RDS1: The Council is adopting an Interim Level of Growth of 12,300 homes between 2011 and 2029

The increase in housing numbers perceived as required in the district is too uncertain , the number has increased from 10800 to 12200 in the space of just 12 months. You should review these numbers again consulting with other areas around us. It is inconceivable that such a level of growth is required after the level of expansion in Warwick District that has already taken place in recent times. This level of housing will severely damage an attractive part of the countryside. People are drawn here because it is so nice , thats not enough reason to expand so much

The 12,300 estimate is not fit for purpose to be used for the remainder of the Revised Development Strategy and proposed individual settlement housing targets over such a long period:

1. Paragraph 4.1.1 shows that the Joint SHMA with neighbouring authorities is at the very start of its process. This will have a significant bearing on overall figures.

2. Justification for the interim level of housing growth is flimsy as it is based on interim projections, contains historic data and is prone to significant sensitivity swings. Would 2011 Census data not be more suitable when available?

The Council is adopting an Interim Level of Growth of 12,300 homes between 2011 and 2029.
The interim level of growth selected by the Council is much higher than is wanted by the residents of Warwick District. In the original consultation in 2011, 58% of the respondents were in favour of low growth. In the report on the Preferred Options consultation in 2012, 97% of the respondents objected to the level of growth. This level of growth is being forced on the District by external pressures and is not justified to support the needs of Warwick District.

I consider that the level of growth is unsubstainable if the qualities of the county is to be maintain for future generations. The District is not in need of regeneration its ecomomy is good and what is needed is controlled growth that will support it but to not imposed additional expansion; The numbers should be halved.

The interim level of growth selected by the Council is much higher than is wanted by the residents of Warwick District. In the original consultation in 2011 58% of the respondents were in favour of low growth. In the report on the Preferred Options consultation in 2012 97% objected to the level of growth. The requirement for additional accommodation is not driven by local need but by the government insisting that targets should be met. I hear that 'localism' is the aim - but see nothing that demonstrates it is occurring.

This number seems excessive. Other projections conclude that only half as many or even fewer are more appropriate. So many are bound to have adverse visual impact, in some places at least, and change the character of this area. The low rate of unemployment in the area implies that new housing for people filling new job vacancies is not needed.

For the reasons laid out below I do not believe the numbers suggested are appropriate.
* In 20 years to 2011 population growth was 18%. Now a further 20% increase is proposed in the RDS within only 15 years, with current forecasts for birth rate and immigration this figure seems erroneous. Using projections based only on natural growth of the population and an allowance for migation, only 5400 homes are required.
* Warwick DCs own consultants G.L.Hearn gave an Economic and Demographic Forecast Study in December 2012. In their option PROJ 5 arrived at only 4405 new homes required.
* If growing for new job is the reason, this is not required as Warwick District has low unemployment at only 1.7%. The 2012 Stategic Housing Market Assesment said that overall "Warwick District had a very good job-homes balance".

This level of growth is far higher than is required for local needs.
* Growth of local employment will be much less than this forecast.
* All this will do is put pressure on the local infrastructure especially the Road system.
* An integrated improved local transport policy has not been put forward.
* Current local business in industrial estates will suffer due to the increased volume of traffic.

Please see attached documents and plan.

Stagecoach Midlands has no comment to make.

I wish to object to the proposed building of 12300 homes in the Warwickshire area as I feel that the intended development particularly to the south of the town will permanently destroy prime agricultural land, blight a beautiful area of the County and increase road congestion and pollution in the area.
I have lived in the area all my life and feel strongly that whilst some new houses are required the figure of 12300 is far too many.
In the past 20 years to 2011 the population growth was 18% now the council are proposing a further 20% increase within the next 15 years. Why is this - as using projections based only on natural growth of the population and an allowance for migration only 5400 homes are required. This figure is from the Ray Bullen paper JUly 2012 updated using 2011 census data in 2013. The Council's own consultants Gl Hearn in their Economic and Demographic study in December 2012 gave in their option PROJECT 5 arrived at only 4405 new homes.
If growing for new jobs is the reason this is also not required as Warwick District has low unemployment at only 1.7%. and that the 2012 Strategic HOusing MArket Assesment said that overall ' Warwick DIstrict had a very good job-homes balance.'

I wish to object to the proposed local plan and in particular those developments projected to the South of the town. I feel that there are too many houses proposed and have detailed my fuller objections on this point in the relevant section.
In addition I feel that the large number of houses projected off Harbury Lane, Europa Way and on Woodside FArm should not be granted as this will create a large urban sprawl, destroy a beautiful part of the county and rolling countryside, build on prime agricultural land and also create a significant level of congestion in this area and town centres of both LEamington and Warwick.
In more detail my objections are as follows:
1. The local RDS plan does not contain any evidence to show that the proposed infrastructure improvements can be delivered from the Developer contributions through section 106 and Community Infrastructure Levy.
Even with new dual carriageways being created around Europa Way all of the traffic eventually ends up either on the Myton Road or Tachbrook Road which ultimately end up crossing over either the River or Canal where there is no no deliverable answer to the the problem of the increased traffic numbers or congestion. There is no suggestion or proposal to build new bridges.
The proposals are only for ugly large traffic lighted crossroads which only cater for vehicles and not for pedestrians.
This increase in vehicles and traffic congestion will also result in higher pollution levels and this wil impact on the Councils legal duty to actually Reduce fume pollution.
The increase in traffic will also detrimentally effect the town.'s economy if the roads are so congested and fume filled - ruining the very pleasant and attractive environment that people currently enjoy.

The consultation held earlier in the process resulted in a decision by those consulted to favour a low growth strategy. This has been ignored in the current proposals which I totally reject. The basis of the plan is a false set of numbers not supported by the existing local population. The existing population do not want to see the area ruined by development of green fields, the creation of intolerable congestion, a gross deterioration in air quality and the ruination of the southerly approaches to Warwick. A new plan is required based on a low growth strategy.

This proposal references an aging population but provides no detail on the proportion of housing to meet elderly needs which are very different to that young professional and families. I am aware of a number of developments planned to address some of these needs but it is not clear from this proposals as to what shortfalls exist. Any sensible and beleivable plan needs to be clear in this area

I wish to object to the local plan in the strongest possible terms

The projected housing need of 12,300 new homes to be built is much too high. Half this number will be sufficient to meet local needs. It is a complete nonsense to suggest that it is possible to forecast a housing need as far into the future as 2029. It is wrong to allocate greenfield land now based on this wildly inaccurate projection and once used the greenfield land cannot be recovered.
The National Planning Policy Framework requires the approval of sustainable development which meets an established housing need, but planning applications already made or imminent for much of the land meet neither of these criteria. A realistic forecast of housing need would mean that the District already has the required five-year supply of sites, enabling economic growth and matching the housing market.
The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint'. Building on it would merge our built-up areas, turning them into a single suburban sprawl. This green space is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded just as strongly.
Transport: sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to existing road network.

Air Quality: 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, business would be damaged
The historic environment would directly be damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, destroying the first impression of the spa town.
Other Infrastructure: I understand that development would be conditional on it funding schools, and healthcare facilities. As a regular user of the local hospital I know that it is already grossly overstretched and I am very concerned that the funding and provision would be inadequate. There would also be risks to water supply, sewage and drainage.
There are better alternatives. 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 .

I wish to object to the local plan on these grounds:
The projected housing need of 12,300 new homes to be built is much too high. Half this number will be sufficient to meet local needs. It is a complete nonsense to suggest to forecast a housing need as far into the future as 2029. It is wrong to allocate greenfield land now based on this wildly inaccurate projection. Once used the greenfield land cannot be recovered.
The National Planning Policy Framework requires the approval of sustainable development which meets an established housing need, but planning applications already made or imminent for much of the land meet neither of these criteria. A realistic forecast of housing need would mean that the District already has the required five-year supply of sites, enabling economic growth and matching the housing market.
The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint'. Building on it would merge our built-up areas, turning them into a single suburban sprawl. This green space is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded just as strongly.
Transport: sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to existing road network.
Air Quality: 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, business would be damaged
The historic environment would directly be damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, destroying the first impression of the spa town.
Other Infrastructure: I understand that development would be conditional on it funding schools, and healthcare facilities. I am concerned that the funding and provision would be inadequate. There would also be risks to water supply, sewage and drainage.
There are better alternatives. 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.

Unfortunately I was unable to attend the presentation of the Warwick Local District Plan on 15 July but I have had feedback on the meeting and am concerned that the Council are not actually listening to the residents of Warwick in respect of this plan. It sounds as if the meeting was less of a consultation and more of this is what we have decided will happen. I have serious concerns about the consultation process and the politics of the situation but will concentrate on issues that relate to the planning process. I have sent a copy of my concerns to The development Policy Manager at Warwick District council.

My particular concerns with regard to the plan are as follows:

HOUSING PROJECTION AND LOCATION

The projected housing need of 12,300 new homes to be built seems far too high for the area. While the National Planning Policy Framework requires the approval of 'sustainable development' which meets an established housing need, planning applications already made, or imminent, for much of the land meet neither of these criteria. A realistic forecast of need would mean that the District already had the required five-year supply of sites, balancing housing with employment growth and matching the housing market. I feel it is inappropriate to forecast so far into the future and to allocate greenfield land now. This will allow uncontrolled growth leaving developers to decide what to build and when.

Also, it has been reported that Stratford District Council have approved a "draft" strategy to build a new 4000 home "town" in the Lighthorne area just south of Warwick. If that goes ahead it would also have some effect on the infrastructure requirements, (as mentioned below), within the Warwick Local Plan; yet no mention is made of that scheme has been taken into account when preparing the Warwick Local Plan.

The land between Warwick, Whitnash and Bishop's Tachbrook is rural and agricultural and present policies respect this. Building on it would merge our built-up areas, making them a single suburban sprawl. The green land is as important as the Green Belt to the north of Leamington and Warwick and should be safeguarded.

I feel there are better ways of ensuring there is adequate housing to meet local needs, especially for houses which people can afford such as gradually releasing land for development as demand grows, giving priority to using brownfield and infill sites near schools, shops and railway stations, building homes close to jobs and co-operating with other local authorities, instead of competing with them for development.
ROAD INFRASTRUCTURE:
Much is made in the plan of the proposed improvements to road junctions, new traffic lights, etc. to enable traffic to move faster into Warwick & Leamington, but no solution is given to the problems caused when the cars reach the towns. Warwick has natural "bottlenecks" in The Butts, Jury St., High St., Smith St., Nicholas Church St. Friars St., Hampton St., and Theatre St. etc. etc. Contrary to transport policies, it would make walking and cycling less attractive, and would have serious implications for public transport. No solution to this is offered in the "Plan" and needs to be prior to any approval for new houses.

I feel the historic environment, which attracts so many people to Warwick, would be damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places, e.g. Bridge End in Warwick, Castle Bridge, Castle Hill and St John's.

AIR POLLUTION
Pollution from vehicle exhausts in many streets in Warwick and some in Leamington is already worse than is legally permitted. The District Council is required to improve air quality, but the plan and its transport strategy would worsen it. Noise and vibration would also be constant, businesses and tourism would be damaged and the long-term health of residents of these streets would be even more threatened. The revised plan does not address these problems.

HEALTH
Apart from the additional health problems that can be caused by any increased traffic congestion there is no mention of the capacity of Warwick Hospital to cope with a massive increase in population. The present hospital is surrounded by housing and cannot expand, can it cope with such an increase as is projected by the "Plan"?

SITES FOR GYPSIES & TRAVELLERS
The need for such sites is recognised and the concept supported. However, even a casual glance at the Plan shows a marked imbalance of the distribution of the possible sites over the whole of the District. Of the 20 possible sites listed only four are in the northern part of the District with the remaining 16 in the southern part, with the biggest cluster just south of Warwick. This should be re-examined to ensure a more equitable spread of the burden on the residents of the District. Again, it seems so much protection is given to the green Belt and so little to our other green land.
CLOSING OBSERVATIONS
The above points are general rather that specific but clearly indicate a need for a more "in-depth" approach to what the District as a whole needs. From the information provided the people who have drawn up the Plan do not seem to have considered all the facts nor how to overcome, or at least alleviate, the problems that will be created by placing the bulk of the predicted new dwellings into one main location. To gain the support and the trust of the residents of Warwick District more openness and consultation than in the past is now required. In addition, serious consideration should be given to giving equal protection to open land to the south of Warwick and Leamington as that given to the "green belt" area located to the north of the towns so that all the open "greenfield" sites can be considered equally and the load spread more equitably.

As one of our elected representatives, I do hope that you will do all that you can to ensure that these concerns are addressed.

I am writing to you all to register my strong objection to the Warwick District Council New Local Plan.

I appreciate there will be a need for a certain amount of new housing over the coming years but believe that this plan it enormously biased and unfair. The scale of proposed building sites encircling us is unbelievable.

Almost all of the proposed sites are 'South of the River' with barely anything in North Leamington or elsewhere. Why is this? Is it felt that the south is not as rich and therefore the people are not as important? Is it believed that the residents in these areas don't need green spaces and views, areas to 'breath'? Is it felt that the children living here shouldn't have the option of attending a single form intake school? Or do you believe that we just don't care what you do to our home towns?

I live in Whitnash, and I love Whitnash. I have an active role in community life and I am raising my two children to love and respect their town. I have many concerns with your poposal.

Firstly the HUGE loss of green fields, the trees, wildlife, the views, the areas to walk to with the kids and just stand and be peaceful and look at the view. This is enormously important to people, their wellbeing and their health. Too many people and not enough space leads to a reduced quality of life. And the damage to our local wildlife should also be of great concern to you all.

Please can you tell me why planning permission was granted to have THREE new supermarkets built within spitting distance from a huge Sainsburys? We do not need this much choice for our weekly shop! Why were these areas of Brownfield land not used for housing? And why isn't a greater effort being made to bring back into use the many derelict homes in warwickshire?

I am also very concerned that this amount of housing would bring THOUSANDS of new families and children to our area. Where will they go to school? After Warwick Gates was built, Briar Hill school became a three form intake. I DO NOT want my children to be one of 90 four year olds starting school. I want the option of a single form intake as it currently is at Whitnash Primary. Please can you tell me what plans there are to cope with this or if our local schools will be forced to increase in size? And what will our secondary schools do? Do you plan to cram more kids into there too?

The volume of traffic is lightly to increase to a level that makes travelling in the area unbearable. No matter what new road traffic management systems you come up with, you cannot make a potential 22, 000 cars disappear. What will life be like? Ages spent on the road just to 'pop' into Warwick and misery brought to all those who commute to the area. The area leading from the M40 up to Europa Way is already a nightmare. Will this make the area attractive to workers and employers? Let alone residents.

Pressure on our ONE busy hospital, doctor's surgeries, children's nurseries, potential flooding, loss of agricultural land and the misery, sadness and anger brought to so many Warwickshire residents. Just a few more of my concerns.

Please do not destroy the very things that make living here so great. I, like so many others, love this area very much and am proud to live here. If you allow these developments to go ahead I believe that there will be a great number of voters that will never forgive you. I hope that you have the intelligence, decency and humility to go back to the drawing board and come up with a new 'Plan'.

Having looked at the Local Plan and attended recent public meetings I am writing to you to indicate my many concerns and total dissatisfaction with the revised development strategy for the Local Plan.

Air Quality

In particular, the air quality issue is of great concern. I understand that air quality in Warwick and Leamington is already above the legal limit. The District Council is required to improve air quality. The scale of planned houses will make it worse. I also note that Stratford Council have their own plans for even more houses south of Warwick, has this development been taken into consideration?

Transport

I believe the strategy is car based and will push even more congestion onto the existing road network. It is obvious that building a dual carriageway to the river Avon bridge will just bring increased traffic to a halt. Also the current bridge was not built to take the potential amount of traffic. Parking in Warwick is already difficult enough, this plan will make matters far worse. As for traffic at the Morrison roundabout on the Myton Road, I shudder to think of the implications on the bridge overlooking the most beautiful view of the castle in Warwick.

Projected Housing

The projected 12,300 homes are extremely high and I understand that less than half that number would meet local needs. also, there are a large number of empty houses in Warwick and Leamington, could these be used to house people instead of just building more new ones?

Could we not build on brownfield and infill sites already within each towns infrastructure.

Should there not be a slower phasing in of housing based on estimated local demand releasing land as demand grows rather than an optimistic estimate so far into the future?

Historic Environment

There is no doubt that the plans will ruin the visual look of Warwick forever. The increase of traffic and people will drive visitors away. We need to conserve the beauty of Warwick not plan to destroy it.

Funding

With the current and projected Government cutbacks, will Warwick District Council have the funding to expand the needed infrastructure to support 12,300 homes?

National Planning Policy

From the meetings I attended it appears that a realistic forecast of need would mean that we already have the required five year supply of sites when you balance housing with employment growth forecasts vs the housing market. Why has this not been taken into consideration in the local plan?

Gypsy Sites

They seem to have all been crammed into the same area. Could they not have been spread out more fairly within the area?


I would be most grateful if you would note my constructive dissatisfaction which is based on my fear that our beautiful town of Warwick will be destroyed in the future.

I have now attended 2 public meetings regarding your proposals and would like to formally record my objection to this plan which in my opinion is ill thought out, incompetent and not in the interests of anyone other than developers.
Where do I start..........
Well firstly the number of homes planned bear no resemblance to what is actually required in the area. Based upon census data from 2001 and 2011 homes for local needs are estimated at 5,400, not the 12,000+ which is the total number proposed the the Revised Development Strategy, with the majority earmarked for the South Warwick area. It came to my attention yesterday that Stratford District Council are also planning circa 4000 homes in and around Gaydon (with 1900 at Lighthorne) to cater for the expansion of the Jaguar/LandRover/Aston Martin facility. It would appear to me that both councils are vying for the same customer for the homes and in reality the volumes planned by Stratford can be removed from the South Warwick plan for this reason (as Gaydon falls under Stratfords juristriction). As these councils share a common border common sense would ensure that there is formal communication between the two parties to ensure a sensible plan for the area as a whole and I believe no discussions have taken place. This should be addressed before any plans are passed. The council will counter agrue that the difference is required to cope with the projected upturn in the economic climate, but the reality is that the land earmarked for employment will cater for circa 2000 jobs. The most recent development at Morrisons has land adjacent earmarked for employment in a very prominent position but this is now being proposed for Retail as business is not interested. So in reality there are too many homes planned with not enough employment opportunities for the prople who may live in these homes - the plan is not sustainable or balanced and is clearly a charter for developers to 'make hay'. This cannot be allowed to happen and must be stopped.
There are also 6305 homes in the district that lie empty. Why are these not being utilised? In the last 5 years a grand total of 251 homes have been taken back into supply. I would suggest that the council should focus more effort into utilising what is already available rather than build more than is necessary
If you look at more recent developments that have been built - Warwick Gates and Chase Meadow, both these developments have proved unsustainable - what evidence is there in place to prove anything will change in this plan. a recent survey has posted that 76% of traffic passing through Warwick is transient and Warwick is a Conservation Area. How will this plan affect the conservation area? The answer is no one knows as this plan does not cover this point.
My main issue with this plan relates to Air Quality and Traffic Congestion which go hand in hand.
Air pollution today is above the legal limits - this will get much worse if this plan is adopted and nothing appears to be happening to resolve todays situation let alone if thousands of cars flood the area if this plan is implemented. As an Asthma sufferer I know only too well how intolerable air pollution is. We are also lucky to have many schools in the Warwick area (Warwick School, Kings High, Myton, Campion etc) with an abundance of playing fields for the children to enjoy sport. Damage to their long term health is already being done with the poor air quality in the area - all we hear from the Council is how they are going to mitigate any further damage but not what they are going to do to sort it.
Anyone who is a local to this area knows that the roads into Warwick and Leamington from the south are unpassable in peak times and that the Myton Road is the same. The council have a poor track record with Traffic flow - look at the debacle on the roundabout outside Morrisons. In the mornings getting off the Myton Road to turn right onto Europa Way is untenable, the traffic lights make the situation much worse (not better). The other way past Myton School and Warwick School are no better, and they want to put another 3500 homes south of Warwick with no option other than car useage (with an estimated 7000 additional cars) to go about their daily events. I said earlier that 76% of traffic through Warwick is transient, this will increase with these plans and the poor old bridge over the Avon will not cope.
Loss of green space and arable farming land - the green land around South Warwick is environmentally sensitive. It would appear that this argument has been dismissed, wrongly in my opinion
Infrastructure has also been overlooked.
Warwick Hospital - can it cope. Discussions have taken place but nobody has said that it can
There are not enough school places for the influx of young people even with the build of additional primary schools
There is no provision in the plan for young people - whare are they going to go, what are they going to do, whatever it is will involve a car journey on gridlocked streets.
Warwick is a beautiful tourist destination with wonderful history and attractions that people travel the country to see. Creating a mass urban sprawl where people are unable to make their way around will be the death of Warwick as an historical attraction and harm local business in the long term.

In closing, the Town Council is objecting to this plan. When the current Prime Minister came into office he pledged that local people would be responsible for local decisions. Its clear from the public meetings that local people do not want this plan to go ahead. Unfortunately our District Council only has two councillors in its executive affected by this plan so politically are not able to make local opinion count.
Everyone accepts there is a need for more housing to cope with local needs, but this plan is not the answer.
One solution would be to make all the brownfield land proposed for development into Green Belt. This can be done and is not illegal (to my knowledge). Making this happen would allow proper consideration of how to allocate development land with due regard to exceptional circumstances required to build on it, and therefore a plan with substinance could be developed

I move for this plan to be rejected in its entirity

I am writing to you to strongly object to the new local plan and I have detailed a number of points below
.
Housing.
Why are the numbers so high? Using projections based on natural growth of the population and an allowance for migration only 5400 homes are required. WDC consultants gave a forecast study in Dec 2012, in their own opinion at only 4405 new homes required. If growing for new jobs is the reason this is not required as Warwick district has low unemployment at only 1.7 percent. The 2012 strategic housing market assessment said that overall Warwick district had a very good jobs home balance.
A major issue is also why nearly 70 percent are being planned to be being built within the same area around Warwick gates and bishops tachbrook.
This will mean that their will be a huge urban sprawl of whitnash, Warwick and bishops tachbrook.
The planning inspector who reviewed the current local plan in 2006 stated that woodside farm should not be built on now or in the future. This still stands and therefore should definitely not be agreed to.
WDCs landscape consultant Richard Morrish in the landscape area statement in 2009 referred to this area at Gallows hill that this study area should not be considered for urban extension, so why is this being ignored. The beautiful rolling countryside will be destroyed.

The local infrastructure cannot possibly cope with this amount of housing. The roads will guide to a halt, already the Warwick roads cannot cope at peak times. The Warwick strategic transport phase 3 assessment show traffic speeds of only 0-10 miles per hour at large parts of Warwick.

Warwick hospital is already at capacity and cannot possibly take more people using its facilities.

The school system in the local area is already bursting at the seems, priority areas are over subscribed. Particularly a problem is Warwick gates where I am a resident. WDC failed to provide a school for over a thousand homes and this has constantly caused problems within the school system, having a knock on effect to all local schools and families. I am currently having the worrying task of finding a school place for my daughter and know of many people disappointed this year who have not managed to get there child into any of their 6 choices even with being a mile or so down the road from the school. If all these houses are going to be built as well as the gypsy sites, will the schools be in place before the houses are built, or are the current residents going to be forgotten and pushed out of priority areas with new people moving into the area. The schools MUST MUST MUST be built before the houses are occupied to stop any further issues. You cannot allow another mistake like Warwick gates to happen.

A major concern is why before the local plan is agreed are the WDC looking at accepting other applications like wood farm and harbury gardens. These should not be accepted until the local plan is accepted after correct public consultation. WDC should stand up to national government during the appeal process if necessary.

I cannot more strongly object to this local plan and the applications that are trying to sneak in the back door. WDC must take more time to consider the plan and reduce the amount of housing and distribute it evenly over the district and not just penalise our area.
The back door applications must be refused until this process is considered together.

From reading the Revised Development Strategy leaflet and attending The Guy Nelson Hall, Warwick School on Monday 22nd July, I was made aware of the full extent of this plan and the negative impact it would bring to Warwick and Leamington Spa.

I live in Warwick, on Camel Close, off the Myton Road and have lived in Leamington & Warwick over the last 20 years and consider this the most beautiful region in the Midlands.

During my time here, I have seen many changes in the region and with some of the recent developments around the new Morrison's and ALDI stores, I can see that the nature of the surrounding town areas are becoming overly congested and normal day to day commuting becoming more arduous.

When looking at the website for Warwick District Council, I have read the comments from Les Caborn and struggle to understand the points being made, as there is several areas of contradiction:
"Councillor Les Caborn, the lead councillor for the Local Plan said "I believe these proposals set out an approach which will enable the district to continue to grow and thrive, at the same time as protecting and enhancing many of the things that make Warwick district a great place"
Interesting... By exponentially expanding the requirements for new homes, the infrastructure required to support this and socio-economic factors it brings will not protect or enhance our region. On the contrary, it can only been seen that these changes will threat the things that make this a great place to live.

He also says:
"I'm really pleased to be putting forward proposals that provide for some real improvements in housing needs, a new country park, opportunities for employment, as well as transport schemes, schools and community facilities. I look forward to hearing what people think of these proposals."
But what about improving the stock of potential homes we already have available? Would this not remove the issues of additional transport schemes required (which would only worsen the situation), burden on schools, hospitals etc?

When looking at the proposed plans, I have major concerns and therefore need to make an official objection on many levels upon why these plans should be rejected.

1. New Homes and Projected Volumes?
District Council proposal for more than 12,000 new homes to be built by 2030?
This is a staggering amount of new homes to be built. A detailed explanation is required to understand how this calculation has been made?
When looking at the overall census from 2001 - 2011, there has been a steady increase in numbers over that period. When projecting this into 2030, an expansion of 12,000 new homes is an exponential growth. How can this be? With the increase of jobs in the automotive sector, this still does not cater for this growth.
Therefore, it is requested that the calculation of new homes is made available to be verified and cross checked with other external bodies.
See section 158 - NPPF: "Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

2. Empty homes currently within Leamington & Warwick and existing brown field sites
Has the existing stock of empty homes and properties available for renovation within the Leamington & Warwick been considered? Would it not make sense to address the issues in the town to rebuild and improve these properties, which are currently abandoned and derelict? Would it not be advisable on a planning perspective to make good these properties and bring them back into a good condition and build up and improve existing areas given the infrastructure we currently have? Is this not more sustainable?
(See point 17 of the NPPF: "encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high
environmental value"
See point 51- NPPF: "Local planning authorities should identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and, where appropriate, acquire properties under compulsory purchase powers. They should normally approve planning applications for change to residential use and any associated development from commercial buildings (currently in the B use classes) where there is an identified need for
additional housing in that area, provided that there are not strong economic reasons why such development would be inappropriate " - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf


3. Empty Office buildings.
In addition to empty residential homes, is it possible to convert existing business / office buildings into a residential properties. Looking around Leamington and Warwick, there are many areas identified that have been unoccupied for several years. Given the economic climate, it is likely that these properties will remain empty and potentially fall derelict.

As per point (2) and (3), it would only be in the council's favour to allow these properties to be converted into homes, such that they can start gaining revenues for council tax!

In addition to this, I see that additional offices are also being suggested within the plan.. Why are the planners doing this? If we can't fill the existing office spaces around Leamington & Warwick, why are we building new offices?
If there is new offices being built, exactly how many people would it support, if all units were occupied..? Would it cover the additional people moving into the area?
Given the current economic state, it is likely for more offices to remain empty. Given this, if the economy took a further downward spiral in the next 10 years, it is likely that the ratio of unemployed to working people would also rise. How does that help the district to grow and thrive?
See point 51- NPPF: - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

4) Green spaces in Warwickshire
One of the many positive aspects of living in this area is the consideration given to green spaces, that makes this region so special.
When looking at the plans of south Warwick, a large area of green fields could potentially be lost due to the unnecessary expansion between Warwick and Leamington.
In addition to this, it is important to consider proper planning and restraint when converting green field sites to urban sprawl. The conservation of wildlife is becoming even more important, but no references has been made to this within the plans for the protection thereof.
Yes, yes.. I see that there is plans for a country park in Whitnash and Sydenham, but lets not forget, this area is already a green field site. How does overstating this on the plan actually improve the wildlife conservation in South Warwick?

In addition to this, one of the biggest assets in our region is Warwick Castle. Why is it that this is the biggest area of expansion.. This can only be described as wilfully irresponsible, which will ruin one of the things that really makes this a great place.
See section 12. Conserving and enhancing the historic environment of NPPF.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

5) Transport
Currently, the road networks around Leamington and Warwick are barely adequate to deal with traffic today. Most homes will typically contain at least 1 if not 2 cars.
If we draw an average of 1.5 cars per household, that will be an addition 18,000 cars on the road. If only half of vehicles travel through Leamington / Warwick during peak times, that will be 9,000 cars...
Expanding the region to deal with this extra volume will only create havoc during peak periods.
The plans show several 'Grade 1 Junction' improvements. However, the network is fundamentally flawed as there are key bottleneck's. All roads tend to lead through the centre of Warwick or Leamington.
Warwick is not able to further increase the flow of traffic due to the smaller streets. Leamington has several rivers and bridges. Access over these bridges are limited.
Therefore, making better junctions will not improve the situation when adding additional cars on the road.
How can this make our region grow and thrive? What will it do to our open spaces? How would this affect the current lifestyle that we enjoy today? How can our roads be safer with more cars on the road?
Have the planners considered this when building the plan? If so, what is their response to traffic management, other than making roads bigger / wider? (which we suggested does not solve the root cause).
With these issues of traffic build-up within the town, it can be seen that issues along the A46 and M40 will also arise during peak periods, adding to the problem.
See a link to an interesting article published by the Project Manager for Transport and Safety in York.
(http://democracy.york.gov.uk/mgConvert2PDF.aspx?ID=12475)

6) Air Quality
Given the traffic buildup at peak times, the schools and homes based along these main roads, it will be apparent that air quality will be affected. According to tests currently being undertaken, the air quality in certain parts of Warwick are not acceptable and increasing traffic flow by 9,000 - 18,000 cars.
What is the planners response to this? Again, is this responsible planning?
In addition to this, new research proves that air quality is linked to the higher risk of lung cancer and heart failure.
See the following link:
(http://www.guardian.co.uk/society/2013/jul/10/air-pollution-lung-cancer-heart-failure)

See point 124 - NPPF : "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf


7) Infrastructure - Schools - Hospitals - Water - Drainage
With the added demand placed upon schools, expansion of existing schools is required plus additional new schools to be built. What does this mean to the overall quality of the existing schools today? Are they able to adequately expand to meet this demand? Will they be over subscribed per classroom, such that the quality of education in these schools drop?
I have 3 children in Primary and Secondary education and this is a very important concern that I have. Taking additional demand in existing schools as well as building a new school will incur a huge investment, of which children's education could be compromised. How does the planned respond to this? What assurances can they provide, not only for children in the area, but also children who wish to move into the area?

Added demand to Warwick Hospital. This is a site which is set within a residential area. Is it possible to expand this hospital to cater for any additional 40,000 - 50,000 people? What is the planners response to dealing with this additional demand. Are there enough beds within specialist wards within the hospital to cater for this growth? (As point 6 reveals, with the added pollution in the area, additional demands may be placed on hospital services).

Water and Drainage is already something of an issue, as works have been carried out within the town to repair this. How would the additional infrastructure cope with this increase in capacity?
Also, would the building of these new homes be placed on any land prone to flooding? Is this something that should be avoided?

See point 162. - NPPF : " Local planning authorities should work with other authorities and providers to:
●● assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands; and
●● take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

8) Alternative plans?
Given that the expected number of homes appears to be excessive and not clearly explained within the notes, the majority of these new sites are south of the region.. Why? Has it been explored if some capacity could be shared in the north of the region?
The protection of green belt land has been discussed for the North, but this is something that I believe should be explored further. Is it not already possible for the local authority to change the use of this green belt for the north? Why has this not been explored? Why is the focus of all the development concentrated on the south?

Has the planning office consulted with planners in other regions surrounding Leamington and Warwick?
What other plans have been submitted in Stratford or Kenilworth districts? Are there other developments already going ahead that the planners in Leamington and Warwick don't already know about? Is there some planning duplication being made upon the number of houses being built?


As mentioned before, I am opposed to these plans and have described over 8 separate and individual objections.

I would welcome a response to the issues raised and a chance to meet and discuss further.

I object to the Local Plan - Revised Development Strategy & wish this to be recorded formally & my further comments passed to the ultimate decision making authority

In summary,I believe the proposal is not sustainable on environmental, economic and social grounds

1. Housing needs - the assumption of business growth & housing needs are unrealistic given that there are already over 5,000 empty homes in Warwickshire, 5 business units on Smith Street in Warwick unlet, land next to Morrisons supermarket unsaleable to business & many business units in both Leamington & Warwick that have become unlet or charity shops because businesses are not viable, given the economic conditions. Furthermore, there are already a number of residential developments that have recently been built or started within close proximity of the proposed developments & they are still not sold or occupied. With the proposal for housing to be built near Lighthorne Heath, any possible increase in jobs for Jaguar Land Rover is already covered. As a result, the likelihood is that the number of commuters would increase as a result of more houses South of Warwick - putting more pressure on roads in & around both Warwick & Leamington train stations which is already high at peak times.

2. Car parking - there is already a shortage of adequate car parking space in & around Warwick. Despite the building of the Warwick Technology Park & the plan for adequate car parking spaces, currently over 40 cars are parking on the verge of Gallows Hill. Increasing numbers of cars because of extra housing will result in an even bigger car parking problem unless attractive alternative means of transport are provided. The current provision of a cycle path on both Myton Road & the Banbury Roads are not fit for purpose as they are not continuous & likely to lead to more accidents.

3. Environment - one of the main generators of income to the local economy is the success of Warwick castle. The views from Warwick castle would be significantly disturbed if the Local Plan were to be approved. The proposal to build houses on the land South of Warwick on Gallows Hill off Banbury Road would mean the green views from Warwick Castle would be destroyed - any proposal needs to be environmentally sensitive.

4. Gas emissions - the air quality is already over the guidelines in both Smith Street & Jury Street, Warwick. The Local Plan would result in a significant increase in car journeys & traffic congestion in & around Warwick (particularly on St Nicholas Street, Mill Street, Banbury Road, Myton Road & Bridge End) - what action is being taken to ensure the resolution of known & forecast air quality problems ? The significant detrimental effects on health & buildings as a result of the increase in gas emissions is unsustainable.

5. Traffic mitigation schemes - the proposed mitigation schemes will only result in complete chaos given that the Avon bridge can only have 2 lanes & so this will result in a bottleneck, particularly at peak periods & when there is a major incident such as a crash on the M40, roadworks, need for Emergency vehicles to pass. The accuracy of the the assumptions used to predict traffic flows need to be checked.

6. Safety of pedestrians (particularly the young, old & disabled) & cyclists are not properly considered in the revised local plan when taking into account their needs to cross roads & access shops, services such as doctors, schools & businesses. This applies particularly to Myton Road, Banbury Road, St Nicholas & Smith Streets - especially, given the significant number of residents & visitors & road users requiring access to Warwick Castle, St Nicholas Park, Warwick School, Myton School & Coten End School.

7. The importance of the Conservation Area south of Warwick, including Bridge End. What special measures are being taken to mitigate the impact of traffic & consequence noise & pollution on the conservation area in the light of its architectural, historic, tourist & environmental importance.

8. Infrastructure - the pressure on local services such as the hospital, education, social services & education is too great. They are already suffering. Furthermore, the drainage systems of South Warwick near & around the river already appear to be inadequate for current users.

Overall, the main practical problem seems to be the likely bottleneck of traffic on the bridge over the River Avon on the Banbury Road, Warwick. What is needed is a plan in which traffic is actively managed away from the bridge on Banbury Road - why is this not included in the revised plan when it is clearly needed ? and all traffic needs to be diverted away from the centre of Warwick. A super highway bypass is needed which would enable the plan to be sustainable & a major re- think of if & where new houses are really needed then perhaps land closer to Coventry or even North of Leamington would be a better balanced fit for a plan to be more sustainable on environmental, economic & social grounds.

Please will you acknowledge safe receipt of these comments & confirm they will be passed on to the appropriate decision making authority.

My first concern is why the need for all the new build in the area.
I suspect it is NOT for our future generations but for the EU allowing any tom - dick or harry into the UK.
This situation will obviously get worse with the New Year intake from Romania and Bulgaria.
Why has any build been diverted from the North side of town? Is that where money talks?
The influx of Eastern Europeans has already down graded the area I live in. Worked hard, bought a house, improved it, street now 'buy to let'.
We have paid into the system all our lives and seen all the hard work of generating a property to the value of £200,000 plus drop to 170,000 due to the buy to let factor.
Who do we claim compensation from due to EU regs allowing what is happening to the UK.
Mr Cameron & Co do not have to live with all this type of change to their community, but they allow it.
I think I speak my concerns on behalf of more people than you realise.

No credible evidence has been given for the need of 12,300 new houses.

A new sprawl of housing estates over green fields will encourage more car dependency in an already congested area as well as using up good agricultural land.

The suggested plans to 'cope with the vastly increased traffic will increase the already illegal atmospheric pollution to even more dangerous levels, quite apart from making the centre of Warwick unbearable for residents and visitors and creating multilane traffic light controlled road junctions.

There is need for affordable housing, but not in the numbers suggested and not in vast soulless estates to suit developers. A lot could be accommodated with in-fills and brown field locations much nearer shops and schools and other amenities. This would also give a chance to local builders who unlike big developers do not need vast greenfield sites.

I am a resident of Bishops Tachbrook, where I live with my husband and 2 children (aged 4 & 6). We have lived in the village for 8 years and chose the location because we wanted to raise our family in a village setting, away from the town centre.

I have read the WDC Revised Development Strategy (2013) and I have attended a public meeting, where I viewed the WDC RDS PowerPoint presentation. What follows is my considered response to the proposed housing developments and Gypsy Traveller sites.

The RDS completely contradicts WDC's strategic vision "to make Warwick District a great place to live, work and visit" (RDS 3.1).
An increase of 12300 homes will not achieve this vision and will, in fact, have the opposite effect for a number of reasons:
The actual number of homes required to meet the projected population growth in the district is 5400. This is based on factual information derived from the national census statistics, and allows for migration. Where is the evidence to support WDC's claim that 12300 homes are required?
The WDC presentation states that; in order to provide for growth of the local population (RDS 3.5), sites for 550 new homes per annum would need to be identified. Over an 18 year period this totals 9900 homes. Where does this number fit in with the 12300 WDC claim are needed to meet growth?

Why has the WDC empty home strategy not been included in the 5 year plan? WDC has redeveloped 250 homes back to use under this strategy and further homes have been identified. In 2012 www.emptyhomes.com identified approximately 1350 empty homes in the Warwick district. Why isn't more work being done around this type of development of existing homes, rather than proposing large scale new developments. There does not appear to be any mention of empty homes in the RDS.

Warwick District currently has a very low unemployment rate, with only 1.6% of the population claiming JSA. If some of the proposed development is about economic growth where is the evidence to show that people moving into the area will be able to find work?
Much of the employment land in the district has not been fulfilled and may subsequently become land for housing, but where are the jobs for the people moving into the area?
I have heard the growth of Jaguar Land Rover cited as an employment opportunity, which would require homes for employees moving to the area. However, the WDC's RDS does not take account of the fact that Stratford District Council are in the process of consulting on a proposed development of 4800 homes in the Gaydon and Lighthorne area. This would be closer to the JLR than any of the Warwick District developments in terms of homes for JLR employees.
Why have WDC and SDC not communicated about their development plans when they are so close? As a Bishops Tachbrook residents we will also be affected by the SDC plans, as any commuters and/or visitors to Warwick and Leamington from the new developments will increase the traffic and associated problems, noise/ air pollination etc.

The visual impact on the view from Bishops Tachbrook, Harbury Lane, Tachbrook Valley, Gallows Hill will be hugely significant for existing residents but also visitors to the area. No amount of 'country park' can make up for the loss of beautiful countryside and open fields, which would be lost to thousands of homes and the associated environmental impacts such as noise and light (from houses, cars and street lighting). The planning inspector who reviewed the current plan in 2006 said that Woodside Farm should not be built on then or in the future. The WDC's own landscape consultant, Richard Morrish, said in the Landscape Area Statement (2009) referring to the land south of Gallows Hill " this study area should not be considered for urban extension and the rural character should be safeguarded from development". The RDS goes against this recommendation, why?


The local infrastructure cannot support such a significant number of houses in one area. The Southern Site already has significant issues in terms of volume and flow of traffic. The RDS does not contain any evidence to show that the proposed infrastructure improvements would alleviate any of the problems that would come with such a large development. No number of dual carriage ways will improve the flow of traffic through the 'pinch points' such as crossings of canals, rivers and railways and the RDS does not provide any realistically deliverable solutions to these problems. Appendix E of the Warwick Strategic Transport Phase 3 Assessment shows traffic speeds of only 0-10 mph in large parts of Warwick. Any increase in traffic, never mind the exceptionally large numbers proposed in the RDS, will make this situation worse. Rather than increasing trade in the town centre it is likely that people would be put off visiting the shops because of the volume of traffic. This view was supported by the Chairperson of the Warwick Chamber of Trade, who echoed this point at the public meeting I attended.

A lot can be learnt from previous developments in terms of the volume of traffics. The Warwick Gates and Chase Meadow developments prove that the people who move onto these developments will use their cars to commute to/from work and to/from shops and town centres. The bus services serving these developments are not self funding and rely on subsidies to run. It would be naive and idealistic to think that this would be any different on new developments. Most houses have more than one car and most people will drive to work. The location of the Southern Site development would require most residents to commute to work.
A lot can also be learnt about sites identified on development plans for facilities such as schools and play areas, which are not followed through. The Warwick Gates plans contained a site for a school, which was never built. This subsequently put huge pressure on surrounding schools and there is still an annual scrabble for places amongst the Warwick Gates residents, who have a nervous wait to see if their child will get their preferred option. Therefore, I have no faith that if the proposed plans go ahead the schools will come to fruition. Similarly, the Chase Meadow development had a playground site on the plans and again this was not built.

One of my main concerns is the health implications. I have read the Local Air Quality Progress Report (2011) and the areas already identified in this report as 'Air Quality Management Areas' will be affected by an increase in traffic volume as a result of the proposed developments. As Air Quality is covered by the Air Quality Regulations 2000 (amended 2002) and the Enviornment Act 1995, as well as various other legislation, I cannot understand why a full Health Impact Survey has not been commissioned. How does WDC know that the proposed developments will not take air pollution levels above the legal limits? It is not acceptable to just go ahead and worry retrospectively when we are talking about serious health implications. Many schools, nurseries and parks are in the vicinity of the Southern Site and the health of the children who use these facilities could be at risk if this goes ahead without a full assessment of the potential impact of such a large development. I seriously worry about the affect on my children's health and other children in the area. In my opinion this issue should take priority over everything else and I am extremely disappointed that WDC are not giving due consideration to this aspect of the impact on local residents.
In terms of Bishops Tachbrook, the village is already a cut through for many vehicles on their way to/ from the M40. When I walk my children to school in the morning there is a disproportionate amount of traffic travelling through the main roads in the village, in comparison to the number of residents. Speeding along these roads has always been an issue and the speed reduction measures are ineffective. There have been no improvements made to the road systems or pavements in Bishops Tachbrook since the development of Warwick Gates and I see no acknowledgement of this need in the RDS. This is yet another example of WDC failing to recognise and consider the wider reaching impact of large scale housing developments on existing infrastructures. If the proposed development goes ahead it will increase the volume of traffic through Bishops Tachbrook and that will increase the risk to the residents of Bishops Tachbrook, as there are no proposed improvements.

The housing proposed for village settlements has categorised Bishops Tachbrook as the largest type (100-150 homes). The Bishops Tachbrook housing needs survey identified a need for only 14 homes. Again, where is the evidence to support the need for 100-150 homes? Why would this many houses be needed in the village when 3400 homes are proposed for the Southern Site development? With regards to the visual, environmental health and infrastructure issues I echo what I have said in the above paragraphs.

I have read the criteria for the sites for Gypsy and Travellers from the consultation document. I do not think that the proposed sites are distributed evenly around the district and again the south contains a disproportionate number. All of the above points I have raised would also apply to the development of a Gypsy and Traveller site in this area.
In terms of the relevant criteria I do not consider the following sites to be suitable:
Site 3: this site is very remote and does not have easy access to facilities, access, pedestrian access.
Site 4: as above.
Site 5: The access is onto a very busy road and there is no pedestrian access. There would be a visual impact on the approach to Warwick and there is a listed building on the site. There would be undue pressure on the local infrastructure and services of such a small village.
Site 6: has no pedestrian access and is very remote in relation to distance from main centres and services.
Site 9: there would be a visual impact on the approach into Warwick and there are listed buildings on the site. The access is onto a busy road and there is no pedestrian access.
Site 10: Too close to the Guide Dogs for the Blind National Breeding Centre.
Site 15: This site is located on the banks of the Tachbrook. As the proposed site may be used as a place of work there could be a risk of contamination.

The school in Bishops Tachbrook has one class of approximately 30 children per intake. A GT site of 5,10 or 15 could be home to 10, 20 or 30 children. As Bishops Tachbrook is a small school already at capacity is could not support the needs of the site. There are other schools in the district that are not at capacity that could support the need.

The sites around Bishops Tachbrook are too remote to support the development and the village and its facilities are not big enough to support such an increase in population, in terms of infrastructure and facilities.

I understand the requirement for WDC to provide 31 pitches but I strongly feel that a larger number of smaller sites evenly distributed across the district in areas where the existing facilities can accommodate the need is the most appropriate way to meet the requirements.

I am writing to voice my concerns about the proposed Local Plan for Warwick which I feel will adversely affect the town and surrounding area providing little benefit and making the environment less pleasant, less safe, and less healthy. I have copied in my District Councillors, who I hope will note my comments and represent them as appropriate. I would be grateful if they could confirm this, or let me know if they are unwilling or unable to represent my views with their reasons.
I have also copied in my MP Chris White, to whom I am grateful for already voicing similar concerns about the Local plan.
As well as my concerns, I have highlighted questions to which I would like a reply.
First, I should state that I understand the disadvantages of not having an agreed Local Plan. But I believe it is fundamental that having the wrong plan is far worse than not having a plan at all. It seems to me that the proposed plan is indeed wrong for Warwick - socially, economically, and environmentally.

Housing
The Warwick District Local Plan is predicated upon a perceived need for an additional 12,300 houses in the area. This number is not proven, and forecasting to 2029 in the light of changes in social and economic conditions over the past 15 year period - or indeed any 15 year period in post-war history - is at best optimistic and almost certainly foolhardy. A more realistic forecast from the Office of National Statistics which examines the nearer term predicts a far lower housing need, one which could be supplied from existing brownfield sites and the normal planning process.
QUESTION: Why does the Plan not use the government / ONS predictions which given that its relative timescale and resources for forecasting must make it more accurate?
Given this false premise as a starting point, the Plan proposes building almost exclusively on Greenfield sites to the south of Warwick, so as to avoid encroaching on land that (by historical accident) has been designated Greenbelt. This Greenfield land is just as valuable to the character and environment of Warwick district, town, and country and should be afforded equal protection. Any reasonable Plan would consider Greenbelt and Greenfield within the county as equivalent, and make the best case for the best use of the most appropriate land accordingly.
The approach to and aspects of Warwick and Leamington from the south contribute enormously to the general perception of the towns and their rural setting is important to continued tourism, as well as the quality of life in the area.
The result will be a clustering of houses in an area with no immediate access to the employment they should serve. Warwick's employment rate is such that it is apparent that 'spare' jobs on this scale are not available. The Plan's own predictions for the availability of employment sites being redesignated for housing makes it clear that new employment in the area is not foreseen.
Therefore, the proposed developments south of Warwick must be to serve as commuter areas. Traffic is unlikely to be moving to the south, given the nature of the Stratford-Upon-Avon Plan which more than caters for new housing North of Stratford/South of Warwick.
QUESTION: Why is the Stratford plan not referenced in the Warwick Plan. If the Warwick Plan has been developed in isolation, as it seems, then the housing requirements it claims will surely be accommodated by the Stratford proposals which further invalidates the figures quoted.

Infrastructure
The Plan addresses only in the vaguest terms how the local infrastructure will cope with the additional 18% of population planned. The most basic mathematics suggests that in order to sustain the development, we should have 18% spare capacity in our infrastructure - that is without yet taking into account the additional housing in the Stratford Plan that will also draw on Warwick's resources and infrastructure in particular for Health facilities. While development would appear to be conditional upon it funding additional infrastructure it does not seem from the Plan that this funding will be sufficient.
QUESTION: Which departments of Warwick Hospital have over 18% spare capacity currently? Which departments are already operating at full capacity (or more)? Is additional capacity needed for the NHS, education, water supply and treatment, or other infrastructure? If so, where will funding for this actually have to come from?

Traffic
The main infrastructure points addressed by the Plan all relate to traffic. This is hardly surprising as the proposed developments will be car-dependent and provide accommodation largely for out-of-area workers. Local transport will therefore increase by at least 18% and probably more. Most of this will be in the form of cars, most of them travelling through Warwick.
The Plan proposes various road changes, none of which are designed to take traffic out of the town of Warwick, but rather attempt to allow the town to cope with greater traffic capacity. Without addressing the main choke-points of the two Avon bridges, and in particular Castle Bridge, these measures will not work. Increased traffic from the new developments will certainly increase air pollution, which is already at an unacceptably high level, as well as increasing the traffic in areas close to major schools. In particular, traffic will be increased significantly along a widened Banbury Road outside Warwick School at a point where there is no pedestrian crossing and where residents have already been informed that the road is too dangerous for a crossing patrol to operate.
QUESTION: Has a Health Impact assessment been carried out with regard to air pollution, and/or the likely effect on road safety especially for schoolchildren? If so, please can you forward me a copy or tell me where to access it. If not, why not?

Local Economy
Warwick town is dependent upon tourism and many of the businesses in the town - including all retail trade - depends upon visitors being able to get into Warwick, park, and get out again. If this becomes a chore, those businesses, and the town as a whole, will suffer as casual visitors simply go elsewhere for shopping and entertainment. Adding to the levels of through traffic will obviously hasten this process.
QUESTION: What proportion of the traffic in Warwick is already through-travelling? I did see a figure from a council survey (not sure which council, I'm afraid, District or County) that suggested that already over 70% of vehicles in the town are travelling through. Is this correct? What will the percentage be when the proposed developments are complete? If there is no data predicting this figure, why not?

Environment
The additional traffic through Warwick will have a detrimental effect on the environment as a whole, and on the physical town itself. As well as a negative impact on conservation areas, listed buildings and other sites of historical interest will suffer from the poor air quality, traffic noise, vibration, and the proposed changes to historic junctions at attractive points of historical interest such as the top of Mill Street.
QUESTION: What assessment has been made of the impact of increased traffic on key buildings, and in particular Castle Bridge. Please can you tell me where I can access the Engineer's / Surveyor's report that must have been completed to ensure that Castle Bridge can actually cope with the increased usage? There seems to be no mention of it, or any other similar assessments, in the Plan.

National Planning Policy Framework
The National Planning Policy Framework requires that proposed developments be sustainable with regards to the environment, the economy, and socially. The Warwick Plan does not meet any of these requirements. It will be detrimental to the environment; it does not serve the current or ONS-predicted economy; it is socially unacceptable.


I have attempted to be as objective as possible in my comments above, but would like to finish on a personal note. My work is not geographically dependent and I - together with my family - live in Warwick because we choose to live in Warwick. It is a convenient, accessible, beautiful, friendly place to live in a delightful rural setting. I am sure that we are not alone in this and that a significant proportion of the local population has made a similar choice. While we are here we obviously contribute to the community in many ways. Warwick is a place where people with a choice want to live.
But if the Plan does through in its current form, then it seems to me that many of the reasons that we had for choosing to live in Warwick will disappear. How many people in similar positions to us will also disappear, it is obviously hard to predict. But there is a real danger that the proposed developments will make Warwick a place where people with a choice do not want to live.

see attached

A, Volume of housing
The main proposal of the Local Plan is for a very substantial increase in residential development in the District. This is largely based on Government projections of housing need. The validity of these forecasts has recently been seriously questioned, not least because they anticipate a repeat of immigration into the area which has been shown to have been associated with the particular circumstances of recent years; there is no evidence that these circumstances are likely to be repeated. The Plan's population forecast also cannot be justified by the evidence: it extends far beyond the period covered by the original carefully researched report. It would be entirely reasonable and in accordance with the evidence, to set a lower figure for housing need, based on the natural growth of the existing local population, without deliberately seeking a further increase.

B, Transport infrastructure
The provision of this quantity of residential development south of Warwick would place a severe strain on the road network in and around Warwick and Leamington.

The aim of the transport aspects of the Plan appears to be, above all, to move traffic through the towns as rapidly as possible, with the least possible inconvenience to the users of the roads. The narrow streets of Warwick are totally unsuitable for this, as all evidence will show - see The Butts and the High Street. There is less evidence in the Plan of concern for the residents and for other occupants and users of the streets. Surveys have shown that a large proportion of traffic entering Warwick drives straight through the town, giving no benefit to the town. The road network should be developed to keep this traffic on by-passes outside the town, not going straight through it. Just getting more traffic passing faster through the towns will only damage the quality of life and the historic nature of the towns themselves, upon which the towns depend for their livelihood, principally through tourism.

C, Air Quality
The existing air quality has been recognised as unacceptably low. The Council is doing nothing to carry out its statutory obligations in this respect. There is no evidence that this poor air quality is properly taken into account in the Plan. Indeed, implementation of the Plan would damage air quality still further. How does the Council intend to meet its statutory obligations in this matter in future?

D, Warwick Bridge
The road network depends on the few existing river crossings. Of these, the bridge in Warwick is over 220 years old. No evidence is produced to show that the bridge is sustainably capable of carrying the further increases in traffic anticipated by the Plan. Has it even been surveyed for this particular purpose?

E, Warwickshire as a whole
There is no evidence that Warwick District Council is co-ordinating its own local plan with the local plans of adjacent district councils. If Stratford District Council approves a major expansion of housing in the Gaydon/Lighthorne Heath area, how will this affect this present Local Plan and the housing need it assumes?

Please think again!

The purpose of this email is to record and express my concern and dissatisfaction with the local plans, for many reasons, including the following:

- they are poorly thought out. There are better alternatives eg. priorty to brownfield sites, release land as is needed, not in advance anticipation of creating non-existent demand

- Health: air quality will be severely damaged and and even further below the legal level permitted. District Council should improve air quality not damage it beyond repair for future generations.

- Noise levels will increase irreversibly, as will congestion

- Transport strategy is car based - how old fashioned and backward thinking!!

- Historic environment will be damaged and spoilt. We have responsibility to look after historic buildings and routes, not destroy or damage them.

- The projected housing need of 12,300 new homes to be built is much too high.
Less than half that number would meet local needs. It is wrong to forecast as far into the future as 2029, and to allocate greenfield land now. It is akin to having no plan at all, allowing uncontrolled growth, just leaving developers to decide what to build when.

Please do rethink this and protect local environment. Please do consider better alternatives: lower housing numbers to meet local needs, especially for houses which people can afford, instead of encouraging in-migration; gradually releasing
land for development as demand grows; giving absolute priority to using brownfield and infill sites near schools, shops and railway stations; building homes close to jobs; and cooperating with other local authorities, instead of competing with them for development.