wish it to remain so, if appropriate we would also wish our Parish to be designated as a "green wedge", providing a significant buffer between the conurbations of Kenilworth, Warwick, Coventry and Solihull.
We have a myriad of extremely well used Footpaths, Bridleways and Cycle routes; we wish these to be preserved as an important area for leisure and recreational activities.

We do not wish housing development forced upon us with the removal and restructuring of the Greenbelt boundaries, but we would support some sensitive infill development within our existing settlements.

P018
As a Rural Parish, we do not have any provision of storm drains to alleviate excess surface water and local road floods. We would wish WDC to revisit their strategy on the maintenance of ditches and gulleys and to also ensure landowner responsibility is enforced.

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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.

See attached

RESPONSE TO WARWICK DISTRICT COUNCIL LOCAL PLAN PREFERRED OPTIONS

PO1: Preferred level of growth
I support the preferred option based on an average 600 new homes per annum, as being realistic against current demographic trends and economic growth projections. However, should economic growth trends change in future years the council should seek to respond flexibly as required.

PO2: Community Infrastructure Levy
This new system of raising funding from new developments to support infrastructure developments offers important new opportunities but also presents major challenges. It requires a new set of relationships between district council, county council and other local partners, to not only draw up and agree CIL-funded infrastructure development plans for the district but to create a long-term stable framework for them to be implemented over many years.

PO3: Broad location of growth
I support the preferred option, and in particular that Kenilworth should have its fair share of new housing development (770 homes per Table 7.2) within the total district target. I disagree with the stated view of Kenilworth Town Council that there should be no further development in the town. A vibrant, sustainable community requires some headroom to expand and develop. There is a clear need for a better housing mix in Kenilworth, especially for more starter homes for young people and opportunities for older residents wanting to downsize to smaller properties.

PO4: Distribution of sites for housing
I support the preferred option that Kenilworth new housing development should be concentrated on the Thickthorn site. Kenilworth Town Council has stated a preference for 700/800 houses to be distributed across the town, but has admitted that this cannot be done while meeting their own criteria. These mixed messages only serve to confuse local residents.
Concentrating new housing development in one Kenilworth location provides the opportunity for the right level of infrastructure development to support this - roads, walking and cycling routes, school and other community facilities. Piecemeal small-scale developments across the town, even if there were suitable sites, would be difficult to support through improved infrastructure, so putting further pressure on existing facilities and resources.
I support strongly the proposed designation of the Thickthorn site for employment use as well as for housing. There has been a long-standing shortage of suitable employment land in Kenilworth. I would not support just an office park however. What is needed is a good mix of employment opportunities, to include for example research and development organisations and light industrial units.
I support the proposed designation of Burton Green as a 'Category 2' village, provided that the Parish Council is fully consulted and involved in decisions about target numbers, types and locations of new housing.

PO5: Affordable housing
I support the proposed option. The proposed policies seem to be soundly based.
It is interesting to note that the Strategic Housing Market Assessment (SHMA) estimates the requirement for 115 affordable houses per annum for Kenilworth alone. This reinforces my earlier statement under PO3 that there is a clear need for a better housing mix in the town. The SHMA estimated need is greater than the total new housing allocation for Kenilworth over the 15 year period of the plan. Consideration should therefore be given to achieving a much higher figure than the minimum 40% affordable housing on the Thickthorn site, and also seeking every opportunity for more affordable housing in any 'windfall' sites that come forward for development within the town.

PO6: Mixed communities and wide choice of housing
I support the proposed option.
Regarding the Thickthorn site, for the reasons stated previously I see the priority within the housing mix being for starter homes for young people, and smaller units for older residents wanting to downsize but to stay living within the town. There could also be an opportunity to cement further the links between Kenilworth and the University of Warwick by the building of new student accommodation - something completely missing at the moment.

PO9: Retailing and town centres
I support the proposed option, in particular promoting the vitality and viability of town centres, and strongly resisting further out-of-centre retail developments.

PO12: Climate change
I support the proposed option, in particular ensuring flood resistance and resilience in all new developments through sustainable urban drainage schemes (SUDS). Well-designed SUDS are not only functional, but can enhance the natural environment of open space areas associated with new developments.

PO13: Inclusive, safe and healthy communities
I support the proposed option, in particular the importance of access to high quality open spaces and sport/recreation facilities for all residents.
In para 13.10 (2nd bullet point), I would like to see the words "pedestrian and cycling" substituted for "pedestrian". Policies should do everything possible to encourage the greater use of bicycles by all sections of the local community, both for healthy exercise and as a sustainable/zero carbon means of transport within our district.

PO14: Transport
I support the proposed option, in particular the strong emphasis on promoting sustainable forms of transport.
The importance of the K2L cycling route between Kenilworth and Leamington cannot be overemphasised, together with provision for bus lanes and bus priority schemes on this important route. I see these as the priorities for highway improvements on this route rather than increased provision for private vehicles.
Within the town of Kenilworth, there is a massive task to be done to improve routes and facilities for pedestrians and cyclists, and this should be the priority for infrastructure investment to support new housing development. I disagree fundamentally with the view of the Town Council that a multi-storey car park is required in the town centre. Policies should be seeking to encourage residents to leave their cars behind for short-distance local trips whenever possible.
Map 5 shows a proposed cycle route through Abbey Fields to link up two elements of the National Cycle Network. This has been the subject of considerable negative comment by some residents, community organisations and the Town Council, which has been reflected in other responses to this consultation I understand.
The council has a duty to balance these strongly-expressed views, i.e. that no cycles should be permitted in or through the Abbey Fields, with the needs of the local community as a whole. I would highlight some of the comments in the Draft Green Space Strategy document, in particular section 4.1.7 on page 19 of that document:
"The value of green spaces can be greatly enhanced by linking them together into corridors and networks giving safe, attractive access for pedestrians and, in some cases, cyclists.
"... enable people living in urban areas to reach the countryside .... provide a green alternative for journeys to work or school."
"By-laws prohibiting cycling and horse-riding in some green spaces may need to be reviewed to achieve this."
Through the development of the Connect2 Kenilworth (C2K) route, the town has gained a valuable green corridor linking it to the countryside, and providing an important new travel alternative for people working at the university, Policies should be focussed on making it more accessible from all points of the town, and there is no doubt that a cycle route through Abbey Fields would become an important link between the west side of the town and C2K. Currently no other options have been proposed which would achieve the same result.
There is also the fact that the Abbey Fields are an important destination in themselves for many local residents, including families with young children wanting to access the playground area, and yet at the moment there is zero provision for any residents wishing to travel there by bicycle. Residents lucky enough to live nearby are able to walk, but others have no alternative but to drive there. With the Abbey Fields car park already at saturation point and due to reduce its capacity shortly, the council must consider how it can encourage more residents to access the Fields by bicycle.
In terms of transport infrastructure to support a new Thickthorn housing and employment development, for the reasons stated earlier a high priority should be given to sustainable transport options - i.e. walking, cycling and public transport. However, this site also offers the opportunity to create an important new link road between the traffic island over the A46 by-pass and the eastern side of Kenilworth (joining Glasshouse Lane at a point near Rocky Lane). As well as serving the new development and ensuring it is fully linked into the rest of the town, it would help to alleviate current traffic congestion around the St John's gyratory - something which piecemeal development of eastern Kenilworth over many years has failed to address.

PO15: Green infrastructure
I support strongly the proposal for the development of a peri-urban park north of Kenilworth. This would build on the success of the C2K Greenway route in opening up this important piece of our local countryside to all sections of the local community.
I do not support the arguments so far put forward for the restoration of the Kenilworth Mere. The outline feasibility study conducted by Warwick Business School MBA students showed that any viable scheme could have a massive impact on a large area of precious countryside adjacent to Kenilworth Castle, almost certainly involving commercial developments such as hotels, apartments etc.

PO16: Green belt
I support the re-drawing of green belt boundaries to the east of Kenilworth and around the village of Burton Green in order to permit the developments proposed in this Local Plan, and for no other reason.

PO18: Flooding and water
As stated previously, I support the requirement for SUDS schemes as part of all new developments.

See attached

GREEN BELT - National Planning Policy Framework requires "very special circumstances"
The Green Belt covers only 13% of the area of England. This preferred plan is for 10,800 dwellings and 43% of land used will be green belt. How can this be justified when there is still plenty of white field land available south of Leamington? Presumably the "very special circumstances" come into effect when the 57% development on white fields has been used. This growth is scheduled to take 15 years at a constant annual rate of 555 houses per year. 57% of 15 is 8.55. So it will be eight and a half years before these "very special circumstances" (ie. white field sites are filled and green belt is needed) comes into effect. By then another plan will have been made!
I disagree strongly with any relaxation of the green belt which is there to stop conurbations merging. This plan will leave less than 1 1/2 miles between Kenilworth and Leamington.
Why does Kenilworth need to expand? It has always been in the past a much smaller town than Leamington and Warwick and mushroomed massively in the 1960s, and also in the 1980s when Knights Meadow estate was built. Why should we let this happen again to keep pace with the other towns? Councillors tell me that the Green Belt is strangling Kenilworth. This is precisely its purpose. We should be grateful that our town has these safeguards in place to protect it.
770 dwellings equates to about 1770 people which is almost a 10% increase in Kenilworth's population in an area which is quite detached from Kenilworth and is not likely to make its inhabitants feel a part of the community. The town centre should be in the middle of the town. Far too much development is on the east side and it should now be the turn of the west, if the Green Belt has to be sacrificed, where there is no risk of it merging with other towns and which would be a short walk to the centre of town without cars needing to be used.
THICKTHORN.
How was the Thickthorn site chosen?
Surely not because it abuts the A46 which is noisy both day and night. Was a site visit made to see just how noisy it will be for all the inhabitants? Were decibel readings taken at various points up the hill to ascertain the suitability of this site? The noise is particularly bad on a hot sunny day with the prevailing south-west wind. What about HS2? The boom will be heard at Thickthorn as it passes 18 times per hour in both directions on the EAST side? This estate will be on the flight path of Coventry International Airport where there is no restriction on night flights and jets scream over the proposed development land and at a very low level on their way to Baginton as they have to avoid the Birmingham flight path, (which is also noisy) as this is the crossover point of the two flight paths.
It would be a very selfish decision to commit people to a life of misery with all this noise even through double glazing. This is not the same scenario as the Woodloes where houses abut the road, which at that point is 4 lanes instead of 6, where there the A46 is the other side of the natural sound barrier of Primrose Hill. At Thickthorn noise is impossible to stop owing to the contours of the land which is a basin causing the noise to be trapped and sweep up the hill towards dwellings. The noise is incessant both day and night. It is an ideal location for the sports fields which are already there, where people can go away at the end and not have to endure it 24 hours a day. Office buildings along it will not dissipate the sound.
TRAFFIC
Having 1200 cars discharging from the estate each morning will be a nightmare and cause even longer queues up Birches Lane and into Glasshouse Lane. It will be a worse effect than the horse fair there every day of the year. Updating St Johns gyratory presumably means traffic lights which will cause long tailbacks into the town centre as they have priority under the give-way scheme.
I cannot understand how a dual carriageway between Kenilworth and Leamington will help as all the traffic will have to funnel in at either end and will just result in 4 lanes of slow moving traffic instead of 2. Creation of bus lanes will in any case limit traffic flow to one lane in each direction to speed up a bus every 10 minutes if you're lucky, and nothing will be gained in terms of traffic build up.
There are no points wide enough along Glasshouse Lane for the junction of a spine road, as the corner with Rocky Lane is on a dangerous bend. In any case, Glasshouse Lane is a unique and attractive feature of 1930s period landscaping, a Kenilworth gem, which should be preserved and which junctions along its length will destroy.
NUMBERS
Where do these figures come from for 10,800 houses?
It is in the interest of the District Council to have as many new houses as possible, as they receive 6 times the Council Tax from the New Homes Bonus Scheme for every new dwelling completed and more than that if they are affordable housing.
This plan is not led by suitability but the interest of landowners to sell off their land for housing.
These are not sufficient grounds for this massive increase in population concentrated in a small area as the plans make little use of rural area development. Lots of villages need regenerating. Radford Semele has had no growth since the 1960s and has a school in place already. It has good transport links to the M40, Fosse Way and Leamington Station and IT IS IN A WHITE FIELD ZONE. If such a large number are needed, they should be put in the South Leamington area on white field sites as Leamington already has all the amenities (parks, department stores, nightclubs, cinemas) jobs to support it. This is a Warwick District Council plan not a Kenilworth plan and there are plenty of other places where housing could be built.

CONCLUSION
Population figures should be challenged.
Green belt should be protected.
Consideration of the effect on the HEALTH of people living alongside a motorway with NOISE and POOR AIR QUALITY owing to constant fumes and directly under a flight path with NOISE due to very low flying aircraft should be made.
DISTRICT COUNCIL
Having looked extensively at your website, I note that according to feedback from the public there is low satisfaction with the way you communicate with people.
I note that you are consulting the people of Kenilworth on Friday 20th July in Kenilworth Library. As the consultation is of 2 months duration, why do you choose to liaise with the people of this town just 7 days before the cut off date for written responses?
Every household in the town should have been notified by post (why not with the Electoral Role info) and notices should have been placed in relevant places about the town as happens for a single house alteration. Instead, the local press is left to do the job for you. You are reaching a small minority. Ask the KWN for circulation figures.
In order to improve this during the further consultation in March / April, I hope you that you will consult everyone by means of a written communication to every household.

See attached

Attached letter

Attached letter

Attached letter

See attached

Thank you for giving the NFU West Midlands Region the opportunity to comment on the Preferred Options Consultation. The NFU is a professional body which represents the interests of 75% of all farmers and growers. Our views are on behalf of the farming and land management sector in general and follow discussion with local members.

It would be appropriate by way of an introduction to offer a few general remarks on farming and the planning system. Clearly food security is a key concern. On a global level it is of absolute importance that the world is able to feed itself; but it is equally important that food is produced in Warwickshire in order to meet our own needs.

The challenge in the 21st century is to increase productivity, maximise output, minimise inputs, achieve environmental sustainability and adapt to a changing climate - all of these challenges are ones which British agriculture is very well placed to meet. It is therefore vital that the planning system helps to ensure that farms can evolve and utilise best environmental practice in order to improve efficiencies and reduce carbon emissions. Our detailed comments on the consultation paper are set out below.

PO3 Broad Location of Growth
The NFU is very supportive of the policy of distributing growth across the District as it will facilitate some growth in smaller rural settlements in order that they remain viable and sustainable. We also welcome the assessment of the Green Belt. It is important to review the situation as the pressures and priorities for development do change. Altering the boundaries and removing some areas could have a positive knock on impact on the agricultural businesses located in these areas. It will give them more opportunities to evolve their businesses in order to remain viable into the future. We would like to enquire why the land south of Harbury Lane, Bishops Tachbrook has been designated greenbelt, as this will constrain the farmers business.

PO4 Distribution of Sites for Housing
We have not made a detailed examination of all the locations outlined in PO4. However, where sites are allocated for development the proximity of the land to existing agricultural business must be examined. Sites should not be allocated for residential development if they are found to be in near proximity to for example an existing livestock unit. We are keen to ensure that development in the countryside does not result in conflict between new residents and existing farm businesses.

The NFU welcomes the support in PO4.D. for rural workers dwellings and the conversion of rural buildings on the edge of settlements. When new dwellings are constructed for farm businesses it is important to ensure that they are able to cope with a range of functions. For example they will almost certainly require adequate space for a farm office and boot room. It is important to note that farming families do not have the option of moving house if they should outgrow their home and this must be recognised when planning new accommodation.

The reuse of redundant rural buildings is a key concern for NFU members. Many of these buildings are no longer suitable for modern agricultural uses for a range of reasons. Having no economic use often means that they fall into disrepair. Therefore in our view it is important that they are given the opportunity of a secure future through redevelopment for residential uses.

PO5 Affordable Housing
The NFU welcomes section B which will facilitate the development of affordable housing in rural areas.

PO8 Economy
The NFU welcomes policy that enables growth of rural businesses and supports the diversification of the rural economy. The NPPF states that "To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century". Paragraph 28 of the NPPF contains a very specific reference to supporting a prosperous rural economy; "Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development". It also states that plans should "promote the development and diversification of agricultural and other land-based rural businesses".

PO14 Transport
The NFU is supportive of the policies aim to provide affordable transport options in villages and rural areas. Unfortunately at the moment there is often no viable alternative to car transport for people who live in rural areas especially if they wish to take up employment.
When considering transport and infrastructure you should be aware that farms and rural businesses are totally reliant on HGV and car transport. Any decisions to target employment away from areas reliant on the road network may have a negative effect upon the rural economy and restrict farm diversification. Tourism also relies on access by private car and new tourism enterprises must not be limited to sites that are accessible by public transport routes.

PO15 Green Infrastructure
Farmers already undertake a range of conservation management measure in order to improve environment quality and enhance biodiversity. This on-going work must be taken into consideration when considering development on farms. Therefore concerns about Green Infrastructure and the creation of Green Wedges should not stifle rural and agricultural development. As we said in the introduction it is possible to increase agricultural productivity whilst continuing to reduce the industry's environmental impacts. By working with farmers and landowners even more can be achieved.
We are concerned by biodiversity offsetting where off site mitigation measures are required. We would welcome the opportunity to discuss how you envisage this working in Warwick District.

PO16 Green Belt
The NFU welcomes the support for farm diversification and rural affordable housing in Policy PO16. These businesses have an essential role in maintaining the local landscape by grazing livestock, maintaining hedgerows and participating in agri-environment schemes. Farms in Green belt areas may need to invest in new buildings or other infrastructure as animal welfare and environmental requirements change. They may also need to diversify their businesses, perhaps by supplying local produce through farm shops. We are also supportive of the flexibility demonstrated in this Green Belt policy as alterations in the boundary must be made in order to support rural development. These changes will help agricultural and rural businesses in the affected areas to develop and evolve in order to ensure their long term viability. However when considering boundary change it is important to safeguard productive agricultural land and it is usually preferable for grade 3 land to be identified for development.

PO18 Flooding and Water
The growth allocations outlined under PO4 will place additional demands on the natural resources of the county. Farmers have a particular interest in this issue as new development will impact upon the surrounding agricultural land. New development sites should have land earmarked for SUDs and green space so that runoff can be captured and managed. We therefore broadly welcome the policy but urge the council to thoroughly investigate these impacts to ensure that adequate water resources and drainage capacity is available to cope with the new demands placed on the District's natural infrastructure.

I hope that you find our contribution to the preferred Options Consultation useful. The NFU is keen to assist the council with the development of planning policy so if you require further information or clarification of any of the points raised in this response please do not hesitate to contact me at the West Midlands Regional Office.

Thank you for giving the NFU West Midlands Region the opportunity to comment on the Preferred Options Consultation. The NFU is a professional body which represents the interests of 75% of all farmers and growers. Our views are on behalf of the farming and land management sector in general and follow discussion with local members.

It would be appropriate by way of an introduction to offer a few general remarks on farming and the planning system. Clearly food security is a key concern. On a global level it is of absolute importance that the world is able to feed itself; but it is equally important that food is produced in Warwickshire in order to meet our own needs.

The challenge in the 21st century is to increase productivity, maximise output, minimise inputs, achieve environmental sustainability and adapt to a changing climate - all of these challenges are ones which British agriculture is very well placed to meet. It is therefore vital that the planning system helps to ensure that farms can evolve and utilise best environmental practice in order to improve efficiencies and reduce carbon emissions. Our detailed comments on the consultation paper are set out below.

PO3 Broad Location of Growth
The NFU is very supportive of the policy of distributing growth across the District as it will facilitate some growth in smaller rural settlements in order that they remain viable and sustainable. We also welcome the assessment of the Green Belt. It is important to review the situation as the pressures and priorities for development do change. Altering the boundaries and removing some areas could have a positive knock on impact on the agricultural businesses located in these areas. It will give them more opportunities to evolve their businesses in order to remain viable into the future. We would like to enquire why the land south of Harbury Lane, Bishops Tachbrook has been designated greenbelt, as this will constrain the farmers business.

PO4 Distribution of Sites for Housing
We have not made a detailed examination of all the locations outlined in PO4. However, where sites are allocated for development the proximity of the land to existing agricultural business must be examined. Sites should not be allocated for residential development if they are found to be in near proximity to for example an existing livestock unit. We are keen to ensure that development in the countryside does not result in conflict between new residents and existing farm businesses.

The NFU welcomes the support in PO4.D. for rural workers dwellings and the conversion of rural buildings on the edge of settlements. When new dwellings are constructed for farm businesses it is important to ensure that they are able to cope with a range of functions. For example they will almost certainly require adequate space for a farm office and boot room. It is important to note that farming families do not have the option of moving house if they should outgrow their home and this must be recognised when planning new accommodation.

The reuse of redundant rural buildings is a key concern for NFU members. Many of these buildings are no longer suitable for modern agricultural uses for a range of reasons. Having no economic use often means that they fall into disrepair. Therefore in our view it is important that they are given the opportunity of a secure future through redevelopment for residential uses.

PO5 Affordable Housing
The NFU welcomes section B which will facilitate the development of affordable housing in rural areas.

PO8 Economy
The NFU welcomes policy that enables growth of rural businesses and supports the diversification of the rural economy. The NPPF states that "To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century". Paragraph 28 of the NPPF contains a very specific reference to supporting a prosperous rural economy; "Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development". It also states that plans should "promote the development and diversification of agricultural and other land-based rural businesses".

PO14 Transport
The NFU is supportive of the policies aim to provide affordable transport options in villages and rural areas. Unfortunately at the moment there is often no viable alternative to car transport for people who live in rural areas especially if they wish to take up employment.
When considering transport and infrastructure you should be aware that farms and rural businesses are totally reliant on HGV and car transport. Any decisions to target employment away from areas reliant on the road network may have a negative effect upon the rural economy and restrict farm diversification. Tourism also relies on access by private car and new tourism enterprises must not be limited to sites that are accessible by public transport routes.

PO15 Green Infrastructure
Farmers already undertake a range of conservation management measure in order to improve environment quality and enhance biodiversity. This on-going work must be taken into consideration when considering development on farms. Therefore concerns about Green Infrastructure and the creation of Green Wedges should not stifle rural and agricultural development. As we said in the introduction it is possible to increase agricultural productivity whilst continuing to reduce the industry's environmental impacts. By working with farmers and landowners even more can be achieved.
We are concerned by biodiversity offsetting where off site mitigation measures are required. We would welcome the opportunity to discuss how you envisage this working in Warwick District.

PO16 Green Belt
The NFU welcomes the support for farm diversification and rural affordable housing in Policy PO16. These businesses have an essential role in maintaining the local landscape by grazing livestock, maintaining hedgerows and participating in agri-environment schemes. Farms in Green belt areas may need to invest in new buildings or other infrastructure as animal welfare and environmental requirements change. They may also need to diversify their businesses, perhaps by supplying local produce through farm shops. We are also supportive of the flexibility demonstrated in this Green Belt policy as alterations in the boundary must be made in order to support rural development. These changes will help agricultural and rural businesses in the affected areas to develop and evolve in order to ensure their long term viability. However when considering boundary change it is important to safeguard productive agricultural land and it is usually preferable for grade 3 land to be identified for development.

PO18 Flooding and Water
The growth allocations outlined under PO4 will place additional demands on the natural resources of the county. Farmers have a particular interest in this issue as new development will impact upon the surrounding agricultural land. New development sites should have land earmarked for SUDs and green space so that runoff can be captured and managed. We therefore broadly welcome the policy but urge the council to thoroughly investigate these impacts to ensure that adequate water resources and drainage capacity is available to cope with the new demands placed on the District's natural infrastructure.

I hope that you find our contribution to the preferred Options Consultation useful. The NFU is keen to assist the council with the development of planning policy so if you require further information or clarification of any of the points raised in this response please do not hesitate to contact me at the West Midlands Regional Office.

-PO1 Levels of Growth
The WDC Housing needs assessment and inward migration figures appear incorrect, the arguments are flawed and the assumptions false. The Council must use due diligence to study the paper submitted by Ray Bullen from Bishops Tachbrook which re examines the migration and population data. It also provides updated figures using the newly published Census information which proves that the WDC conclusions are incorrect.
Mr Bullens report provides a much more realistic conclusion of only 5,336 houses needed over the plan period.

PO3 Broad Location of Growth
I am concerned about the over concentration of development in villages along the B4439 corridor to the west of Warwick. This proposal places far too much strain on this rural area and its infrastructure. Any attempt to 'improve' the infrastructure will adversely affect the rural character of this area. Why is development not being spread to also include villages to the East and North of the District ?

PO16 green Belt
I profoundly disagree with proposals to remove Green Belt status from certain villages.
The principles of creation of Green Belt land are still valid today and provide a valuable protection from inappropriate development.
There are many contradictions between the WDC plan proposals and the National Planning Policy Framework which says that Green belt must be protected unless exceptional circumstances exist. PO16 item B directly conflicts with PO16 item C. (page 17).

If any small scale development is allowed in village locations, the type of housing must not be dictated by developers. The local community must be able to determine what is required for local need.

Any development must be planned in a priority order using Brown Field sites first, secondly developing areas close to existing infrastructure, and only allowing any developments in rural and Green Belt areas as a last resort.

As scanned.

As scanned.

See attached.

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.

I wrote to the Development Officer earlier, 14 July 2012. In the meantime I have consulted with others and as a result of this have additional concerns which I wish to draw to your attention. Please see letter in pdf format as an attachment which refers.

At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became apparent that the Preferred Options Plans, nominally open for consultation and discussion were nothing of the sort. The strong impression given in the presentation was that in the minds of the presenters, the 'only option' open is the one presented, even though the key argument for what constituted the justification for the Green Belt Land Grab was not made. Insult has been added to injury in freely admitting that the 2009 consultation, presumably based on sound 'Planning Criteria' is replaced by the 2012 consultation which clearly is not. The principle of 'Equalising the Misery' is scarcely a sound basis for planning.

This meeting has prompted me to make further comment, particularly when at the end of the meeting the Chairman Jonathan Lander encouraged those attending to make written submissions to WDC and copy their MPs if they felt there was merit in this course of action.

This was made the more poignant when Michael Doody immediately stood up and stated it was in no one's interest to copy the MPs, as there was a risk of repercussions and Local Government loosing control of planning decisions. He elaborated on this theme but found no support for his assertions.

Bill Hunt (Deputy CEO Warwick District Council) gave the WDC presentation at the Church meeting and also present were :

Councillors J.M.Lander (in the Chair), Mrs.A.Kelsey, J.McDonagh, L.J.Sant-Cassia and M.A.L.Tansey; County and District Councillor M.Doody; District Councillors J.S.Hammon and N.Pratt; and Mr. Bill Hunt, Deputy Chief Executive of Warwick District Council; together with some 150 members of the public, including Councillors Margaret Cashmore, David Cox and Peter Delow of Cubbington Parish Council.

There is also the matter of the WDC website, where 'contributors' are encouraged to force their submissions into 'boxes'. This looses the personal touch and is in danger of a total loss of context; the practise is certainly inhibitive. There is no satisfactory substitute for free form written letters ! To give an example of the anger and frustration this sort of thing can cause I refer you to the decision to ask for questions to be submitted in writing at Trinity School 'consultation' meeting, failing to address those questions at the meeting and providing only a summary of responses to 'subject areas raised' did not endear WDC to those taking the trouble to attend the meeting and try put a stop to this apparently politically motivated charade.

The handling of the change of plans to the newly 'Preferred Options' is certainly not in the public interest; and all those I have spoken to, have been greatly irritated by this lack of courtesy and consideration. A significant lack of trust certainly appears to have been generated.

This poses the question When and How do WDC propose to make available copy of letters of comment, objection and support in order to assure the public that letters/submissions are being properly addressed and the content properly taken into consideration; and enable interested parties to see the nature of submissions just as WDC do routinely for the more private and delicate subject of Planning Applications. I should be grateful for your written reply.

Letter detail

When I came to Old Milverton 35 years ago, L.Spa enjoyed an enviable reputation as a
Shopping Centre and was recognised as having a thriving 'community spirit'. Latterly,
much of this has been lost. Independent retailers appear to have lost confidence in
trading in the town. In places empty shops and offices show a town in decline.
By implementing the plans now proposed, the two plots of sequestered Green Belt land in
the Parishes of Blackdown and Old Milverton are set to become 'housing in isolation',
which will result in a 'Dormitory Development'; some say a 'ghetto'. The outcome can only
be a feeling of isolation and a huge increase in unnecessary commuting across L.Spa,
adding to the existing congestion at well known bottlenecks which so far WDC have found
impossible to resolve.
This is particularly pertinent as there is no detail admitted of the proposed infrastructure
intended to service this development. It might not even materialise - for example, if the
sale of the housing proposed founders; a not unlikely outcome in view of the land value
and expected high market value of the new housing in this area. If on the contrary, a
major and inspired infrastructure component is built in and it is successful, it can only be to
the detriment of L.Spa town Centre as shops, offices, services and places of work are
dispersed away from the Town Centre.
By developing a transport hub based on the Railway Station and the commercial/
recreation and services already in place to the south of the town; and locating new
housing development as laid out in the 2009 plan south of the town, it may still be possible
to retrieve much of what has been lost. To develop at Old Milverton & Blackdown can only
have the reverse effect. Our political representation appears to have completely lost sight
of this important consideration.
Why has it not been possible for Warwick District Council to take a grip and reverse the
deterioration experienced in Leamington Spa and exploit the many assets and advantages
associated with the existing infrastructure, services and trading opportunities south of the
town. Significantly, in the first instance, build Affordable Housing where they are needed,
upgrading the empty/derelict buildings and return the many houses originally built for
families to live in but no longer in family occupation.
In summary, It seems the social and cultural life of L.Spa is about to be finally
ripped out of the town and be dispersed into isolated units on the northern
periphery. WDC should be regenerating L.Spa by concentrating its development
from the town centre to the south and not fragmenting it by developing to the north
of the town. What a prospect for legacy !
At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became
apparent that the Preferred Options Plans, nominally open for consultation and discussion
were nothing of the sort. The new plans have been presented as the 'only option' even
though the key component of what constituted, 'Very Special Circumstances' for the
justification of the Green Belt Grab, was not made. It was agreed even by the DCEO that
the plans lack this very necessary robust argument.
Robert Solt demonstrated further weaknesses in the case for the Preferred Options Plans
by explaining that the numbers did not add up, on several counts. Mainly that the model
used was outdated and most of all, the input data was flawed being based on earlier
projections which are no longer valid, resulting in a very considerable overestimate of
housing need. No allowance appeared to have been made for the recent changes in the
nature of the local work force from manual to blue and white collar and a very significant
increase in numbers of professionals and academics.
It follows that a contemporary detailed audit is outstanding and is required to quantify
housing need, specifically to include the changes outlined above. An audit of similar rigor
is required to establish the total availability of development options to include all sites
Whitefield, Brownfield and Windfall (for which a particularly rigorous assessment is
needed and with inducements offered up to encourage this process). An explanation for
the 'apparent loss' of development sites since the previous assessment (see 2009 plans)
would not go amiss.
Missing from the report is a statement covering the impact of changes which must be
taken far more seriously such as the austerity measures and other significant events in
process, including the fate of the Euro and our EU member States and our Trading Status
as a nation committed to the practice of a disproportionately large scale Food Importation
Policy. Food Security has simply not been considered. In large conurbations this could
become the single most important consideration for Local Government.
If Climate Change and an increasing demand for western living standards are to be
aggressively pursued by Indians Chinese and Africans etc., we have the makings of 'the
perfect storm' in the ability of these countries to feed their own people, let alone export.
The UK is one of the more densely populated countries, at least in the EU and perhaps the
one at greatest risk from global food shortages. A consideration not to be taken lightly
when seeking to destroy Green Belt and good quality Agricultural Land.

Scanned representation