2 The Local Plan and Consultation Process

This is an unfortunate process and it has not been handled well - in particular the 2011 stage set expectations for levels of growth and then the outcome disregarded the electorates views and choices - and we all wonder why the public is reluctant to engage in these matters...

It is a shame that the 2011 part of this process was so badly carried out - that consultation offered a choice of growth levels and electors voted clearly for LOW LEVELS despite the associated lower levels of infrastructure provision. It was unreasonable to then say that so much higher levels had to be accommodated. What was the point of that consultation?

All Declarations of Pecuniary Interest for Warwick District Councillors and Parish Councillors should have been published online before the consultation process began.

All information should be published online instead of being sent to Parish Councils where dissemination is haphazard.

The Budbrooke consultation was a 2 hour slot which was very crowded with long queues.

Budbrooke PC has allowed only one evening on 3 August to discuss its response to the Local Plan. The PC should be more flexible.

The on-line system takes some time to master and favours developers and landowners who have more resources.

There now appears to be two additional development sites at Budbrooke and possibly more.

In order to ensure a fully informed consultation process, the locations of all proposed development sites and the proposed housing numbers for each site should now be published on Warwick District Council website and the Parish Council website. Residents should then be given an opportunity to respond on them.

Declarations of Pecuniary Interest of all Parish Councillors

To ensure total transparency, these should have been published at the start of the process and the Standards Committee should now publish them without delay on the Council website

There is no material change to the previous local plan that was issued. According to your figures 99% of people who responded objected to certain parts of the plan and therefore you are not taking into account the representations of the people you are in office to serve. This needs a rethink with proper consultation, not just rehashed plans offered to the public.

I have been delayed in sending in my comments because of the website for the Plan wrongly telling me I was using the wrong e mail or password and I hope these few comments can be added on the early morning after the midnight closure on the 29th ( a strange date which actually confused me!)

1 Clarendon Retail Arcade
One anchor and 42 units are are far too ambitious given the fate of retail units in the town centre currently. Effort should be put into securing one or two high quality retailers to plug gaps. New empty premises should not be risked

2 Extra Homes
Gradualness should be the principle. Resentments are already being stirred up and it is necessary to take people with you. There is a sound argument for resistance to some aspects because current services are seen as already struggling to cope , although these proposals are better than the last ones. The Green Belt should still be respected despite government being more flexible on this principle. But nobody's area should be perceived as being overwhelmed.

The economic case for supporting these numbers is not demonstrated and in this context social housing should be a considerable proportion of the extra build

I hope these few comments should be added

I was pleased that you decided to attend the Forum meeting at Whitnash this evening. I have thought for some time it would be good if you could sense the public feeling face to face.

What you witnessed was the outcry of the public against the Local Plan. Unfortunately because the speakers used the majority of the time lecturing the people on the merits of the Local Plan there was insufficient time for many more questions. Many people left because of this. We consider this is all part of the very poor consultation that has been the norm at the public meetings.

If you personally had given a brief introduction then invited questions you would have received the same information that the independent objectors have been bombarding you with since the start of the Local Plan. Together with my colleagues we speak to the people and understand their feelings. They are frustrated because WDC have not consulted them effectively.

The sadness of this Local Plan is that the sheer amount of work that has gone into it by WDC (and no one is denying that) means it has become their baby and they are now trying to defend it and will not listen to any criticism. That clearly needs to change. You have now seen the reaction and hopefully listened to the voice of the people.

If I can now remind you of the exchange of speech's in 'The House' by Chris White MP for Leamington and Warwick, and The Leader of the House - Mr Lansley, that I read out in the meeting.

Mr White: "Residents in my constituency are becoming increasingly concerned about the local plan being developed by Warwick District Council. They feel that their voice is not being respected and I believe that the Council needs to rethink its ill-conceived proposals."

Mr Lansley: "My Honourable Friend makes a specific point relating to his constituency and his local council. I hope that his local council will listen to what he says. The Localism Act 2011 sets out to give power to local authorities and neighbourhood plans, and tries to ensure that they take account fully not only of the simplified national planning policy framework, but do so in the context of local decision making by local people. He is right to stress that point".

The questions you now have to answer are
1. "Are you going to rethink WDC's ill-conceived proposals?"
2. "Are you going to take account of the simplified NPPF but do so in the context of local decision making by people?" On this point and to make it abundantly clear, the local decision making by the local people is they are totally against the Local Plan and are demanding it be scrapped and altered to follow a sensible alternative as has been suggested.

You and your officers have constantly made the point that you would have to have very special circumstances to build the houses in the Green Belt. Now you have very special circumstances. Spelling that out, there is almost total opposition to the Local Plan despite the attempts to sell it to the people. Personally I do not know anyone who is in favour except those who stand to make very considerable financial gains. Their wishes should be the last thing you consider. WDC should not show any allegiance, consideration or support to developers and land owners. Additionally the current planning applications are premature and should be treated as such. There is no proven need for these aggressive plans so they should be rejected totally if they are supporting the Local Plan.

The local people are telling you that the Local Plan is extremely bad planning and is unacceptable, so WDC need to withdraw the Local Plan, reject all planning applications and then listen to the people who are willing to spend their time in order to get an acceptable solution. The reasons given in objections are all very real arguments but have been rejected by WDC as if they were irrelevant. Or officers have tried to convince us of vain attempts to prove that mitigating measures will be taken. The general con-census has sunk to the accusations that someone is living in a dream world.

Ray Bullen spoke last on the 12,300 number of houses that is the core problem that WDC are using to support the Local Plan. We know there is no hard evidence to support the number of 12,300. As we understand, this is not a figure demanded by government so it must have been invented by WDC. The information used is understandably risky and will not stand up to the test of time.
When setting out the framework of the Local Plan, WDC should have made it their aim to satisfy housing needs to satisfy the needs of the local people. That is why it is called a Local Plan. They should not have set out to place the great majority in one densely packed area so the new residents would need to commute to their work place. As there is relatively little unemployment in the District compared with neighbouring Coventry, then it follows that very little new housing is necessary.

It has been shown that by adopting a much lower prediction of 5,400 homes or thereabouts there will be no need to allow any of the batch of applications now being processed.

Furthermore, to be planning now for what will extend as a plan for the next 18 years is foolhardy and extremely irresponsible. It is seen as bad planning at its very worst. When approved in its acceptable form, the Local Plan should only be allowing a phased number of houses each year. Most importantly the Local Plan should be catering for the needs of Local People and it is not doing so.

WDC should have used a more sensible lower figure to cover for the next 5 years. Then proposed to update this on a rolling basis without the commitment to provide infrastructure for the higher number they have adopted. As I have pointed out in earlier correspondence, and supported by my colleagues this would not have needed the concentrated brown areas on your maps as it could be contained by existing housing stock that needs upgrading, together with brownfield sites.

Further to this and even if we did need the 12,300, and we do not, the houses could be spread through the District by either proportional distribution or the creation of a single new site to the West of the District or a number of smaller ones. Leamington, Whitnash and Warwick have been used extensively in recent years for the majority of housing developments with negative effects on that area. These alternatives have been put forward but are not being examined seriously.

Now it is time to stop this rude attack and think again. WDC do not have to hide behind the NPPF or the Green Belt. These are not set in stone and can be relaxed to stop the intentions of the Local Plan. The Green Belt excuse was used to appease North Leamington protesters but we still seek further information on how this occurred and if members of the Council were involved. There must inevitably be a time when the Green Belt will need to be relaxed. That time is now to avoid great harm to the area South of Leamington and Warwick

There must now be acceptance of the reaction of the public and accept that the Local Plan should not proceed.

WDC have constantly defended the support of and allowing the current planning applications that are tied to the Local Plan. Their excuse has always been that if they do not approve them they will go to appeal by and be judged by a government inspector. This excuse has been traced down to the Rt Hon Eric Pickles MP allegedly threatening to tell his inspectors to approve any such plans. This is a really serious turn of events and is being challenged. If that threat exists it must be removed to allow democracy to decide.

Regarding this point, WDC would be expected to do the right thing regardless of such fears they may have. Failure to do so will be an injustice. They are assured the people who are opposing the Local Plan and its planning applications will support them in that regard.

Finally the representative from WCC was considered to be rude and arrogant in the manner he spoke to the audience. He could not see that no one was listening to his ridiculous and dismissive comments about the road network. It would be appropriate if this comment was passed on to the leader of WCC as relevant to the opposition to the Local Plan..

I am writing in response to WDCs consultation exercise for the New local Plan.

WDC completely ignored the opposition to the recent Gateway planning application and I have absolutely no doubt that if it can ignore 800+ letters of opposition to that development in the green belt and the unanimous opposition of the local parish councils there is no chance of the council listening to any opposing views to their proposed local plan.

I am appalled by the completely arbitrary estimates for future employment land requirements and the non scientific approach to the amount of land required for reserves/margin/flexibility. No reference is made to how these figures are arrived at. Is there a nationally approved way of calculating this or are they in fact just "pulled out of a hat"?

The result of all this will be an over-provision of employment land and unnecessary removal of large amounts of land from the green belt.

I am also appalled at the way previous employment land has been re-designated as housing land thus creating an artificial shortage of employment land. This is another example of "sleight of hand" by WDC and has been done without consultation or support of the local community.

The employment land proposals within the New Local Plan (RDS6, RDS7 & RDS8) should be removed, as they are not logical, necessary, sustainable or based on robust estimates of future demand.

The Revised Development Strategy is acceptable in the compromise that exists in balancing housing/infrastructure with Green Belt land.
There are no exceptional circumstances that allows the use of Green Belt land north of Leamington Spa.
It is vital to preserve the limited green space between Leamington and Kenilworth. Without the Green Belt land there is risk that Leamington and Warwick will merge with the West Midlands.
WDC should now resist approving any planning applications until the Revised Development Strategy is completed. This is to ensure that the correct infrastructure is planned and available.
Brownfield sites are still the best way to plan housing. The development on the old Potterton's site should be completed before any new planning applications are passed.
The foundations for these dwellings are already in place and those dwellings would reduce the numbers of housing units needed elsewhere.
The Revised Development Strategy has a reasonable distribution of new housing across the District. 17% of the new houses will be in the Green Belt North of Leamington, at Thickthorn and Lillington. 15% of the proposed development will be in Warwickshire Villages.
It is important that most of the development is located close to where there are employment opportunities (to the South of Leamington & Warwick). This provides opportunity for people to live close to their place of work. This is turn reduces or eliminates commuting for many people, with a consequential positive impact on the environment & everyone's quality of life.
The prospect of access to a good local workforce will help to encourage more businesses to set up & relocate to the area, helping to generate more jobs & prosperity for the local community.
The Revised Development Strategy provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. It is important that these road improvements are carried out as part of a coordinated plan. Traffic surveys show that road improvements can cope with the planned new development and that locating the majority of the development South of Leamington will reduce traffic movements, ease congestion and reduce pollution.
The Revised Development Strategy should provide for the necessary schools, hospitals and other infra-structure to support the new development.
I have special concerns about Warwick hospital as it struggles now to meet the demand of patients. The hospital and other infrastructures should grow before the population of Warwick and Leamington does.

As a local resident, I am absolutely appalled at the proposed housing developments being suggested for the South of Warwick. The impact of this on traffic, schools, medical facilities, pollution, water provision and control, the character of Warwick as a town is all detrimental.

It is the kind of planning that gives planning a bad name. The number of new houses proposed exceeds our needs. The original exhibition at Myton School in March 2013 about the scale and impact of the development.was economical with the truth. As a result I find myself being suspicious of developers and distrustful of planners and their motivations.

Given the current comments by the Council for the Protection of Rural England and others that the precious, inspirational and irreplaceable English countryside is in danger of being eroded by poorly (some might say lazy) planned developments; it seems my views are justified.

I urge you to rethink, to scale down substantially this development, to take more notice of local feeling, to find alternative locations (preferably brown-field sites to infill), to recognize the constraints on development imposed by schools, traffic congestion, etc. That would be what I would call planning.

As residents of Bishops Tachbrook, I write with concern over the proposed development plans for the areas around the village.

My husband and I attended the recent consultation meeting in the village. After listening to the Council representative, and villagers views and concerns, we came away with the strong feeling that this is already a 'done deal'. The meeting was for the purpose of letting the villagers and those affected close by, know what was to happen to the land surrounding Bishops Tachbrook and Whitnash. It was a marketing ploy aimed at selling us on the 'proposed' developments.

We came to live in Bishops Tachbrook 10 years ago as we wanted to live in the village, experience life in the village community, a semi rural location. We paid a premium for our property to do this.

Why is there such a need to develop every piece of green field, build housing estates on them and let the local residents views become obstructed with bricks and mortar??? Where is the respect for the local residents?

Our farmland is set to become a mass of building developments, and we object to it!

Why so many houses? With banks and mortgage market being slow to respond to demand for borrowing, and so many young people unable to get onto the mortgage ladder, who will occupy these houses? We understand that there will be social housing, and this in itself, sadly brings concerns with it.

Now, it appears, that in a few short years, this will all change, and for us personally, not for the better. The 'village' will no longer be. With the proposed building of approx 3,500 new homes, what can the residents expect?

Our concerns are that:

1. With the proposal of approx 3,500 new homes comes the prospect of approx. 7,000 more vehicles within this villages boundaries. In today's lifestyle, rarely does each home have less than 2 vehicles. Volume of traffic increases significantly where schools are located.
2. This alone presents a real concern, as increased traffic indicates increased air pollution. People living in this area will rely on transportation.
3. The main road through the village becomes a short cut for an increased number of motorists trying to get to the Banbury Road/M40. This affects those who live in the village that also have a need to access these roads, resulting in further delays in commuting to from/work.
4. Employment Land - the suggestion was made that this would be to the benfit of local people by encouraging companies to locate to the area. In our experience, people commute to/from their workplace even if it relocates
5. Residents of Bishops Tachbrook do commute to areas outside of Leamington Spa/Warwick etc., and always will do. We have to go where the work is and some don't have the luxury of choosing where they work!
6. Travel time to/from our place of work increases with the increase in traffic.
7. The value of our homes will reduce if/when proposing to sell
8. Within the next few years, Bishops Tachbrook will become like Whitnash, now a part/extension of Leamington Spa
9. Proposed Primary & Secondary Schools/Local Centre/Medical Centre and certainly a Park & Ride facility? These do not suggest that Bishops Tachbrook will not be affected greatly by the proposals
10. How does the council propose that Warwick hospital will cope with the extra demands on it's already stretched services?
11. Who pays for the sizeable infrastructure required?
12. How will the residents of Bishops Tachbrook benefit from this?
13. How will this new home 'proposal' be policed?
14. Residents express a concern over personal safety/security. How will this be addressed?
15. How will the 999 services cope with the extra demand when they are under manned and already suffering as a result of governmental/council cutbacks?

General: We submit our comments on the above with heavy hearts and pessimism that no account will be taken of the points that are made by a very concerned community, who believe our chosen way of life in this lovely Warwickshire area will be destroyed.

Estimated Needs: I question the need for 12,000 new homes in the WDC area. The proposed concentration of 4,5000 homes (1/3 of the total) south of Warwick/Leamington amounts to destroying the green belt - an attractive rural area of the County. This will create an urban sprawl and almost join up Whitnash, Bishop's Tachbrook with Warwick and Leamington. A distribution of houses among all the villages/towns would be fairer and more pleasant for everyone. Is account taken in the draft plant of proposed developments of 1,400 new homes south of Leamington? More use of brownfield sites, such as Ramsay Rd derelict industrial area in Leamington, would be an ideal site for attractive development; bordering on Sydenham estate it would benefit from the existing facilities. It is currently a disgraceful tangle of empty units and overgrown environs. I understand that new homes are proposed for newcomers from cities and towns. Will the idyllic prospect of a rural life be less attractive when it is no longer rural or attractive.

Warwick and the Castle are the jewels in the crown of the area. Motoring to the Castle from M40, J 13 or 14 presents an outstanding journey past an agricultural landscape; this will be destroyed by a development of the size envisaged and detract from the Warwick experience.

Pollution: The air and noise pollution in Warwick centre itself (already at very high levels), will become a health hazard - and added to pollution from the M40 in this village area, will destroy a peaceful, attractive environment of which the District Council should be proud.

Traffic: Congestion of roads already causes severe problems, consequently we avoid going into Warwick and Leamington at peak times. To drive across the Banbury Road from this village to travel to M40 north, Warwick and Leamington, we sometimes have to journey south to join the convoy of cars from Leamington, Warwick and M40 and then find a turning area before proceeding north!

Access into Warwick and Leamington involves crossing one of the five bridges. The delays even now deter us from shopping in these towns to support local businesses, which WDC should be encouraging. Greenfield development would make residents car-dependent and would further increase the traffic flows into and out of the towns.

Provision of extra traffic-light crossroads at such junctions as Bridge End, Castle Hill, Smith Street would destroy the appearance of these unique historic areas.

Urgent attention should be given to providing a Park and Ride facility from near Greys Mallory Island/A46/M40 to Warwick and Leamington. Other towns, such as Shrewsbury, Stratford, provide successfully this useful facility to maintain the environs of their town centres.

Amenities: The impact of a substantial increase in population on the local hospital facilities and services, including car parking, is a matter of grave concern. Journey times to the hospital are erratic, dependent on traffic flows, and can lead to being late for appointments.

Schools: Some Local schools have already reached their full capacity - particularly if, like our village school, they have worked hard to produce excellent standards, Recently a new family to the village could not get their child into the local school and have to transport him by bus elsewhere, thus aggravating road congestion.

Agricultural: The destruction of good arable land into housing estates is a very worrying effect of the Plan. The country needs to encourage and develop farming to provide food for future generations.

Water Supply/Sewerage Can Severn Trent provide adequate services for such a vast development?

The Local Plan 2013 will see the end of life as it is currently known in the South Leamington Area. I am writing to object in the strongest terms to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.

It is totally inappropriate that applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved. This is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed. I would like the Council to explain why this is occurring.

The council is claiming that 12,300 new homes need to be built. This figure is being strongly contested by many objectors to the Local Plan. Where is the evidence that we need this many new homes? I am aware that a local councilor is working hard to get to the truth of this figure and that 5,400 over the next 15 years is a far more appropriate number for local needs. Which brings me to the point 'Local Needs' is a key phrase. It is my belief that this excessive housing has nothing to do with local needs but the desire for developers to tempt people, who are not local to move to Leamington. This will only add further to the burden currently being inflicted on pressure points on the roads in Warwick & Leamington & all its infrastructure. This is development for developments sake & it does nothing to aid affordable housing . Warwick Gates is a prime example of this, where many of the people living there are commuting long distances, and the vast majority of houses are privately owned and are not affordable to most first time buyers. Far better to build the houses where the jobs are. This would be a far more sustainable solution.
Therefore can the council please tell me where the 12,300 jobs are in South Leamington?

The council mentions in its proposals that 22.5 hectares are being set aside for new employment land. Can the Council please provide me with the name(s)of the business(s) & type of employment likely to be offered.

WDC does not have the right to ask that people only object to sites adjacent to their homes, this is an issue for the community and not just those closest to the sites as the impact will affect all of us. I strongly request that the council explains itself. Clearly the council fears the amount of responses it is going to receive, if the council cannot cope than this plan is unsustainable and should be rejected.


This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash. When it was seen for the first time in public it has appeared as a statement of intent and not as a suggestion with alternatives.

Scale and proportion

* massive long term coalescence of settlements,
* loss of significant open space,
* loss of local countryside,
* loss of agricultural land,
* lead to significant urban sprawl.
* excessive bulk and scale,
* significant overdevelopment of the area

The effect of these potential developments on the existing local communities and infrastructure will be devastating, and I believe have been grossly underestimated by both Warwick DC and the developers.

Effect on local road traffic/infrastructure

The road infrastructure south of Warwick/Leamington and around Whitnash is already stretched.

* 2 or more cars per household,
* 9000 extra vehicles using the local road network.
* the local road infrastructure is inadequate. (e.g congestion on various local roads)
* traffic heading towards the town centres is already a major problem,
* gridlock, increased pollution etc.
* congestion on rural roads outside the town at peak times is also already a problem
* traffic noise,
* potential increased danger to pedestrians and children.

The National Planning Policy Framework, Policy DC7 states:
"Policy DC7 goes onto highlight that development will not be permitted where it generates significant road traffic movements, unless mitigation measures are used to avoid adverse impacts."

These developments will generate significant road traffic movements, and I do not believe that mitigation measures will alleviate the problem, certainly on a local level. If all the developments in the area are given the go ahead as part of the Local Plan, the situation will become untenable.

Effect of local services/amenities

The National Planning Policy Framework, Policy DP2 states:
"that development will not be permitted where it has an unacceptable adverse impact on the amenity of nearby uses and residents and/or does not provide acceptable standards of amenity for future users / occupiers of the development."

* pressure on local schools
* primary schools already oversubscribed year on year
* increased pressure on the local secondary schools
* effect on catchment areas
* effect on applications from siblings of children already in one school
* new schools not "guaranteed" to be built as part of the developments
* limited access to doctors and dentists surgeries in the Whitnash and Warwick Gates and Myton areas already
* effect on increased numbers on the local hospitals

Flood Risk

* already flood issues in Whitnash and Warwick Gates
* scale and density of proposed housing,
* large areas of paved/concreted or tarmac surface etc,

Alternatives to the Local Plan

There are many reasons why the Local Plan represents a disaster for the whole of the South Warwick/Leamington/Whitnash areas, predominantly because of the sheer concentration of most of the districts proposed new housing in one relatively small area.

Alternatives that should be considered include:

* Identifying existing housing that is derelict or currently unoccupied,
* Identifying empty industrial units with a view to use the land for brownfield site housing.
* Identifying an area in the surrounding countryside to use to build an entirely "new town".
* Spreading the numbers of new homes evenly around the district, with lots more much smaller developments.
* Smaller developments given to local builders rather than large national firms, thus helping the local economy.

Applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed.

Therefore, I hope you listen to the concerns and suggestions of the residents of your district, and act accordingly. This Local Plan cannot be allowed to come to fruition, and I hope Warwick DC come realize that, withdraw it, and refuse all the various planning applications relating to it, namely:

W/13/0776 - 280 homes at Woodside Farm fields
W/13/0606 - 720 homes on Lower Heathcote Farm land, south of Harbury Lane
W/13/0603 - 370 homes on land west of Europa Way/South of Gallows Hill
W/13/0607 - 220 homes on Hawkes Farm fields
W/13/0036 - 200 homes on Grove Farm fields (application on hold)
W/13/0464 - large Retirement Community development on Gallagher Land near Heathcote
W/13/0858 - upto 100 homes at Fieldgate Lane/Golf Lane, Whitnash

I hope Warwick DC would also refuse any new applications relating to the following:

Myton Garden Suburb - upto 1250 homes
Further development South of Gallows Hill - upto 260 homes
Former Severn Trent Sewage Works - 225 homes
Further development at Grove Farm - 375 homes
Whitnash East/South of Sydenham - 500 homes

We wish to object to the Lapworth (Kingswood) Revised Development Strategy and the proposed development of Kingswood Nurseries and Kingswood Farm.

Our objection is based on the following points:

1. The proposed development sites - Kingswood Nurseries and Kingswood Farm
The Land that these proposed sites occupy is not in the parish of Lapworth as the proposal states. They are in fact in the parish of Rowington. As residents of Rowington parish and who live opposite the proposed sites, we have not been notified of any proposed development within the parish of Rowington. We understand that we haven't been notified due to the fact that there is no proposed development for Rowington parish.

2. Flooding
The Environment Agency has previously objected to the development of these sites on the grounds of flooding. A previous application for 11 dwellings was refused due to the risk of flooding in 2004/5. The new proposal for 50+ houses by far exceeds what has previously been refused by the Environment Agency. The land and nearby properties are already subject to flooding and the proposed size and scale of the new development can only serve to exacerbate this. In recent years, the road has become impassable due to the level of flood water from Kingswood brook, which bounds the proposed site. The hairdressers, post office and residential properties opposite and adjacent to the site have all been regularly subjected to flood water.

3. Highways
The Old Warwick Road is designated as a 30mph zone. However, traffic regularly speeds through the village. The proposed site has a hump back bridge to the east and a bend in the road to the west. In addition, there are vehicles parked on the verge and on the highway throughout the day and night, making the proposed access dangerous to both users of the proposed junction and to passing traffic.

4. Retirement / Social Housing
It is unreasonable to suggest that Rowington Parish needs additional retirement / social housing. There are almshouses and retirement bungalows within both Rowington and Lapworth parishes which already meet the needs of local retired people. The fact that there is no real prospect of obtaining a job locally and the fact that there are no local amenities such as a convenience store, chemist or other retail shops would also question the need for social housing especially as there are no frequent public transport links serving Rowington. From firsthand experience, we know that these issues exclude people without their own transport as it makes living in the parish a very isolated and lonely existence. Developments such as this proposal are more suited to areas that have good public transport links and those that have good local amenities.

5. Greenbelt
The proposed sites are both within designated greenbelt land. Under current legislation, greenbelt land is protected from development. By definition, this means that sites that are not greenbelt should be considered and developed ahead of any greenbelt site. It is unacceptable to put forward a development proposal on greenbelt land when more suitable local sites are available without the inherent problems listed above.

6. Village category
We believe that Rowington and Lapworth should not be classed as category one status. They are both small settlements that do not have the infrastructure, services or the environment to support such large-scale development as is being proposed.

We wish our objection to be registered with all future consultation processes and communications regarding the proposed development at Kingswood Nurseries and Kingswood Farm.

We write to raise our strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.
This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.
Scale and proportion
 massive long term coalescence of settlements,
- loss of significant open space,
* - loss of local countryside,
* - loss of agricultural land,
* - lead to significant urban sprawl.
* - excessive bulk and scale,
* - significant overdevelopment of the area
The effect of these potential developments on the existing local communities and infrastructure will be devastating, and I believe have been grossly underestimated by both Warwick DC and the developers.
Effect on local road traffic/infrastructure
The road infrastructure south of Warwick/Leamington and around Whitnash is already stretched.
- 2 or more cars per household,
- 9000 extra vehicles using the local road network.
* - the local road infrastructure is inadequate. (e.g congestion on various local roads)
* - traffic heading towards the town centres is already a major problem,
* - gridlock, increased pollution etc.
* - congestion on rural roads outside the town at peak times is also already a problem
* - traffic noise,
* - potential increased danger to pedestrians and children.

The National Planning Policy Framework, Policy DC7 states:
"Policy DC7 goes onto highlight that development will not be permitted where it generates significant road traffic movements, unless mitigation measures are used to avoid adverse impacts."

These developments will generate significant road traffic movements, and I do not believe that mitigation measures will alleviate the problem, certainly on a local level. If all the developments in the area are given the go ahead as part of the Local Plan, the situation will become untenable.

Effect of local services/amenities
The National Planning Policy Framework, Policy DP2 states:
"that development will not be permitted where it has an unacceptable adverse impact on the amenity of nearby uses and residents and/or does not provide acceptable standards of amenity for future users / occupiers of the development."

* - pressure on local schools
* - primary schools already oversubscribed year on year
* - increased pressure on the local secondary schools
* - effect on catchment areas
* - effect on applications from siblings of children already in one school
* - new schools not "guaranteed" to be built as part of the developments
* - limited access to doctors and dentists surgeries in the Whitnash and Warwick Gates and Myton areas already
* - effect on increased numbers on the local hospitals

Flood Risk

* - already flood issues in Whitnash and Warwick Gates
* - scale and density of proposed housing,
* - large areas of paved/concreted or tarmac surface etc,

Alternatives to the Local Plan

There are many reasons why the Local Plan represents a disaster for the whole of the South Warwick/Leamington/Whitnash areas, predominantly because of the sheer concentration of most of the districts proposed new housing in one relatively small area.

Alternatives that should be considered include:

* - Identifying existing housing that is derelict or currently unoccupied,
* - Identifying empty industrial units with a view to use the land for brownfield site housing.
* - Identifying an area in the surrounding countryside to use to build an entirely "new town".
* - Spreading the numbers of new homes evenly around the district, with lots more much smaller developments.
* - Smaller developments given to local builders rather than large national firms, thus helping the local economy.

Applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed.

Therefore, I hope you listen to the concerns and suggestions of the residents of your district, and act accordingly. This Local Plan cannot be allowed to come to fruition, and I hope Warwick DC come realize that, withdraw it, and refuse all the various planning applications relating to it, namely:

W/13/0776 - 280 homes at Woodside Farm fields
W/13/0606 - 720 homes on Lower Heathcote Farm land, south of Harbury Lane
W/13/0603 - 370 homes on land west of Europa Way/South of Gallows Hill
W/13/0607 - 220 homes on Hawkes Farm fields
W/13/0036 - 200 homes on Grove Farm fields (application on hold)
W/13/0464 - large Retirement Community development on Gallagher Land near Heathcote
W/13/0858 - upto 100 homes at Fieldgate Lane/Golf Lane, Whitnash

I hope Warwick DC would also refuse any new applications relating to the following:

Myton Garden Suburb - upto 1250 homes
Further development South of Gallows Hill - upto 260 homes
Former Severn Trent Sewage Works - 225 homes
Further development at Grove Farm - 375 homes
Whitnash East/South of Sydenham - 500 homes

I wish to respond and object most strongly to the Revised Local Plan. The first point I would make is that the process seems hopelessly flawed. In 2009, before the last election, the fields between Myton Road and Europa Way were earmarked for development and residents in the area objected formally in their hundreds. (Please check records. ) Yet in 2012 the Preferred Options once again earmarked this area: this time for far more development. Last year again we objected. Why is the consultation process not taken seriously?
Level of Growth
It is my understanding that during the last 12 or 13 years Warwick has undergone a large increase in population, indeed 12% since 2000, which is approximately twice the rate of increase for Warwickshire and twice the national average, and indeed three times the increase for the West Midlands. I would therefore strongly question the need for this level of growth and object to it.
Broad Location of Growth and Transport
I object to the urban fringe development of fields to the West of Europa Way. As no doubt you are aware Warwick has geographical limitations because of the river and the historical centre. Traffic from the Myton Road area is funnelled onto the Banbury Road Bridge and through the constricted town centre. The Revised Local Plan would necessitate that perhaps an extra thousand cars per day would need to cross Warwick in order to reach the A46. As someone who lives and works in Warwick and takes the children to school in Warwick, I foresee massive irresolvable problems with traffic by increasing the number of cars on roads which cannot be improved or widened.
I object to the proposed development of this area with relation to traffic on Myton Road. Myton Crescent is impassable for half an hour at the beginning and again at the end of the day due to Myton school traffic. Similarly, the Banbury Road end of Myton Road suffers in the same way when Warwick Preparatory School and Warwick Senior School begin and end.
If new employment is being created in Coventry and Gaydon, surely the sustainable planning option would be to build dwellings there? Alternatively, local villages where there are good transport links and the potential to improve road access should be developed, rather than the urban fringe development of Warwick. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46.
Historic Environment and Green Infrastructure
I object specifically to developing the area west of Europa Way. It was designated an area of restraint when building work on the Technology Park took place. The notion that the Myton area will be some sort of 'garden suburb' seems to be nonsense when you look at the number of buildings proposed and the impact on the environment.
Climate Change
I try to walk my children to school when I can and I am horrified by the discovery that the entirety of Warwick town centre road network is in breach of Nitrogen Dioxide levels. This problem has been in existence long before the Preferred Options have been set out (Warwick District Air Quality Action Plan 2008), and remains in breach of these regulations today. I object to the increased public health risk which adding more cars to the centre of Warwick at peak times will certainly contribute to. Slightly outside the centre of Warwick, anyone who lives in Warwick knows how congested Myton Road is for 1.5 hours at the start of each day and again from 3.30pm until about 6pm at the end of each day. I walk past stationary vehicles and noxious fumes as I walk my children to and from school. The new Morrisons has increased congestion further. The idea of adding thousands more houses to this area and cars to this road network is desperately poor planning.
Myton Crescent floods whenever we have heavy rain, even if only for a short period of time. Houses in Myton Crescent and The Malins are at serious risk of flooding if the relief offered by the fields on the area of restraint were to be removed by building on these fields. The Revised Local Plan would seem to me to be negligent in that it is not future-proofing residents against our increasingly erratic weather patterns. I attach a photograph taken this week to stress my point.

write in response to the consultation period currently in operation with respect to the "Local Plan Revised Development Strategy."

I firstly write to support the removal of planned development on greenbelt land to the North of Milverton. Development here would be totally unacceptable and in direct contravention of the NPPF. The fact that Warwick District Council has now developed both the "Core Strategy" and "Local Plan Revised Development Strategy" without development on this greenbelt land effectively proves no exceptional circumstances exist.

To U-turn to a plan which does involve development on the North Leamington Greenbelt would be unacceptable because there would be far too great a risk of coalescence with Kenilworth and Coventry. There is a very well used public footpath running through the greenbelt land there providing an excellent leisure and exercise resource for the local people of all ages and free of cost. Trying to incorporate this into development there would not be successful and would result in a loss of that resource. Furthermore the transport assessment the council has produced/published shows that development in this area would result in greater congestion and therefore pollution than development in the South. There has quite clearly been immense local opposition in the previous consultation to development on this greenbelt land and all the points raised opposing development there that were raised in the previous consultation must be carried forward to this consultation, I will not be able to list them all here but expect them to be noted in the summary of consultation responses to this consultation, to not do this would be a lack of joined-up thinking by the council. In short development on the North Leamington Greenbelt would be in direct contravention to the NPPF in terms of not meeting the exceptional circumstances requirement, would be unsustainable for the future of the district and would require an entire new consultation process which the district does not have time to do because of the serious delays that have already been incurred in getting this plan out and the subsequent knock of damaging effects of not having a plan.

I realise that a Joint Strategic Housing Need Assessment has occurred or is on-going, it is essential that the council put together a strong argument as to why Warwick District cannot accommodate any of Coventry's housing needs. However if they fail to do this it is imperative that any additional development is not located on the land to the North of Leamington - indeed there are further development opportunities on non-greenbelt land and on brownfield land that must be brought to bear first. For example the removal of development from "The Asps" is bizarre. The argument is that development would be seen from the castle and therefore would change the historic setting of the castle. Castles were traditionally built on hills in order to look over the towns they were charged with, if there was to be a heritage loss by building on land that can be seen from the castle/can see the castle then development around almost every castle in the entire country would be, according to these principles, incorrect! Indeed there have been many developments in view of the castle/viewing the castle in recent times. This argument is null and void, the heritage value is within the castle itself and it's immediate surroundings (which the Asps does not qualify as). Should you want to preserve a view of the castle from the Asps then this could easily be incorporated by use of a linear park. The Asps is just one example of many non-greenbelt sites that should be built on before greenbelt land.

Furthermore should more housing be needed, a proper, formal assessment of a new village to the South of the district has not been completed, there is ample space to build one of these and this assessment must be completed before development is considered on greenbelt land. This assessment should be started from the position of "Is it possible to build a new village in the South of the district?"

Finally the council has identified a huge number of potential gypsy sites, the requirements needed to make each site suitable to be selected are very similar to the requirements needed to make sites suitable for housing developments. Therefore all proposed gypsy sites that do not accommodate gypsys could accommodate housing development before greenbelt land. This particularly includes land to the West of Warwick Racecourse that is conspicuous in it's absence from planned development - whilst some of this site floods the majority of it does not, and can therefore be built on. The allocation of the site as a potential gypsy site includes the "racecourse spur," unless the council has been disingenuous in it's inclusion of the site as a potential gypsy site then this spur should thus not create a barrier to development, finally there is already road access to this site and it has been offered up for development by it's owners.

There are therefore many options for development of housing on land that is not greenbelt land to the North of Leamington and these must be built on before development on the greenbelt. Were the plan to develop on the North Leamington Greenbelt be re-ignited then so would the immense local opposition and the plan would be fought right through to the inspectorate and judicial review beyond that, based on the sound knowledge that the plan would be the wrong plan for the future of the district.

There are positive aspects to the current plan, which is why it should remain in place; by placing development in the South then accommodation can be near existing employment facilities and the M40. Concerns raised by people across the county about pollution and congestion clearly demonstrate that development should be in the South. The transport assessment shows that development in the South reduces pollution compared to building in the North. This goes not only for the current plan, but also should any more development be needed - this too should be located in the South. If development was not located in the South then people would have to travel to supermarkets, employment land and to the motorway and there is no convincing guarantees whatsoever that this could be mitigated.

A further advantage to the development in the South is that public services can be targeted to that particular area, with new schools etc, that are purpose built to meet the needs of that population, spreading development over the district with bits here and there would mean a make-do-and-mend approach would need to be taken, with worse outcomes for the current population, future population and the education of the next generation.

At meetings regarding the Local Plan Revised Development Strategy there have been arguments that the plan is 'not fair.' These and other simply emotional arguments should be ignored, the plan is fair - there remain plans for development in North Leamington, including on the greenbelt eg at Thichthorn and Lillington and significant development in villages including Milverton . Emotional arguments should be ignored and politics should not intervene in planning the future development of our district. Planning should be based on planning principles. Indeed the reason that these emotional arguments have arisen, I believe is not due to the plan itself, but the way it has been presented to residents by the council. For example development in direct-contravention to the NPPF should never have been proposed in the North Leamington Greenbelt in the first place, doing this has caused the South to see "a change" this should never have happened, furthermore there has been no attempts to demonstrate the attractive nature of development to the South. For instance better and bigger provision of schools, pollution mediation methods, or the advantages of the Community Infrastructure Levy. Perhaps the greatest failing is the failure to properly use the proposed country park to the South of the Town to mitigate development and improve that area for local residents, rather than build it on the outside of the town so far fewer people can benefit from it. I will now discuss this in greater detail:.








Proposed Country Park to South of Town

The proposed country park demonstrated in the image on the left is totally in the wrong place. It has I believe been put there not for planning reasons, but for political reasons. It has been put there to appease the tiny minority of people who live in Bishop's Tachbrook. Interestingly the county councillor for Bishop's Tachbrook is the district councillor who seems to be in charge of the local plan.
I agree that a park in this area is absolutely essential to development in this area, but rather than being placed on the outside of the new development it should be placed bordering the existing housing. This would mitigate the quality of life impact of the new development for people living in existing housing. It would also act as a green lung and therefore help to mitigate the pollution impact of new development. In effect locating it next to existing development it could mitigate the concerns of the many existing local residents have and what will no doubt be their responses to this consultation. This should be the council's response to their concerns.
In it's current form this park is in direct contravention to the NPPF - it is not sustainable as the plan states that is would create a permanent boundary to the South of the town. This is unsustainable. Development cannot happen to the North of the town due to risk of coalesnce with the major urban areas of both Kenilworth and Coventry. However the next major urban area to the South is Banbury many miles away. Therefore in the future the town must develop Southwards and this park prevents that and is unsustainable because it fails the NPPF's economic test of sustainability - "ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation;" it contravenes it's social test for sustainability "meet the needs of present and future generations;" and it fails the environmental test by not maximally "minimis(ing) waste and pollution" as a park adjacent to existing development would act as a green lung and reduce pollution.
The park also contravenes the NPPF because building this park adjacent to existing development and not where currently planned would contribute to "improving the conditions in which people live, work, travel and take leisure" as this land would be more accessible to more people and would thus be more of a "creative exercise in finding ways to enhance and improve the places in which people live their lives." By having walking and cycleways across this park this would encourage sustainable activity again meeting the NPPF's demand to "actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling."
Using this park in this way would also take account of point 66 in the NPPF "Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design nof the new development should be looked on more favourably."
It would also meet paragraph 69 "safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas" as this land would be more accessible and better used.
It would further meet paragraph 73 "Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities." because a park between existing and future development would be more accessible to local people.
Therefore in conclusion to this section there are very many reasons why this park should not be located in it's current unsustainable location as a Trojan horse to force future unsustainable development on the Northern Greenbelt, risking the future of this district out of a seemingly politically motivated desire to provide a quite excessive level of protection to Bishop's Tachbrook, which is still quite a way from the proposed development anyway. Many people feel very strongly on this issue and it would certainly make representation to the inspectorate regarding this element of the plan and indeed it would be a shame for the plan to fail on something which could be a great opportunity but is currently being mis-used. A much better location for the country park is shown on the right:

I write this with no great belief that any notice will be taken. The District Council approach to the villages involved seems to me to be one of obfuscation and concealment of information. One guesses that this tactic is be able to claim that people have been consulted whilst doing exactly what suits them and the building industry. I restrict my comments to the following three concerns.
1. The ILG figure of 12300 has been called into question and is thought too high. However there seems to be a lack of clarity on this and there seems to be an implication that this could even rise with consequences for building allocations.
2. The scoring criteria for Primary Service Village category is not by any measure objective and seems to be based almost on whim. In the case of Lapworth/Kingswood this seems to be based on an intention that it will be placed in the highest category come hell or high water rather than anything else. .
3. It is accepted that some development in any village is inevitable. With good sense this can be done without affecting too much the character of the place. However in the case of Lapworth the development is now to be concentrated in the area of Kingswood.and proposed level of housing numbers would swamp that area, with adverse effects on the local infrastructure. As to the character of the place, that, of course will go out of the window - but hey what does that matter !

I would like to make my objections known about the "Revised" proposals to the Warwick District Local Plan 2013. Anything less consultative I have yet to experience! I feel my civil rights are of no consequence to the non-elected members of the WDC. I do not approve, and object to, the "Sheriff of Nottingham" approach to Local Government.

As the form produced is inadequate for the task, my specific objections are listed below:

ROAD INFRASTRUCTURE
Piecemeal "improvements" can be compared with the little Dutch Boy with his finger in the dyke. The proposed improvements are TOO LITTLE, TOO LATE! Warwick and the environs are already hopelessly traffic clogged. Until work starts on a by-pass or ring road any future housing development plans should, in all conscience, not even be considered.

AIR POLLUTION
Parts of Warwick Town Centre and adjacent feeder streets already have Air Quality deficits. What will 6,600 new dwellings - and the accompanying vehicles - do to the Air Quality?

HEALTH
Do not the WDC non-elected officers have a Duty of Care towards the health issues of the present inhabitants? Are the non-elected officers unaware of the detrimental health issues associated with poor air quality? A follow-on problem is the fact that the medical facilities are already over-burdened without space to expand.

I sincerely hope my objections will be taken seriously.

I am writing to express my horror at the new draft Local Plan and the threat it poses to the local area. This plan flys in the face of concerns expressed during the 2012 Local Preferred Options consultation and goes against the professed "Vision" and aims of Warwick District Council. If the Council goes ahead with this it is ignoring its own promises to local residents and the opinions of the local people whose taxes are funding the Council.

The new plan involves an excessive number of new houses concentrated in a small rural area, replacing agricultural land with an urban sprawl. Calling the development a "Garden suburb" will not change the fact that we are talking about thousands of houses on greenfield land. This many houses are NOT needed and certainly not in one place. The local need is for fewer than 6000 new houses by around 2030. This proposal is for more than double that, with 4500 of them south of Warwick. This is larger than the village I live in, which has grown gradually over hundreds of years. Building such a volume of housing all at once, in one area is reckless and unnecessary.

The Council states in its plan that it wishes to "Avoid development in locations which could potentially lead to the coalescence of settlements". Leaving a small section of land around the Tach Brook as the only space between a new sprawl of housing connecting to Warwick Gates, to Whitnash, to Leamington and Warwick is an insulting token gesture and does not address the concerns raised by residents of the area in the Preferred Options consultation of last year. Describing this land as a "Naturalistic open space/ buffer" says it all. We do not want a tiny strip of "Naturalistic" land, we want the natural landscape and agricultural land that is there now. To insinuate that this buffer will mitigate all the problems is at worst blatantly dishonest and at best woefully ignorant and naïve.

This volume of housing will cause an unbelievable increase in traffic and congestion through the area. We have already seen the effects of the Warwick Gates estate on traffic through the village and en route to Leamington and Warwick. This would increase pollution, road traffic accidents and make journey-times much longer. If new schools are added to the mix, traffic problems would be exacerbated further - it is already that case that traffic is about 10 times worse during term time than during school holidays.

The Council also states that it wishes to "Develop sustainable communities". How about protecting exisiting communities? As was shown in the recent consultation on parish boundaries, Bishop's Tachbrook is a strong and thriving independent community with a great history - again, this is being threatened by the plan to build thousands of new houses and practically link us up with the urban area that is Warwick Gates/ Whitnash / Leamington.

What the council is talking about is replacing agricultural and natural landscapes with a vast amount of housing, then as an afterthought, adding in so called "Community spaces" and "Country parks" - some kind of 'fake natural landscape' to ease developers consciences. This does not undo the damage wreaked on the landscape and wildlife. If the Council really cares about preserving the local area and making "Warwick District a Great Place to Live, Work and Visit", it should protect and celebrate its beautiful local landscape, not turn it over to the highest bidder to bulldoze. In building such a large number of houses in one area, you would also effectively be getting rid of any incentive on the part of potential new residents to live here. No one wants to live in a massive estate where roads are congested and overcrowded and local towns full of pollution. People come here BECAUSE of the countryside and relative quiet. Warwickshire is known for its agriculture and landscape and has been throughout history. The Council is also overlooking the impact on Warwick's historic town centre, which is already becoming highly polluted and congested. Don't forget that tourism is a key part of the local industry, being close to Shakespeare Country (I work for the Shakespeare Birthplace Trust) and having the ever-popular Warwick Castle in its midst. We should be aiming to preserve the countryside and local villages as these are part of Warwickshire's 'image/ brand". Tourists do not come here to see thousands of modern houses and villages that have been swallowed up by the growth of the urban landscape. Think how popular the Cotswolds is, with its country lanes, open fields and well-defined villages. If this plan goes ahead, I suspect many visitors will just bypass Warwick and Leamington and make do with visiting other places to avoid the traffic - after all, there won't be much left to see with all of the open fields gone and Warwick town centre reduced to a traffic island.

It is really quite illogical to build such a large number of properties in an area which is never going to be able to provide enough jobs for this many people. Anyone living on such a new development would be compelled to commute by car, when it would make more sense to build new housing on brownfield sites near existing industry. In an era when there is an increasing desire for ecological homes, minimising car journeys, cutting energy use and protecting the environment, this seems like a retrograde step.

I would therefore urge Warwick District Council to reconsider and:
1. Reduce the planned housebuilding for the District to a more reasonable level and not build for the sake of it.
2. Spread the development widely within the district - a few hundred houses at most here and there.
3. Use brownfield land rather than agricultural land and land which is a haven for wildlife.
4. Consider more suitable sites for housing e.g. near workplaces/ cities.
5. Work to reduce traffic, congestion and pollution within the area, rather than increase it.
6. Celebrate and protect our historic and beautiful landscape and make it more appealing to visitors, residents and potential new residents.
7. Stay true to its professed vision and mission and listen to the opinions of EXISTING taxpayers (I for one would not like to stay here if this plan goes ahead).

Everyone can see that this proposed development is completely out of proportion with what is sensible and what is required. This is too many houses, in the wrong places, without thought for the consequences. It is not too late for the Council to do something about this and save our local area and stand up for local people.

I write to raise my strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.

This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.

Scale and proportion

* massive long term coalescence of settlements,
* loss of significant open space,
* loss of local countryside,
* loss of agricultural land,
* lead to significant urban sprawl.
* excessive bulk and scale,
* significant overdevelopment of the area

The effect of these potential developments on the existing local communities and infrastructure will be devastating, and I believe have been grossly underestimated by both Warwick DC and the developers.


Effect on local road traffic/infrastructure

The road infrastructure south of Warwick/Leamington and around Whitnash is already stretched.

* 2 or more cars per household,
* 9000 extra vehicles using the local road network.
* the local road infrastructure is inadequate. (e.g congestion on various local roads)
* traffic heading towards the town centres is already a major problem,
* gridlock, increased pollution etc.
* congestion on rural roads outside the town at peak times is also already a problem
* traffic noise,
* potential increased danger to pedestrians and children.



The National Planning Policy Framework, Policy DC7 states:
"Policy DC7 goes onto highlight that development will not be permitted where it generates significant road traffic movements, unless mitigation measures are used to avoid adverse impacts."

These developments will generate significant road traffic movements, and I do not believe that mitigation measures will alleviate the problem, certainly on a local level. If all the developments in the area are given the go ahead as part of the Local Plan, the situation will become untenable.

Effect of local services/amenities

The National Planning Policy Framework, Policy DP2 states:
"that development will not be permitted where it has an unacceptable adverse impact on the amenity of nearby uses and residents and/or does not provide acceptable standards of amenity for future users / occupiers of the development."

* pressure on local schools
* primary schools already oversubscribed year on year
* increased pressure on the local secondary schools
* effect on catchment areas
* effect on applications from siblings of children already in one school
* new schools not "guaranteed" to be built as part of the developments
* limited access to doctors and dentists surgeries in the Whitnash and Warwick Gates and Myton areas already
* effect on increased numbers on the local hospitals

Flood Risk

* already flood issues in Whitnash and Warwick Gates
* scale and density of proposed housing,
* large areas of paved/concreted or tarmac surface etc,

Alternatives to the Local Plan

There are many reasons why the Local Plan represents a disaster for the whole of the South Warwick/Leamington/Whitnash areas, predominantly because of the sheer concentration of most of the districts proposed new housing in one relatively small area.

Alternatives that should be considered include:

* Identifying existing housing that is derelict or currently unoccupied,
* Identifying empty industrial units with a view to use the land for brownfield site housing.
* Identifying an area in the surrounding countryside to use to build an entirely "new town".
* Spreading the numbers of new homes evenly around the district, with lots more much smaller developments.
* Smaller developments given to local builders rather than large national firms, thus helping the local economy.

Applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed.


Therefore, I hope you listen to the concerns and suggestions of the residents of your district, and act accordingly. This Local Plan cannot be allowed to come to fruition, and I hope Warwick DC come realize that, withdraw it, and refuse all the various planning applications relating to it, namely:

W/13/0858 - upto 100 homes at Fieldgate Lane/Golf Lane, Whitnash
W/13/0776 - 280 homes at Woodside Farm fields
W/13/0606 - 720 homes on Lower Heathcote Farm land, south of Harbury Lane
W/13/0603 - 370 homes on land west of Europa Way/South of Gallows Hill
W/13/0607 - 220 homes on Hawkes Farm fields
W/13/0036 - 200 homes on Grove Farm fields (application on hold)
W/13/0464 - large Retirement Community development on Gallagher Land near Heathcote

I hope Warwick DC would also refuse any new applications relating to the following:

Myton Garden Suburb - upto 1250 homes
Further development South of Gallows Hill - upto 260 homes
Former Severn Trent Sewage Works - 225 homes
Further development at Grove Farm - 375 homes
Whitnash East/South of Sydenham - 500 homes

Dear Sirs,

Re: Representation on Revised Development Strategy

Please find attached a representation from the Steering Group for the Lapworth Parish Plan on Warwick District Council's Revised Development Strategy published in June of this year.

These comments are taken from an analysis of responses from 350 Lapworth households to the Housing section of a detailed survey sent out in April this year. I apologise for not using the suggested response format, but this did not work well in the context of our comments. The full survey report will be available in August and will be sent to the District Council at that time.

Please note that the statistical information from the survey has not yet been independently verified, although it has been checked by members of the Steering Group. It is not expected that the final report will contain any material changes.

Contact details are provided in the representation. If you require any further information, please do not hesitate to let me know.

I write to raise my strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.

This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.

Scale and proportion

* massive long term coalescence of settlements,
* loss of significant open space,
* loss of local countryside,
* loss of agricultural land,
* lead to significant urban sprawl.
* excessive bulk and scale,
* significant overdevelopment of the area.

The effect of these potential developments on the existing local communities and infrastructure will be devastating, and I believe have been grossly underestimated by both Warwick DC and the developers.




Effect on local road traffic/infrastructure

The road infrastructure south of Warwick/Leamington and around Whitnash is already stretched.

* 2 or more cars per household,
* 9000 extra vehicles using the local road network.
* the local road infrastructure is inadequate. (e.g congestion on various local roads)
* traffic heading towards the town centres is already a major problem,
* gridlock, increased pollution etc.
* congestion on rural roads outside the town at peak times is also already a problem
* traffic noise,
* potential increased danger to pedestrians and children.

The National Planning Policy Framework, Policy DC7 states:
"Policy DC7 goes onto highlight that development will not be permitted where it generates significant road traffic movements, unless mitigation measures are used to avoid adverse impacts."

These developments will generate significant road traffic movements, and I do not believe that mitigation measures will alleviate the problem, certainly on a local level. If all the developments in the area are given the go ahead as part of the Local Plan, the situation will become untenable.

Effect of local services/amenities

The National Planning Policy Framework, Policy DP2 states:
"that development will not be permitted where it has an unacceptable adverse impact on the amenity of nearby uses and residents and/or does not provide acceptable standards of amenity for future users / occupiers of the development."

* pressure on local schools
* primary schools already oversubscribed year on year
* increased pressure on the local secondary schools
* effect on catchment areas
* effect on applications from siblings of children already in one school
* new schools not "guaranteed" to be built as part of the developments
* limited access to doctors and dentists surgeries in the Whitnash and Warwick Gates and Myton areas already
* effect on increased numbers on the local hospitals

Flood Risk

* already flood issues in Whitnash and Warwick Gates
* scale and density of proposed housing,
* large areas of paved/concreted or tarmac surface etc,

Alternatives to the Local Plan

There are many reasons why the Local Plan represents a disaster for the whole of the South Warwick/Leamington/Whitnash areas, predominantly because of the sheer concentration of most of the districts proposed new housing in one relatively small area.

Alternatives that should be considered include:

* Identifying existing housing that is derelict or currently unoccupied,
* Identifying empty industrial units with a view to use the land for brownfield site housing.
* Identifying an area in the surrounding countryside to use to build an entirely "new town".
* Spreading the numbers of new homes evenly around the district, with lots more much smaller developments.
* Smaller developments given to local builders rather than large national firms, thus helping the local economy.

Applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed.

Therefore, I hope you listen to the concerns and suggestions of the residents of your district, and act accordingly. This Local Plan cannot be allowed to come to fruition, and I hope Warwick DC come realize that, withdraw it, and refuse all the various planning applications relating to it, namely:

W/13/0776 - 280 homes at Woodside Farm fields
W/13/0606 - 720 homes on Lower Heathcote Farm land, south of Harbury Lane
W/13/0603 - 370 homes on land west of Europa Way/South of Gallows Hill
W/13/0607 - 220 homes on Hawkes Farm fields
W/13/0036 - 200 homes on Grove Farm fields (application on hold)
W/13/0464 - large Retirement Community development on Gallagher Land near Heathcote
W/13/0858 - upto 100 homes at Fieldgate Lane/Golf Lane, Whitnash

I hope Warwick DC would also refuse any new applications relating to the following:

Myton Garden Suburb - upto 1250 homes
Further development South of Gallows Hill - upto 260 homes
Former Severn Trent Sewage Works - 225 homes
Further development at Grove Farm - 375 homes
Whitnash East/South of Sydenham - 500 homes

This is an objection to the Local Plan on the grounds that the public's wishes as reported in the Final Report of Public Consultation (published December 2011) very much seem to have been disregarded in the Local Plan Revised Development Strategy (published June 2013).

Appendix 5 in the Final Report of Public Consultation (page 63) shows that:

a) 54% of the public respondents advocate LOW LEVELS of development or growth in our part of leafy Warwickshire with all farming land protected.

b) 31% say that NEITHER LOW LEVELS NOR HIGH LEVELS of development in our leafy Warwickshire are acceptable. Only a LIMITED LEVEL of development is acceptable.

c) Only 15% say that HIGH LEVELS of growth of services and facilities are required to support a growing population in our leafy part of Warwickshire.

The message behind these three percentages is partly concealed because the (incorrect?) percentages are separately presented on page 64. The wording seems to conceal the real meaning of the Scenario 3 which is that high levels of population growth will demand a proportionately high level of growth in services and facilities. So only 15% of respondents want a high population growth.

Why then does the Local Plan Revised Development Strategy expound on an intention to build 12,300 new homes? The consultation process shows that the public does not want it. Such a HIGH LEVEL of growth would result in a high level increase in road congestion and air pollution - a staggering 78% of respondents agree that this is an important issue.

I object to the Local Plan Revised Development Strategy because it does not seem to have been developed from public consultation. In Paragraph 1.2, WDC considers it important that the Local Plan revised development strategy will "deliver the Council's Vision for the District". The idea of consultation is generally recognized as a bringing together of visions from residents, voters, elected representatives and district councils alike. A declaration by WDC that it will deliver the Council's Vision for the district is not in keeping with what I understand to be consultation and I therefore object to the whole document.
End.

1.1 In its Local Plan Revised Development Strategy, May 2012, the Council [in para 2.2] invites comments on the proposals. Here are the comments of The Warwick Society.
While the Society's main concern is that a better Plan must and can be proposed, these comments are necessarily framed as objections, to make it clear that the present proposals are unacceptable to many residents of Warwick and its neighbourhood as well as to the Society.
Just as the Revised Development Strategy [its para 1.4] focusses on the main changes since the Preferred Options proposals, so this response is to be read alongside the Society's letter of 27 July 2012 commenting on the Preferred Options, of which a copy is annexed, pages 6-10.
1.2 The Warwick Society, the town's civic society, was founded in 1951. It 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. The history and the architectural character of Warwick, which make it one of the most distinctive towns of its size in Britain, were summarised in the Society's letter of 27 July 2012 .
1.3 The Plan and its Development Strategy give an opportunity to make the town and the district around it a finer place, and a better place to live in, to be educated in, to work in, and to visit. It is well-placed at the south-eastern corner of the West Midlands for sustainable development, prosperity and continuing attractiveness. The requirements for a Plan pursuing these ends were summarised in the Society's letter of 27 July 2012 . That letter continued :
The Preferred Options fail by a long way to achieve this. The Issues 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.
1.4 We greatly regret that, in the face not just of the Society's objections but also of strong criticism from the overwhelming majority of respondents to that consultation, the Council proposes an RDS which would do even greater damage to Warwick and its neighbourhood.
97.5% of respondents objected to development of the land south of Warwick. The Council's retort has been to increase substantially the number of houses proposed for that area, postulating that public opinion carries little weight in such decisions.
The arrogant disregard of the Council for the views of residents and other interested parties is itself cause for objection to the RDS.
1.5 The RDS has many accompanying documents. It is a further sign of the attitude of the Council to public involvement that all have been issued simultaneously, giving residents and other interested parties only six weeks during the summer holiday period to understand, discuss and respond to material which has taken well over a year for many council staff and consultants to produce.
As well as much more material in the 'evidence base', these accompanying documents include:
Sites for Gypsies and Travellers, raising concerns for residents adversely affected by the RDS by proposing a majority of the twenty potential locations for the three sites needed throughout the District in the same concentrated area close to Warwick;
The Community Infrastructure Levy Preliminary Draft Charging Schedule, which is not referred to on the Council's webpage notifying us of the consultation on the RDS and G&T sites but only on a later, subsidiary page;
The Final Interim SA Report, which disguises its purpose - Sustainability Appraisal - behind its acronymous title, is neither notified on the webpage outlining the two 'main' consultations, nor referred to at any point in the RDS which it purportedly supports; and
The Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3, which proposes the reversal of existing policies to reduce the impact of traffic in Warwick Town Centre but is not itself the subject of 'consultation'. The County Council unilaterally abolished the Town Centre Forum late in 2012 and has done nothing in the intervening eight months to implement the new but less effective process of discussion with which it proposed to replace it.
1.6 We explain hereafter as briefly as we can our main objections to the Revised Development Strategy. We do not comment on the Final Interim SA Report nor the Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3 or the other accompanying documents, but have many observations on their assumptions, analysis and conclusions which we will make separately.

2 Housing Need
2.1 The criticism of the methodology and the outcome of the housing need projections made in our objection to the Preferred Options , stands. The proposed figure of 12,300 new homes to be built is much too high. We note that it is a provisional figure, pending completion of the joint assessment being carried out with councils in Coventry, Rugby and Nuneaton & Bedworth. It must also be dependent on co-operation with Stratford District Council over its proposal for a new settlement at Gaydon, which might be superior to much of the proposed development south of Warwick in meeting housing needs for employment there.
2.2 You have yourself stated, at the Community Forum meeting held at Warwick Gates on 13 June, that half of those new houses would meet local needs and half would be for incomers . In our view, even less than half of 12,300, under 6,000, will be sufficient to meet local needs, and we refer to the analysis carried out and discussed with you by Ray Bullen for Bishop's Tachbrook Parish Council which supports our conclusion.
2.3 Forecasting as far into the future as 2029 is clearly very uncertain. By fixing now a single end figure, based on assumptions and trends and 'compound interest' - incurred by repeating small percentage differences over many years - the RDS projections can only have one certainty - that they will be wrong. Worse, by taking this single long-distant future figure and giving it short-term weight, in allocating greenfield land for development now, the damage of error will be immediate. This approach is akin to having no plan at all, allowing uncontrolled growth, leaving developers to decide what to build when, with our towns, villages and countryside blighted by the effects of false certainty and a National Planning Policy Framework which seeks development at all costs.
2.4 While the NPPF requires 'sustainable development' which meets an 'established housing need' to be approved , planning applications already made or imminent for much of the land south of Warwick meet neither of these criteria. A realistic forecast of housing need is that the District already has the required five-year +5% supply of sites. Using the exaggerated and uncertain RDS projections in support of short-term, expedient planning applications - which could over-ride the Plan process before it reaches Examination in Public - would open the Council to legal challenge.

3 Prudent use of Land and Natural Resources and
Protection of the Natural Environment and Landscape
3.1 The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint', designated at the time of the construction of the Warwick Technology Park, and intended to give permanent protection to this vital green gap. The Society has repeatedly suggested that it should be designated as Green Belt, but the Council has refused to implement this.
3.2 Building on it would merge the built-up areas, turning them into a single suburban sprawl. This would conflict directly with one of the principles of the Local Plan Strategy, 'avoiding coalescence' .The green space between the built-up areas to the south is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded as strongly.
3.3 Once developed, this green land could not be reclaimed. Its development would conflict with the basic principle of sustainability, 'meeting the needs of the present without compromising the ability of future generations to meet their own needs'

We use the term incomers as being less ugly than the technical term in-migrants, regretting that there seems to be no expression which is not pejoratively confused with the word immigrants; we refer to people moving into Warwick District from other areas, noting that encouraging the movement of better-off people from the West Midlands conurbation and Coventry may be one of the objectives of developers in Warwick District, and perhaps of the Plan.
Your word not ours; Revised Development Strategy, page 8, third point from bottom
Report of the World Commission on Environment and Development to the General Assembly of the United Nations, 11 December 1987
4 Sustainable Transport and Reducing the Need to Travel
4.1 Sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network. While the Local Transport Plan gives priority to sustainable means of transport in the hierarchy - walking, cycling, public transport - the Transport Strategy assumes that these developments would have the same ratio of peak hour car use to housing numbers as every other development of recent decades.
4.2 Development at relatively low density cannot effectively be served by public transport. The low concentration of the population does not provide sufficient volume for a bus service to run viably at a frequency which makes it an attractive competitor with car use. The limited influence which the County Council has over operators of unsubsidised commercial routes make it unlikely that a bus service would survive after the first few years of developer subsidy, as has been seen at other sites including the Hatton hospital redevelopment.
4.3 Whatever the fine words about walking and cycling routes within the suburban developments, these sustainable modes will not make a significant contribution to meeting transport needs. Distances will be too long for walking, for example from the areas south of Warwick to the town centres or railway stations; and cycling will be very unattractive as soon as cyclists reach the road network on which the use of cars has been intensified. The putative designs of new junctions in the Transport Strategy make it clear that the design priority would be to maximise the flow of vehicles, with people on foot and cyclists diverted to circuitous routes, with secondary priority at traffic light controlled crossings.
4.4 The Transport Strategy concludes that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. The infrastructure plan proposes spending almost all of the potential developers' funding contributions on intensifying the use of the existing road network. The schemes that it labels 'junction improvements' and 'mitigation' would be improvements only in maximising the flow of vehicles; and mitigation only in reducing the increase in congestion, while increasing not reducing the impact of traffic on town centre streets. They would both make sustainable modes less usable and damage the historic and natural environment with the intrusive impedimenta of the highway engineer.

5 Air Quality and Climate Change
5.1 The already illegally dangerous pollution in streets in centres of Warwick and Leamington would be made worse by the increase in traffic. Noise and vibration would be constant and business and residential amenity would be damaged.
5.2 No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, and in particular 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 air quality to be given absolute priority.
5.3 It has been suggested by the Council's Chief Executive that the air quality requirement could be met after development has been approved by then considering ways in which traffic through Warwick town centre could be reduced. This approach would invalidate the Transport Strategy, as the only way to reduce the volume of traffic would be transfer to other modes or other routes, neither of which has been assessed in the Strategy. A transport plan which meets all the objectives, including protecting the historic environment and assuring air quality, must be agreed before development is allocated.


6 The Historic Environment and the existing built environment
6.1 Warwick's historic environment is vital both to the social goals of the plan, to give people a sense of place and belonging, and to the economic goals as the basis of its visitor economy. It would be directly damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's.
6.2 Development on the land between Europa Way and the Banbury Road would extend sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would directly damage the Castle Park, Grade 1 registered landscape; and the 'junction improvements' on the Banbury Road would damage its rôle as part of the Castle Park planned landscape.
6.2 The historic environment would also be indirectly damaged by the effect on the economy of the town centre streets being primarily a conduit for through traffic, constantly full of fumes and noise, and with their commercial premises split from each other by queues of vehicles. The damage to the commercial success of the town would lead to a longer term indirect effect of reducing the demand for such premises, residential and commercial, and a fall in their maintenance funding. There is a real risk of the town centre hollowing out, in a miniature echo of the great American cities, becoming a poor quality zone in a car-based suburban sprawl.

7 Other Infrastructure
7.1 While in theory development would be conditional on it funding schools, and healthcare facilities, strong concerns remain that the funding and provision would be inadequate, and that there would be risks to water supply, sewage and drainage.

8 Alternatives to this Plan and Development Strategy
8.1 Lower housing numbers which meet local needs, especially for affordable housing, instead of encouraging in-migration; the gradual release of land for development as demand grows; giving absolute priority to using brownfield and infill sites; building homes close to jobs and not mainly within 20% of Warwick District ... many options exist but have not been given proper consideration in the preparation of the RDS.
8.2 Absolute priority should be given to brownfield sites, with greenfield sites only being allocated when there is a proven immediate need. This will ensure that more brownfield sites become available, their value increased by the non-availability of easy, profitable alternatives for the mass housebuilders.
8.3 While a year ago the IBM/Opus 40 site on the north-west edge of Warwick was to be used for office development, it is now likely to be proposed for housing. It provides a good example of the way in which long-term plans are by their nature crude, and that housing sites can be found on brownfield sites well-connected to the transport network.

9 Conclusion
9.1 In objecting on these strong and numerous grounds to the Revised Development Strategy, the Society offers its assistance to the Council in the necessary task of devising a better alternative, with the full involvement of a wide range of residents and business interests.
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.
1.5 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.
1.6 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.
1.7 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.
1.8 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.

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