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

I refer to the 'New Local Plan'. I attended the meeting at Trinity School and now wish to comment as follows:


Concerns:
1. I consider the numbers of houses proposed over the life of the Plan to be excessive and unjustified.

2. The District is already too crowded, the additional population will 'swamp' the existing and is unfair to those who have already made their homes here. The additional traffic will lead to 'gridlock' in existing streets, especially Warwick High Street/Jury Street, and will create even more pollution.

Comments.
1. I was bitterly opposed to any further development in the Milverton/North Leamington areas as this would -
a) require the loss of good farm land at a time when the nation needs to increase not decrease agriculture.
b) it would further encroach on our 'green belt' separating us from Kenilworth.

2. I am pleased therefore that the Revised Plan recognises that there are no special circumstances for the use of this green belt and does not include proposals for further development in the Milverton/North Leamington areas.

3. The use of land in the south of Leamington/Warwick to meet the proposed development makes sense because -
a) ease of access to the M40 J14 and J13
b) all large and recently built supermarkets etc are to the south of the town.
c) local employment opportunities.
d) the Revised Plan allows for road improvements.

4. The District has an asset in Leamington Football Club (the 'Brakes'). The Club has risen through the levels of the sport and is only held back due to its present location. Provision for an independant stadium in South Town that would in due course cater for the Club becoming professional should be considered. (I am not an offial of the Club).

5. Having to use the Emscote Road 'cycle path' on a regular basis I have no confidence in the Council's ability to provide safe and acceptable cycling facilities which will be needed.

6. I have no comments to make on the proposed gypsy sites other than I feel the pitch size proposed is larger than needed.

7. If this development within the the District is essential I consider the Revised Plan to be the best option and it has my support.

Thank you for giving me the opportunity to comment. Having attended the Trinity meeting I do have sympathy with the Planning Officers with the task they have in this matter, clearly they will not 'please all the people all of the time'.


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 just as strongly.

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.

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 has the required five-year supply of sites, balancing housing with employment growth and matching the housing market.

Transport: sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network, bridges over the River Avon, and parking. Contrary to transport policies, it would make walking and cycling less attractive, and could not have good public transport. It has long been obvious that the current road infrastructure within the Warwick South Area does not cope with present levels of traffic and so to propose this level of additional build would appear reckless and ill considered. It is fine saying that this will be addressed, but how? This area does not lend itself to the building of large arterial road networks. Please protect the history of our area.

Air Quality: pollution from car exhausts in many streets in Warwick town centre 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. Worse, the long-term health of residents of these streets would be even more threatened.

The historic environment would directly be damaged by the increase in traffic and by 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, giving no impression of the beauty of the spa town.

Other Infrastructure: While in theory development would be conditional on it funding schools, and health care facilities, the Council's predicted funding and provision has a woeful shortfall and is not enough. There would also be risks to water supply, sewage and drainage.

There are 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 co-operating with other local authorities, instead of competing with them for development. Every area of Warwickshire should take it's share of these new houses however, currently, these proposals would appear to be being bullied through by an Executive committee who are acting as Nimby's. It is time that fairness was considered. Current proposals are not fair!

The possible Gypsy and Traveller sites are concentrated in the same area, again because such strong protection is given to the Green Belt and so little to our green land. Again, not fair.

The consultation process and the politics of the situation also give rise to concerns, but these are matters to be pursued by other means.


Question:
Where would all the people moving to this proposed build work? Concentrating the majority of these new houses in one area is wrong. The old "local plan" was ludicrous but this is worse, please reconsider before it is too late.

I wish to respond to some of the points outlined in the Local Plan:

3.4 Do not agree: has the Avon Bridge been assessed for increase in traffic? Solution: commission report asap. Installation of additional traffic lights not enhancing the aspect in this conservation area.
Solution: decrease in traffic required.

3.5 Do not agree: concentration of 4,500 houses in one area ie to south of Warwick and Leamington. Solution: look for alternative sites

3.5 Meeting Housing Needs: 6,000 required by 2010 so why is WDC proposing 12,000? Solution : reduce stated number

3.6 No mention of air quality ie traffic emissions. Already an ongoing problem identified. Solution commission report to assess impact of increased traffic asap. Solution 2 - reduce number of vehicles in town centre.

3.6 Sustainability: Do not agree - the plan does not meet our current needs and therefore fails this criteria

4.3.10 It was agreed at Area Committee in January 2008 to reduce the volume of traffic in Warwick. So how will this be achieved with the inevitable increase in traffic?
Solution: there is only one way into Warwick from Banbury Road and no viable alternative. Saying that car drivers will use M40/A46 to access roads to north - what evidence do you have? I was told at exhibition "it was hoped this route is used"

5.1.29 This will result in deterioration of air quality ie standing traffic at lights and slower speeds through town.

5.6.1 Have these been tested to a sufficient level of detail?

Public Transport - I do not drive therefore I know the limitations of using buses, reduced evening services, limited on Sundays and Bank Holidays, none on 25th & 26th December. It is not realistic that
residents can rely on public transport. Solution: provide and subsidise
a comprehensive bus system to suit the needs of residents
7 days a week from 6am to 11pm including Sundays and Bank Holidays.

5.6.3 The proposed implementation of blocking the right turn from Smith Street into St Nicholas Church Street will seriously impact on visitors, customers, traders and residents. How is it proposed that drivers wishing to access roads to the south ie Banbury Road or Stratford Road do so efficiently? Solution remove this idea from the proposal.

5.6.5 The introduction of possibly 2 lanes and reduced parking in St Nicholas Church Street is detrimental to this historic road and its residents. It does not seek to reduce traffic, will impact on the poor air quality identified both at St John s and St Nicholas Church Street.
In addition visitors to St Nicholas Church will not be able to access a right turn from their church onto Banbury Road. A crossing across Castle Hill for tourists and residents has been identified as a requirement for safety, how will this be accommodated?

At an exhibition of the Local Plan I was informed that the Plan was rushed through and therefore not passed through the "Plain English" route. I also feel the amount of documentation and short time scale imposed is difficult for respondents to reply to.

My greatest concern is air quality especially in light of two reports recently published in national newspapers concerning traffic emissions.
The Council has a responsibility to ensure that a reduction in pollution is carried out as a matter of urgency.

New Homes and Projected Numbers

I struggle to understand the long term plan to increase the volume by 12000 and in the south of the District by over 4000 in the next phase. This will completely transform the dynamics of the community to the south of Leamington and severely damage the appeal of the area. I would want to see clear evidence that the local economy and new employment will demand such growth. This said, in planning terms the recommended solution seems to be an easy planning option. A huge swathe of housing adjacent to Myton is not clearly thought through.

We already have a large vacant property stock and many brown field sites which with imagination and thought could be brought back in to play to regenerate the town and restore its character.

Why cannot we see smaller developments around the outskirts, both north and south of Leamington rather than one' big bang '.
The constraint of green belt seems to have been overcome and modifications made by other District Councils . Is there joined up thinking across the whole of the County both in terms of policy and capacity?

I am also concerned at the impact the Plan has on the land close to and surrounding Warwick Castle - a major economic attraction to the District.

Office Buildings

Why are there proposals for more office accommodation?
There remain significant office buildings vacant in Leamington - indeed many offices have been unoccupied for some years. Proper planning should bring these buildings back into the equation. They also provide options for redesignation / modification as housing.
In this way the gradual decay of our town centre could be addressed. It remains too easy simply to build outwards!

Transport

The proposed modifications / widening of roads to meet expected volume changes does not acknowledge the fact that as roads draw closer to the centre of Leamington there are unavoidable bottlenecks with simply no where for traffic to go! Peak travel would become impossible if we extrapolate the average number of cars per proposed new dwellings in terms of vehicle growth.

Health Services, Schools and infrastructure

While any developments would need to balanced by additional health centre and GP services it is difficult to see how Warwick Hospital and both its general and maternity services could cope with increased patient numbers which in the long term could rise by up to 50,000 The hospital itself is landlocked with no scope for expansion.

The quality of education in existing schools could well be undermined if capacity is not accurately calculated. I am uneasy about class numbers rising above accepted norms.

Has the current work regarding drainage in the town taken account of the impact of such a large increase in dwellings?


In conclusion I remain very unhappy about the Plan. It does not appear to have been thought through with any in depth knowledge of the District but and with somewhat dubious population statistics and economic forecasts.

I am writing to object to the current proposals in the Warwick District Council Local Plan Revised Development Strategy and to support an alternative strategy. This is not based on purely emotional reaction or "nimbyism" but on acknowledged planning considerations, a concern for the future of Warwick and its suburbs, and some relevant legal implications. In particular I have grave concerns about the ability of the future transport infrastructure to cope with the District Council's proposals and the disastrous effect that those proposals will have on the quality of life in the town and its suburbs.
Although the thought of any major new housing development affecting Warwick is profoundly worrying, I accept the District Council's view that the economic arguments justify a reasonable level of development in the area covered by the Local Plan. However, the proposal to allow 12,300 houses by 2029 is far too extensive and must call into question whether district councillors, especially those representing constituencies outside Warwick, are genuinely concerned about the future of the County Town. I understand that in response to the consultation, evidence will be put forward by acknowledged local experts in planning, legal and conservation matters. I believe that these representations will justify a substantially reduced proposal for housing development in the area.
Transport infrastructure
It must be patently obvious to anyone who lives or travels through the area that Castle Bridge, Myton Road and Prince's Drive are struggling to cope with the existing level of traffic, especially at peak hours. The modifications to the road system following the opening of the Morrisons and Aldi supermarkets are not solving these difficulties. The tiny modifications in the above three areas proposed in the Local Plan documents will only tinker with the problem. The impact of 3,195 new houses with access to the existing traffic bottlenecks of Myton Road and the Shires and the old Ford Foundry roundabouts will lead to more extensive gridlock and pollution in the whole area between Castle Bridge, the Ford Foundry roundabout and Warwick New Road. Even if one accepts that the Local Plan is not intended to improve the existing traffic and environmental pollution, it should not be allowed to exacerbate gravely an already barely acceptable situation.
Environmental Pollution
I understand that the level of pollution in Warwick town centre is already above legal limits and that the District Council will be receiving submissions about this during the consultation. I urge the Council to give full consideration to this evidence.
Level of Housing Development
At a recent meeting the audience was given to understand on planning grounds that to meet the existing needs of the area only 5,400 (not 12,300) houses are required. This could be achieved without using the vast swathe of greenfield land south of Warwick, Leamington and Whitnash, by relying on the much less invasive and intrusive 5,678 homes already completed or allocated in the Local Plan. Any significant increase above the 5,678 would appear to give grounds to those who suspect that the Council is more concerned to attract people from outside the District than to support its existing population, and to attract lucrative planning proposals from developers. There appears to be no current evidence of a demand for employment development schemes. The lack of interest in office development on the area allocated on the Morrisons site speaks volumes in this regard. This feeds the frequently made suggestion that the Local Plan is really aimed at attracting new home owners to the Warwick area who will not work there. This may be more lucrative for the Council, but commuter traffic would therefore increase, further exacerbating the problems of transport infrastructure and environmental pollution outlined above.
On a further important point, it is very worrying that Stratford-on-Avon District Council is consulting about the possible provision of some 4,500 houses in Gaydon and Lighthorne Heath, not many miles from the main development area proposed by Warwick District Council. It is very likely that many such home owners would look to Warwick for employment and services, again further exacerbating the problems outlined above.
Conclusion
If Warwick District Council is genuinely concerned to implement a Local Plan that is "strongly based on evidence and takes account of representations made by interested individuals and organisations", then I believe that it should modify its proposals and allow only the 5,700 or so houses on sites already completed or allocated.
This would be in keeping with the Council's strategic vision of making Warwick "a great place to live, work and visit". Please do not betray that vision by subjugating what has until now always been a great place to live to the voracious demands of excessive housing development that would ruin the nature of Warwick and its suburbs forever.

You have invited objections to the proposed new local plan. Mine are quite simple and they are: Too many people and Too much road traffic. My wife joins in these objections.

I am writing to you to strongly object to the new local plan.
I have a number of points detailed 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.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

I have been following the development of the latest attempt at a local plan and find the whole thing a bureaucratic nonesense. A lot of very talented council employees have spent an enormous amount of their valuable time trying to create a cohesive and coordinated plan to cover the housing needs for Warick and Leamington Spa for the next generation, with appropriate infrastructure to support a very large number of houses.

However, already over 2,500 (or is it 3,500??) dwellings have had planning applications already placed with the council. These refer to potential schools, provision for health care etc but do not seem to offer the definitive infrastructure that is required. 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.

Why not scrap the whole thing and let a free-for-all sort it out BECAUSE THAT IS WHAT IS HAPPENING - NOW.

However I do have some specific points:
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 grind 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. My son has currently the worrying task of finding a school place for his daughter and we 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.

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.

I write with reference to the Proposed Revised Development Strategy for Warwick and Leamington as proposed by the local Council and my concerns in this regard.

As a local resident I have grave concerns regarding the proposed plan for our town and the effect this will have on the local environment and more importantly the historic and wonderful town of Warwick.

I understand the overall plan proposes over 12,000 new homes in Warwick and Leamington and in particular the overly proposed allocation of 6,630 new homes south of Warwick town. I have been advised that based on the last 10 years births and marriages a truer reflection of our needs would be 5,400 new homes. I am gravely concerned that the over populating of our town with in excess of 12,000 homes will have adverse effects in many ways and am not convinced that this proposal is a true reflection of our requirements.

I believe this proposal will be the ruination of historic Warwick which should be protected at all costs. This proposed plan is not a sustainable development and is not in the interest of Warwick but favours the feathering of developers pockets only.

The loss of agricultural land and green space is appalling and the plan saturates the south of Warwick with over development whilst the North of Warwick is spared. Whilst the North of Warwick is allocated as Green Belt land the South is equally if not more important to retain as green land and the Council should have protected this by applying for Green Belt status for this area.

I remain concerned that the increase in traffic that such a development would cause has not been properly considered and whilst dual carriage ways are proposed for all main routes from the M40, the volume of traffic trying to cross over what can only ever be 3 bridges over the river will bottle neck and cause Warwick to come to a complete stand still during peak hours. I am particularly concerned that the Bridge over the river by the castle simply cannot cope with this level of traffic and will be destroyed. It is considered that 76% of traffic will be through traffic crossing to the North side of Warwick towards employment in the Coventry area. To develop the South instead of the North is simply ridiculous.

The Air Quality in Warwick is at illegal level already, and as my husband is a sufferer of asthma since we moved here we know the importance only too well of this problem. It has recently also been linked to cancer and as such I would request the Council to provide information regarding the Health Impact and a commitment to what plans they have to resolve what will be already illegal and unacceptable levels.

No commitment to what impact this excessive development will have with regard to if the local facilities such as the Hospital has been provided.

As a resident of Saumur Way, I am absolutely horrified that not only will our wonderful Warwickshire views be destroyed but that our quiet cul-de-sac is to become a through road. A key factor in our purchase of our home 15 years ago. The cycle path that is frequented by school children and is a safe passage way for their journey to school will become a danger spot. Whilst we are assured that only a section of the proposed estate will access from Saumur Way and bollards will prevent other cars from using this access, it is obvious that motor cycles will use this route as a rat run to the Myton Road.

Not only is this development proposed but an additional 1,900 homes at Light Heath currently being applied for which will add another 4,000 vehicles crossing through Warwick. It would seem that Warwick Council and Stratford Council have not liaised regarding this development and therefore this additional traffic is not considered in the Warwick Plan.

The proposal allocates a certain amount of land set aside for business development. Currently allocated business assigned land cannot be sold for this purpose and is in the propose of being re-allocated for housing. An indication that this proposal will not be sustainable and will increase the unemployment of Warwick.

I am concerned off the flooding indications of such a development. In the recent winter the fields of the Henry VIII trust land currently farm land were flooded and I know that in previous years this land has flooded onto the properties within the Saumur Way site. I do not believe the area can safely accommodate such a development without flooding risk to the houses already here.

I strongly object to this proposed development plan which I believe to be the ruination of a wonderful historic town destroying and altering forever the landscape and views from our wonderful Castle which can never be undone.

see attachment

I am writing to object to the draft Local Plan that has been proposed by Warwick District Council on the following grounds:

The estimates for the demand for new houses are based on very unclear evidence and assumptions. Many other districts make some attempt to justify their housing demands based not only on the change in demographics but more importantly the estimates for growth in employment in the area (and what the plans will do to stimulate that growth). The Revised Development Strategy adopts an interim level of growth of 12300 homes between 2011-29, and quotes various studies but there is no hard evidence in the document to substantiate the huge growth contained within the estimate.
To get an idea of the scale of the demand, I drove around Warwick Gates with its own community centre, health centre, and shops serving around 1500 houses. This is a big development. The local plan estimates the Warwick District will need the equivalent of 8 x Warwick Gates to satisfy the housing demand. We need some hard evidence to substantiate that scale of development!
The National Planning Policy Framework specifically states that councils should take into account neighbouring schemes and yet no mention is made of the proposals by Stratford District Council to build a new 'village' of 4500 homes near Gaydon, which would be nearer to Warwick than Stratford. This is another 3 x Warwick Gates. There must be some overlap in the assumptions made for the demand in such a small area and the plan should not proceed until that demand is justified by realistic assumptions.

The plan defines the location for about 6000 of these homes. It proposes to put the vast majority ( nearly 3 x Warwick Gates ) in a small area south of the Warwick. The rationale for the location of the major developments in this area seems to be that the Green Belt protects development elsewhere in the county. When the Green Belt land was established, north of the towns of Warwick and Leamington, it was intended to stop urban sprawl. There is no difference in practical terms between the 'green' land to the north of the district and the south of the district. They are both green and they both should be protected from urban sprawl. The council has the powers to use the Green Belt land for development and not use it as an excuse to condense all future development into a small area south of Warwick.

The subject of transport is the most baffling part of the plan. We live on Myton Road and we chose to live there because of the difficulties of commuting to the centre of the town. Everyone who has to get into or through Warwick knows of the huge traffic problems around the town. The proposed infrastructure improvements seem to ignore the fact there will always be 'pinch points' where roads cross the river. These cannot be overcome by improvements to junctions and dual carriageways. There will be much more congestion as a result of the proposed massive increase in housing in the area (11 x Warwick Gates ). The house occupants will be reliant on cars, usually with more than one car per family. There has been no clear data ( from traffic simulations ) to show the effect on traffic congestion in the area. It is not realistic to estimate an increase of over 12000 homes ( most of which will be in the area south of Warwick ) and have an infrastructure plan which simply improves traffic junctions. This is not a sound basis of a sensible plan for a town that is already experiencing huge traffic problems.

Warwick already has air quality issues, which will be exacerbated with the increase in pollution caused by the introduction of additional large numbers of cars crawling through the streets of the town. The residents of Warwick should not be exposed to this additional risk and the school children of Warwick School and Myton School rely on sensible adults to protect them.

The demands on the infrastructure for schools and hospitals will greatly increase. In particular, the demands on Warwick Hospital have not been adequately assessed. This is a relatively small hospital just about coping with the needs of the current population. Add 8 x Warwick Gates (plus the likely effect of the Gaydon 'village' - 3 x Warwick Gates) and it is clear that the demands will exceed the capacity of the hospital to cope with the increased population.

In summary, this is not a plan that shows how Warwick District will grow and change over the coming years. It is simply a charter for house developers. The demands for housing are speculative and excessive. They have no declared employment projections and no mention of the effects of adjoining developments in Gaydon. The concentration of development into one area conveniently relies on green belt rules, which could be easily overcome. The effects on Warwick in terms of traffic, pollution and health are not adequately addressed and I hope that the plan will be reconsidered before we go down a route, which will ruin such a beautiful town. As a newcomer, my sense is that the outrage shown by the people of Warwick is not a NIMBY reaction but a genuine desire to oppose a plan, which would have such an adverse affect on their town. The Council's stated vision is 'to make Warwick District a Great Place to Live, Work and Visit'. It is inconceivable that this plan can fulfil that vision and the plan should be rethought, involving the people of the district to satisfy that vision.

Consultation Response to New WDC Local Plan Preferred Options Paper

I am writing to object to the proposal for 12,300 houses in Warwick District and nearly 4,000 new houses in Warwick. In objecting I refer to the National Planning Policy Framework which "aims to strengthen local decision making and reinforce the importance of up-to-date plans".

Population Growth

The NPPF states that there should be a clear strategy "taking account of the needs of the residential and business communities".

Why has the number of 12,300 been proposed which is higher than the 10,800 proposed in the Core Strategy and was strongly resisted by Warwick District Council at that time? The West Midlands Regional Office was vehemently criticised by WDC for producing these flawed and untenable figures. Your figures do not comply with WCC population figures and are therefore unreliable. A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause immense damage to the character of the County Town. Migration from other areas into Warwick's more attractive green environment has produced most of the population growth. The provision of more houses will encourage more migration and Warwick will no longer be an attractive area. The new Plan should cater for LOCAL needs not migration into the area. You have included figures to cover an increase in students but they should be housed near the Universities not in the District, especially in south Leamington. Increasingly high concentrations of students in certain areas is an issue of concern.

Regarding your assumptions on the demand for housing, given that more than 50% of national population growth has been from immigration over the last two decades, and the government has publicly stated it wishes to greatly reduce this future net immigration, why is Warwick District planning for an even greater level of growth over the next 15 years, than has been experienced in the recent past? Warwick District population has increased by 12% since 2000, which is approximately twice the rate of increase for Warwickshire, twice the national average increase, and over three times the increase for West Midlands. Warwick Councillors asked that the proposed development should be equitably distributed over the District but half of the homes proposed in the new Local Plan are south of Warwick.
Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and history has shown that the necessary infrastructure has never been put in place.

The NPPF (48) states that Local planning authorities may make an allowance for windfall sites in the five-year supply". 1,224 properties have planning permission or a planning brief at the moment and yet you do not appear to have taken these into consideration. This would equate to a two-year supply of houses. I do not believe our authority has identified and brought back into residential use the 300-400 empty houses and buildings (NPPF 51) to the extent they should have done. Not all empty homes have been identified. New planning laws now allow unused office space to be converted to housing and his should be taken into account in the housing projections.

We have not been given information on where the 'missing' 6,000 homes are proposed to be built. Why not? You have stated at Aylesford School that this has not been decided yet. How can we make informed representations without the full facts being presented in the proposed new Local Plan?

The validity of your forecast projections of housing need has been seriously questioned. Evidence submitted by Cllr. Ray Bullen demonstrates that there is a 5 year housing land supply. The last 5 year housing land supply document is dated November 2012. It is out of date. The NPPF 153 says the " Local Plan .......can be reviewed in whole or in part to respond flexibly to changing circumstances". Therefore the out of date 5 year plan should be updated immediately to take account of those changing circumstances.

Research by Cllr. Ray Bullen shows that only 5,400 homes are necessary for local need which allows for moving in and out of the area based on what happened in last 10 years (births/deaths/migration). 12,300 includes economic growth but if jobs don't materialise unemployment will rise. Unemployment is low 1.6% currently. We need a homes/jobs balance. If we are looking to build housing you then have to match employment to housing. There appears to be no current evidence of a demand for employment development schemes. Employment land currently available cannot attract employers so cannot justify building 12,300 houses, e.g. the lack of interest in office space at Morrisons. Where will we find employment to match housing? The large office block plan at IBM is now being used for housing (windfall site).

The NPPF requires 'sustainable development'. The three criteria of sustainability are environmentally, economically and socially sustainable. The development south of Warwick is not sustainable.

I believe that the only motivation for WDC producing such figures for demand is the income that will benefit WDC in New Homes Bonus, rent, rates, council tax monies etc.

Stratford-on-Avon is currently consulting on the possible provision of some 4,500 houses in Gaydon and Lighthorne and this would impact on the need for houses in Warwick District. Local authorities have a duty to co-operate but WDC have not had discussions as yet with SoA.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Green Belt

The NPPF (79) states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence."

An incredible 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

NPPF (88) states "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and I am objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. I would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

Stratford-on-Avon have said there are exceptional circumstances to develop on certain areas of Green Belt. Why doesn't WDC take same point of view? There is land available north of Leamington and in Kenilworth which is nearer to employment in Coventry and the Gateway.

Coalescence

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The current Local Plan states in para 9.11, "It is important to protect the areas of restraint from development proposals that could alter their predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate one urban area from the next." The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including owls, uncommon woodpeckers, roe deer and badgers. This green space also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on! The NPPF 109 states "the planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological netwoerks that are more resilient to current and future pressures."

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. 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. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Yet your reason for allocating development on Green Belt, against the National Planning Policy Framework is that "there is nowhere else to build". This argument is totally flawed and I would expect the Inspector to find this Plan unsound on this issue.

The NPPF (17) states that planning should be "empowering local people to shape their surroundings."

Why has this amount of housing been proposed for South Warwick when the previous consultation on the Core Strategy produced a 97% response in overwhelming opposition to housing here (700 objecting to the Europa Way, Gallows Hill and Banbury Road area.. Why were those results not heeded when you devised the new Plan? These plans do not reflect the aspirations of the community as the Government intended in the Localisation Act.

Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk but you are proposing to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102)

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. You have received photographic evidence of flooding from properties in Myton Crescent and the Malins. When the Warwick Technology Park was created, there were severe flooding problems in the adjacent Myton Gardens. The field donated to Myton school as a restricted covenant playing field has proved to be unusable because of water-logging, demonstrating on-going water-management problems. Even more relevant to the Malins and Myton Crescent was the severe flooding in 2007 caused by the re-orientation of the water run-off flows and the disturbance and removal of top soil from the Round Oak School playing fields behind Myton Crescent. It was only after threats to sue the County Council that remedial action was taken. This consisted of a bund to capture excess run-off and a pump situated in the north-west corner to return water uphill into the drain near the Round Oak School. This action has proved ineffective and inadequate as run-off water has periodically flowed into the gardens most recently in October 2012 when the water level reached was only a few inches below the level of the electricity sub-station situated between 26 Myton Crescent and 1 The Malins.

The field at the end of The Malins slopes upwards from The Malins and run-off water from adjacent fields above and to the right and behind also flows towards The Malins and Myton Crescent. When there is a downpour on saturated ground, water flows quickly down, fills up the lower parts of the field and collects in the gardens of nos. 26, 28 and 30 Myton Crescent, and overflows into the gardens of nos. 3 and 12 The Maslins and towards no. 1 The Malins and the electricity sub-station. There is little indication that the seriousness of this flooding is being taken into account.

Ignoring flood risk is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere." The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

 
Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. They were then allowed to build more houses on the area allocated for sport/play area at CM. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Coventry Council should also provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

Infrastructure

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "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."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries, evening clinics and Saturdays to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost. The public sewer discharges to Longbridge Water Treatment Works. Severn Trent currently transport sewage from Longbridge to Coventry by tanker several times a day. They do not have the capacity now to deal with sewage at the Longbridge site and it is inconceivable how they will cope with sewage from another 4,000 houses in Warwick. How many more tankers will be required and at what extra cost?

Buses have not proved to be sustainable. The only service for Myton Road is one per hour and no-one uses it.

CIL

The NPPF (175) states "Where practical, Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan. The Community Infrastructure Levy should support and incentivise new development, particularly by placing control over a meaningful proportion of the funds raised with the neighbourhoods where development takes place."

You have not provided information on these charges at all. I do not believe that there will be anywhere near the amount of funding available from CIL to cover the above extra infrastructure needs, especially new roads, bridges, schools and hospital. The hospital currently is in crisis and there is no room to extend. Funding for a new hospital is in doubt.

Air Quality/Traffic

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "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."

The Traffic Assessment commissioned states, "Schemes proposed within the modelling at this stage have not been tested to a sufficient level of detail to determine that they are the optimum solution" and "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"!

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 12,300 new homes, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?

The 2008 Air Quality Action plan for Warwick shows the very worst area being Warwick town centre and states on page 17:-

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape geology, cultural heritage and material assets must be thoroughly assesse, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. Ass assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

NPPF 124 states, "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."

I request that a Health Impact Assessment will be carried out including air quality testing well before any Local Plan in its current form is approved.

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road, Europa Way, Castle Bridge, Emscote Road and Prince's Drive are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen. One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area. The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then put it in for development - why? Traffic would increase at the Butts, the narrowest road in the town and the no right turn plan for St. Nicholas Church Street would impact severely on the economy of Smith Street. Vibrancy of the town centre is important. Think about what the effect will be on people sitting outside cafés in danger of being knocked over and pollution from all the traffic being funnelled through Warwick. People won't want to shop in Warwick because they won't be able to get into the town. It will be the destruction of Warwick and the people who want to shop here. There will be an adverse affect on Tourism.

Parks

In the new Local Plan our parks will not be sufficiently protected from development by the old area of restraint policy we once had.

Historic Environment

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. We need an impact assessment to ensure its conservation. English Heritage have offered to help with this.

The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional." The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre. Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe" (NPPF 32).

Gypsies and Travellers Sites

Why are 15 of the proposed sites south of Warwick and only 3 north of Warwick?

Conclusion

You state that in 2026 Warwick District will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands that have developed and grown in a way which has protected their individual characteristics and identities....." In my opinion this could not be farther from the truth.

The above comments demonstrate that this Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable. I believe the Planning Inspector will declare it unsound, especially on the air quality issue. It cannot be justified as "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence" and it is not "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework." (NPPF 182)

This Plan should be completely revised taking account of the above, specifically reducing the numbers of housing proposed for Warwick.

I wish to object to the Revised Developement Strategy for the Local Plan, as it is would require a very substantial increase in car journeys, which is clearly neither desireable, nor sustainable.

RDS 1 I object to the assesment that 12300 houses are needed in WDC. I accept the need for more houses in our area, if they are to fulfil locally generated needs, not just to create suburbs that will encourage people to move in from other more established areas. A more realistic figure would be about 6500 homes. Much of them one or two bedroomed dwelling, for which there is the greatest need. There are already some 1150 permissions for housing granted by WDC, and the developers have not built more than about 200 per year at best.
Local Authorities have a duty to co-operate with each other in preparing their local plans, what consultation there has been between Coventry City, and Stratford District Councils(SDC) has not led to any agreement as to developements bordering on the boundaries of WDC.

Para5.5.9 Page 52 asseses that Coventry Gateway will become 'a significant creator' of employment. The transport links, already good, will be enhanced. A substantial number of dwellings should be built close by, both on the Coventry side and the WDC side.

Gaydon No mention is made of the current employment at Gaydon, and the projected growth there. Presumably because it is on the Stratford side of the boundary. SDC are planning to build a substantial number of houses, shops, schools etc , close to the Gaydon source of employment. This is an example of developement that wil be 'Sustainable' in the future, not needing long trips by car for work, shops schools etc. WDC should also site a large development near there, in order to make the 'New Town' more viable, and to help to reduce the considerable car traffic that it already causing severe congestion in the area.

Concerning your proposals, I would like to raise the following objections:
>
> The excessive targets for new homes would ruin the historic county town of Warwick. There is no evidence for this requirement and no mandate from the community to support it.
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> The proposed development is unbalanced, meaning that the south of Warwick will be overburdened. This would be especially detrimental given the proposed development by Stratford District Council to have 4800 new houses at Gaydon/Lighthorne. Many of the 20,000 new residents would be travelling into or through Warwick town centre for work, shopping or use of the medical facilities.
>
> The resulting huge increases in traffic would lead to severe congestion within Warwick. The historic town centre is not capable of accommodating this to allow traffic to flow in anything resembling an efficient manner. These proposals are totally inappropriate for the Conservation Area of Warwick and would damage its fabric, environment and its businesses.
>
> The resulting increases in traffic congestion would also lead to significant increases in pollution, which we know is already likely to be breaching Air Quality Regulation (England, Wales, 2000). This would be detrimental to the health of our community.
>
> In Bridge End and the surrounding area there is already a very real risk of damage to properties from flooding, particularly from drains. The 6,630 proposed new dwellings would put the drainage system under severe strain and subject many of us to damage from the inevitable flooding.
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> We in Warwick are very proud of the heritage of Warwick castle which is vital for the town's economy. The landscape to the south of Warwick should be protected, otherwise the historic nature of the town, including views from the castle ramparts will be irrevocably damaged.
>
> Therefore we are strongly opposed to the Revised Development Strategy and hereby register our objection to this local plan.

As a resident in the District, I would like to register my fundamental concerns to the proposed Revised Local Plan.

There are a number of features that will prove to be serious retrograde steps to the area:

1. Why are brownfield sites not being utilised before new greenfield developments - is it "easier" for developers to go for greenfield sites?
2. The farmland that is now being earmarked for development is medium to high grade and should be retained for its ability to produce multiple crops and be part of the UK agricultural economy rather than requiring yet more food to be ultimately imported
3. The density and volume of new houses - the number of houses appears to be significantly overstated and concentrated to the south of Warwick along Gallows Hill area rather than being spread more evenly (even if the number of houses required is a correct projection).
4. It is not a given that all new residents will work in the same area as they live, therefore congestion is inevitable because of the concentration of new houses to the south of Warwick
5. Likewise the proposed new employment area close to Gallows Hill is likely not needed, there are numerous empty office blocks available for new businesses already existing on various technology parks or other areas around the district. Many that have not been fully occupied since they were built.
6. The density of development means that the very features that attract people to live in Warwickshire will be lost and the developments will just become co-joined, with no distinction between the different sub areas and villages. The attraction of Warwickshire is farmland between and surrounding the town and villages adjacent to Warwick and Leamington, providing space and definition to the residential areas. People who live in Warwick District do not want to live in a housing/pseudo town sprawl. The "country park" that is proposed on the edge of the new Gallows Hill development is a poor substitute for open fields and becomes a semi urban "park" given its location not open countryside. Prior studies that WDC commissioned (Planning Inspector 2006) )stated that the Woodside Farm area should not be built on.

In addition, Bishops Tachbrook, seems to have been "chosen" as a Primary Village for expansion, presumably because of the volume of housing due to be created as a result of the Local Plan. This is based on a poor premise and seeks to alter the dynamic of a successful village. A village has a distinct identity and the boundaries shouldn't be needlessly expanded. The views from the village are of rolling countryside, which would be slowly eroded and the distinct spacing that allows the village to function as a village (rather than as an add on to a new development or Warwick Gates or Whitnash) will be lost. There is real history to the village which would be lost forever. Likewise extra housing and increased attendance at the school will cause more congestion and be dangerous to pedestrians and drivers. The size of the existing roads fits with the size of the village and to expand or widen the road network would again destroy the soul and history of the village, which should be retained for future appreciation by others. Adding on an extra 100-150 houses is also unnecessary, and again a very high volume where the need is not supported or proven.

Gypsy Sites

There are significant concerns regarding the location and number of pitches proposed. Firstly, it should be noted that it is not a given that gypsies would use such sites, in other areas (Shipston) there are sites which were set up but not used. Land that is used by the gypsies tends not to be managed well and so becomes an eyesore to other surrounding residents. The write ups suggest that they will pay council tax but given that many of the gypsies will probably be unemployed there is no motivation to take pride in the surroundings. If the council does not manage these, then there is limited re-course by those potentially affected in the direct vicinity.

The proposed sites, such as those at No's 3, 4, 5,9, 10 and are all located adjacent to busy roads, which would be dangerous to all parties including the gypsies. They are not close to secondary schools.
There is no information on the maximum number of people that would be allowed to stay on the site. The public information states 20-30 number of caravans but that does not give any idea of possible density of inhabitants, which will put a strain on local services.

I sincerely hope you will listen to the feedback the WDC receives and revise the location and volume of development to a less intrusive and a more sensitive number.

WDC should revisit its plans and include sites to the north of Warwick and Leamington. Stratford DC are proposing to develop 4,800 new dwellings in the Lighthorne Heath and Gaydon areas. The combined weight of extra traffic these and the Warwick DC proposals will create, cannot be accommodated by increasing the capacity on a few junctions as described as the way in which this can be managed. The pressures on the existing roads are already under strain.

It is important that the character of villages south of Warwick and Leamington do not lose their distinct characters and community cohesion and become suburbs of the two towns.

The figures showing a need for these developments have not been shown to justify these developments. They rely upon unproven demand for movement into the area. Locations to the south of the two towns have extra housing already allocated to them.

This is a letter of objection to the new local plan. Our objections are on two main grounds.

Population. Local requirements are under 6000 houses but the WDC want over 12,000. TheDistrict Council would liketo take a large area of farmland, apparently so they can concrete over all land not built on already, thus creating an enormous housing estate with insufficient schools,hospital beds, drains and sewers and other vital substructures. There would be too many houses with inadequate public facilities.


Traffic: There are already serious traffic problems in a number of places.It remnains to be seen how traffic problems in various parts of this huge proposed development are dealt with. Part of the proposed WDC solution is to have yet more tricky roundabouts working in partnership with traffic light crossroads. Are they expected to overcome not only existing problems but new ones as well?

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.
It also suggests an unfair proportion of proposed Gypsy and Traveller sites in this area particularly in the Parish of Bishops Tachbrook, despite there being brown field sites in the district, (in addition to the vast amounts of Green belt land in the district that would also be more suitable due to infrastructure already in place).

Consideration also needs to be taken to the proposals by Stratford District Council to build a 'New Settlement' of approximately 1,500 new homes at Gaydon/Lighthorne Heath and the damaging affects this will also have on our infrastructure and air pollution levels!! From my own experience of living in Bishops Itchington, people in these villages travel to shop in Leamington for groceries, etc, not Stratford. The town will benefit from increased custom without the need to build excessive numbers of houses in our own district that there is no local need for.

Warwick and Royal Leamington Spa are centres for tourism, not just Stratford!
The proposal to build Gypsy and traveller sites on the main tourist routes from the M40 could affect the visual impact.

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
* increased air pollution in Warwick Town Centre (already at high levels)


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)

I object to the new local plan for the following reasons. We only need 5,400 houses. We do not need 4,000 in Warwick. Increase in traffic congestion and already illegal levels of pollution. Coalescence removing area of restraint. Infrastructure proposals inadequate and insufficient funding available. Increased flood risk. Inadequate sewage capacity. More sewage lorries needed to carry sewage to Coventry. Too many Gipsy sites in south Warwick. Please acknowledge this E mail.

I am writing to object to the new Local Plan. I am absolutely disgusted that Warwick District Council intends to destroy our lovely town by carving up our beautiful surrounding countryside and building houses, turning Warwick and the surrounding area into a massive suburban sprawl. Our area is renowned for being part of 'Leafy Warwickshire'. If the local plan goes ahead then 'Leafy Warwickshire' will be no more. Our surrounding countryside, which has been here for thousands of years, should be protected and safeguarded for future generations, not decimated by this preposterous Local Plan.
Furthermore, it is abhorrent that you are dumping 12,300 houses on Warwick District. Less than half that number would meet local needs. Warwick and its residents will suffer greatly for many reasons. Besides the fact that the appearance of Warwick and the surrounding area will be greatly altered and ruined for people who live in and visit the town, Warwick is designed in such a way that would not sustain any more people and cars. There is not sufficient infrastructure to support such a massive increase in urbanisation; the District Council's predicted funding and provision for other infrastructure such as schools and healthcare facilities etc. is not enough and there would also be risks to the water supply, sewage and drainage.
There is not sufficient infrastructure to cope with any more people, let alone the massive development that Warwick District Council are proposing. Sprawling development is inevitably car-dependent. Currently the roads of Warwick cannot cope with the amount of traffic that passes through it every day. This plan would just be squeezing more congested traffic onto the existing road network, the already buckling old bridge over the River Avon, and in limited parking areas. At the moment this traffic is causing severe air pollution in Warwick and the surrounding area, which is already worse than is legally permitted. The District Council are required to improve air quality, but the plan and its transport strategy would worsen it. Noise and vibration would also be constant and businesses and tourism would be damaged in these tough economic times. Of even more concern is the fact that the long-term health of residents in the town would be even more threatened. It is disgraceful that you are willing to risk the health of the people who already live here just to fulfil the criteria of your ill-informed and poorly conceived Local Plan.
Moreover, the historic environment of Warwick, which attracts visitors from around the world and of which locals can be proud, would be directly damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge (described as being the most beautiful view in Britain), on Castle Hill, and at St. John's; and on the approach to Leamington via Europa Way.
What message are we sending to the world about how we treat our beautiful historic towns? This would undoubtedly have a dramatic effect on tourism and consequently the economy of the area. We should be preserving our heritage, not erasing our cultural identity and destroying the historic integrity of our buildings.
There are better alternatives to this crazy Local Plan. Please reconsider what you are doing to our wonderful town. If the Local Plan goes ahead then Warwick and the surrounding area will be irreversibly damaged and the town that we all know and love will be no more. It is an issue that many of us are concerned and upset about, but you have the power to change this bleak future for our town.

I write to object in the strongest possible terms about the local plans you are looking to impose upon the district.
After looking into the figures of houses and the locations in which you are proposing to allow construction on I object on the following basis
a) Why are the housing numbers so high
Over 20 years to 2011, population growth was 18% now you propose a further 20% increase in the local plan RDS within only 15 years allowing 12300 to be built. Using projections based on natural growth of the population and an allowance for migration only 5400 homes are required (Ray Bullen paper july 2012 updated using 2011 census data in 2013).
Your own consultans G.L. Hearn gave an economic and demographic forecast study in December 2012 and in their option Proj 5 arived at only 4405 new homes required.
The local area has an unemployment rate of 1.7% so if growth for jobs is the reason for building the new homes, this is not required. The 2012 strategic housing market assessment stated that overall "Warwick District had a very good job-homes balance.
b) Visual Impact
Currently Leamington Spa and Bishops Tachbrook are just visable to one another and these developments would in effect join up the two localities into one sprawling urbanisation. Loosing valuable agricultural land and irreplaceable views. The local planning inspector who reviewed the current local plan in 2006 stated that Woodside farm should not be built on now or in the future. WDCs own landscape consultant Rickard Morrish in the landscape area statement refered to the land south of Gallows hill concluded "this study area should not be considered for urban extension and that the rural character should be safeguarded from development. Why has the district council now gone against that recommendation.
c) Local Infastructure
The local plan RDS does not contain any evidence that the proposes infrastructure developments can be delivered from the developer contributions through section 106 and community infrastructure levy.
With so much unnecessary housing concentrated to the south of the town centres surrounding roads will end up severely congested causing pinch points of crossings of canal river and railways where there is no realistically deliverable solution to the problem. Will the village of Bishops Tachbrook have to contend with further volumes of traffic using the village as a rat run, with even more potential for speeding and accidents and potential fatalities.

With all this extra congestion and traffic surely the air quality will suffer causing more pollution being badly damaging to health. The local economy could also potentially be damaged by filling the streets with intolerable levels of traffic and fumes and not shoppers and visitors enjoying their qualities.
d) Housing proposed for village settlements
The local plan RDS also proposes new housing around village settlements. The allocation of housing is proportionate to the categorisation of the settlement. Bishops Tachbrook has been categorised as being one of the largest type, this means that Warwick District council proposes 100 - 150 homes to be built adjacent to the village envelope. Our own local housing survey found a local need for only 14 homes, 10 affordable homes and 4 "market homes" again the figures looking to be imposed on the village bear no resemblance to the local communities ACTUAL needs.
To conclude the local plan does not set a level of house building which meets population growth within the district building homes that people want and can afford. It is growth for its own sake not the local communitys. It does not make good use of brownfield sites for as much as possible for these developments but instead looks to use high grade agricultural land which is sheer madness with food production ever moving up the agenda, as a nation how can we feed ourselves if there is no land to grow food on. The local plan would worsen air quality in Warwick where the level of pollution is already illegal. The rapid growth being proposed would put heavy pressure on schools and the hospitals, perhaps even on water supplies and drainage. I srongly object to these plans and am disgusted that the local community might have these poorly thought out plans, forced upon us by faceless bureaucrats and big business with no regards for local wishes. The elected officials would do well to remember who elected them in the first place.
I strongly object to these plans and wish to place my views on record.

1. The original 2012 Local Plan identified a housing requirement of 10,800 new dwellings for the District. The LPRDS now states that the requirement has increased to 12,300 homes. This is a nearly 15% increase in forecast and we do not see a robust reasoning in the LPRDS for this significant change.

2. The proposed increase of new homes in Hampton Magna up to 150 is likely to result in some 300 additional residents to the village. We are concerned that the existing amenities and infrastructure in the villages cannot absorb this increase without significant improvement. To name just a few:

* Budbrooke Primary School is already oversubscribed;
* the single access road through Hampton Magna and Hampton on the Hill has seen increasing traffic in recent years due to the development of Warwick Parkway Station and its is often used as a "rat run" of speeding traffic to Warwick Parkway station and the motorway links;
* The sewage system is already at capacity and there are a number of areas in Hampton Magna and Hampton on the Hill which are prone to flooding.

If there is any proposal to build new housing in this area then consideration and provision must be made to improve the infrastructure first.

3. It is essential to preserve the rural character and green belt area of Hampton Magna and Hampton-on-the-Hill. This area has already been significantly affected by the development of surrounding road and motorway networks, the railway link at Warwick Parkway as well as Birmingham International Airport. The residents have long suffered increased noise pollution and traffic from these developments, and the District Council has a duty to consider carefully the impact of the proposed new housing and not to devastate this area further.

4. There is already an existing demographic division between the east and west regions of Warwick resulting in variances in schools, local amenities, social and recreational facilities and house prices etc. The Local Plan is an opportunity that the District Council should use to bring down the division and make Warwick a more integrated town. Hampton Magna and Hampton on the Hill already have a high proportion of affordable housing, and to propose a further 150 homes of which 40% are affordable housing will only serve to increase the east and west divide.

5. We understand the need to provide pitches for Gypsies & Travellers which was missing in the original Local Plan. The LPRDS now suggests twenty different sites within the District to accommodate 206 pitches. However, we are not convinced that the proposal has been well researched and thoroughly assessed - it feels more of a kneejerk reaction and a piecemeal approach, yet the locations and sizes of these sites could have long lasting impact on local communities. There are six proposed sites within two miles of Hampton-on-the-Hill amounting to 41 pitches, and some of these proposed sites are very close to main roads which we do not consider as suitable for any residential purposes no matter who they are. We would suggest that pitches should be built on brownfield sites wherever possible, or be accommodated within the development of future new housing areas where all the amenities will be at hand.

The Local Plan is a blue print for the future development of the District and we believe it is also a great opportunity for improving the infrastructure, supporting economic development, enhancing community integration and improving quality of life for the residents. We urge the Councillors and the Council officers to carefully reconsider the number of developments, their locations and the impact on local infrastructure and local community.

I object to numerous elements of the WDC Local Plan. I am not a planner and therefore it has taken considerable time and effort for me to draw together a reasoned response - time that many families simply do not have.

In the public meetings I have attended throughout the Consultation I have been astounded at the insistence of Council officers that the Local Plan in its current form is going ahead irrespective of the public response. What kind of Consultation is that?

I have also yet to hear a solid reason why the greenbelt land north of the river, earmarked in the first draft, is no longer being considered. Limited release of this land would create a more balanced and sustainable urban area.

I understand that fairness is not a planning concern. But the concentration of such a high proportion of the proposed new housing south of the river is completely unacceptable. Aside from the coalescence of settlements this will cause, the strain on local infrastructure, the nightmare traffic and corresponding reduction in quality of life for existing residents, it will impact upon Leamington Town Centre, which will cease to be just that, a centre. If the proposed new levels of housing are built south of the river, this will skew the demographic across the District, the Town Centre will become increasingly irrelevant as new residents access retail outlets and supermarkets located south of the river. At a time when Town Centre retailers across the country are struggling, I am shocked at the District Council's blatant disregard for the local economy and their willingness to plan the decline of Leamington Town Centre.

I would like to object specifically to the following areas of the Local Plan:

Level Of Growth
I am not convinced that WDC's required number of houses is based on sound analysis. Recent projections by respected local planners suggest that the District Council has over estimated the need. I am concerned this has been done for expediency, to ensure the Local Plan is passed upon eventual government Examination. Also, I am not convinced that WDC has effectively exercised its Duty to Co-operate with Coventry in cross-boundary housing provision.

Location of Growth
The Local Plan should make more Green belt releases to the north of Leamington. As mentioned above, a spatial rebalancing of the urban form is required away from the southern edge of Whitnash/Warwick/Leamington. This surely would be sound planning practice, creating a more rounded urban area, enabling greater accessibility for the Town Centres (Leamington and Warwick) with them forming two central hubs. If the proposed developments to the south take place, Leamington Town centre will no longer be 'central' to the District's urban area.

Myton Garden Suburb
The proposed development here will result in a coalescence of Warwick, Whitnash and Leamington. Additional traffic on Europa Way and north under the railway would pose serious concerns.

South of Gallows Hill
This area of land is highly visible and covering it with houses would impact on the backdrop of Warwick castle, damaging the local tourism industry upon which numerous businesses in the local area rely. In planning terms it is not a logical extension of an existing urban form, but instead would create a peninsula of development to the south.

Whitnash East
In the immediate vicinity of this site there are areas of historical and conservational interest which must be preserved. I am doubtful that the cost of relocating Campion School in order to gain access to this site can be justified by the number of new houses proposed.

Warwick Gates Employment Land
I am concerned at proposals that this land be reallocated for housing when there is no other land in the urban area that offers this amount of high quality land area for employment in such an accessible location. Why is the proposed housing density in this area so low?

Woodside Farm
Access to the development is a major concern. A single access point would isolate the development from the existing community and create such a volume of traffic that it would be simply unsustainable. How can the significant cost of highway improvements to provide two access points be justified even if physically possible? The proximity of Ashford Road and Harbury Lane junctions surely precludes access via Tachbrook Road and access via Landor Road is precluded by the current road alignment and lack of vehicle capacity. Our local road infrastructure simply could not cope with the numbers of new cars this development would bring. Increased air pollution and traffic noise are real concerns, alongside the danger posed to pedestrians (particularly children) of residents from the new development using Othello Avenue as a cut through to access local shops. The National Planning Policy Framework clearly states that development will not be permitted where it generates significant road traffic movements unless mitigation measures are used to avoid adverse impacts. I do not see any convincing evidence that mitigation measures will be adequate enough in this instance.

The visual impact of this dense development, 83m above sea level compared with 65-68m for established housing in the area, would be unacceptable, making it highly prominent in the local landscape. Furthermore the fact that some houses will be up to three storeys high raises significant concerns of privacy for existing dwellings. Attempts to mitigate this issue using trees for shielding will likely bring problems with shading and access to natural light.

The area proposed for development has steep inclines, as steep as a rise of 5m in 40 (1 in 8). Flooding from the fields is already a concern for those houses that back on to the Woodside Farm area. Given the density of the proposed housing, I am very concerned about the effect of considerable new water run off from hard surfaces in a new development, and the potential flood risk this would pose to existing housing backing on to it.

Woodside Farm is Grade 2 agricultural land. With growing population rates and domestic food production demand rising, it is fundamentally unacceptable to build on land of this quality when brown field sites are available.

Fieldgate Lane/Golf Lane
How is this site going to be accessed? The junctions at Coppice Road/Morris Drive and Whitnash Road/Golf Lane do not have the capacity to cope with the additional traffic these developments would bring, particularly at peak periods.

I object to the Local Plan - Revised Development Strategy and wish this to be recorded formally and 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 s significant 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 and disabled) and cyclists are not properly considered in the revised local plan when taking into account their needs to cross roads and access shops, services such as doctors, schools and businesses. This applies particularly to Myton Road, Banbury Road, St Nicholas & Smith Streets - especially, given the significant number of residents and visitors and 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 and consequence noise and pollution on the conservation area in the light of its architectural, historic, tourist and environmental importance.

8. Infrastructure - the pressure on local services such as the hospital, social services and education would be too much. They are already suffering. Furthermore, the drainage systems of South Warwick near and 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 and a major re- think of if and 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 and social grounds.

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

This should be a plan to provide affordable housing for local people as and when it is required, it is not. It should provide work for local builders and not see the import of a developer's workforce. This is merely a plan that fits nicely into the requirements and planning of big Developers and Landowners who are willing to sell. The result will be an influx of people from Birmingham and Coventry who will then commute to their employment area on roads not equipped to take the extra traffic. This problem of housing need is exacerbated by the high level of multiple occupancy dwellings within the area serving the local temporary student population. If these properties were available then the need for housing would not be so urgent.

Any local plan should be fair to all residents this is not. It places something like 70% of the proposed development in one area instead of spreading it fairly throughout the district. Areas north of the river are being protected whilst those south are not. The argument used by WDC against using greenbelt land is inconsistent as they are quite happy to approve the use of a large area of greenbelt land to facilitate the Coventry Gateway another project at the moment under scrutiny.

The infrastructure of the whole area south of the river has been under tremendous pressure for a number of years. The proposed road alterations and introduction of traffic lights and traffic calming will not lessen the impact of the increase in traffic from all the developments in the plan. At least 12,000 houses, if not more, with at least 2 cars per establishment it must be obvious the chaos that will ensue.

The resultant increase in pollution from this influx of vehicles will be detrimental to the population, with the resultant pressure on our already fully overtaxed medical facilities. Warwick Hospital is already working to full capacity how can the facilities there be expanded?

The revised Local Plan Proposals of June 2013 that set a target of 12,300 new households in the district by 2029 is too high. The target should be contained within 5,400 houses which are the best projection arising from actual births, deaths and migration in the last 10 years and trends emerging from the changing economic circumstances since 2008. Until this is agreed new applications for houses should be deferred.

As it stands the 2013 Local Plan is a plan to encourage urban sprawl. There will be one massive housing estate stretching along the edge of Whitnash, Heathcote and Warwick, with the subsequent loss of local countryside, agricultural land, and significant open space. Future generations will inherit a massively overdeveloped area and communities blighted by the effects. I think Warwick DC have opted for the easy option - let's dump it all south of the river in one massive sprawl rather than accept there will be more detailed effort to find favourable less intrusive sites. Large Developers are only interested in managing large construction sites to maximize their profits our Planners should not have this as their first priority rather than what is best for the community as a whole.







Anne Steele OBJECTION TO THE REVISED DEVELOPMENT STRATEGY LOCAL PLAN page 2 of 2


The sprawl is already happening, take a walk down Gallows Hill and count the number of cars parked on the grass verges opposite The Warwick Technology Park. Already this area cannot cope with the vehicles required by employees. Hasn't anyone done the maths more than 12,000 dwellings with say on average 3 people per household that's more than 36,000 people?

Schools in this area do not have the spare capacity to absorb pupils although I am aware there are proposals to build schools but I am sure that the houses will come before the schools so where will those children go whilst waiting for the new build? There is no guarantee that the proposed schools will be built. Adding temporary accommodation to existing schools is not acceptable. There will be a significant effect on catchment areas with parents unable to obtain places for siblings of children already at the same school. This is already happening as a result of the recent Warwick Gates development.

There will be an effect on water supplies and drainage. This has been experienced with the Warwick Gates development and such a large area will no doubt have a more dramatic effect. An area can cope with small pockets of construction but not on the scale proposed in the 2013 Local Plan. I have no technical knowledge to quote on this point but can only comment from experience. I understand that Warwick Gates was built on an area with a history of flooding.

The environmental impact on the area seems to have been treated lightly. The whole area has a significant wildlife population Muntjac deer, Hedgehogs, birds not to mention the flora. Also there is the aspect of possible flooding with such a large amount of green land being covered with tarmac and concrete.

Any house building in Warwick District should be fairly spread throughout the district and not confined to one large swath of land as is proposed and be within a more realistic requirement prediction which I believe is available.

I urge Warwick DC to be open minded, listen to the views of residents who will have to live with the effects of any future plans and realize that this plan is unacceptable, 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 - up to 100 homes at Fieldgate Lane/Golf Lane, Whitnash

Warwick DC should adopt the same policy and 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 object to the Local Plan - Revised Development Strategy and wish this to be recorded formally and 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 s significant 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 and disabled) and cyclists are not properly considered in the revised local plan when taking into account their needs to cross roads and access shops, services such as doctors, schools and businesses. This applies particularly to Myton Road, Banbury Road, St Nicholas & Smith Streets - especially, given the significant number of residents and visitors and 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 and consequence noise and pollution on the conservation area in the light of its architectural, historic, tourist and environmental importance.

8. Infrastructure - the pressure on local services such as the hospital, social services and education would be too much. They are already suffering. Furthermore, the drainage systems of South Warwick near and 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 and a major re- think of if and 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 and social grounds.

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

I wish to raise objection to the Revised Development Strategy for the Local Plan for Warwick.

1. The number of homes proposed far exceeds the number required to meet local need. Taking account of births and deaths, a statistical analysis shows a projected figure of 5,400 homes. (ref.The Warwick Society) These could be dispersed throughout the area without the need for a concentration to the south of Warwick. Rather than encouraging in-migration, housing numbers should focus on meeting local need, giving absolute priority to using brownfield and infill sites near schools , shops and railway stations as well as building homes close to jobs to ensure that traffic is kept to a minimum. This could be done in co-operation with other local authorities, instead of competing with them for development.

2. At present unemployment in the area is just under1,400. Any further influx of incomers would drastically increase this, making the proposed increase in population, an unsustainable development.

3. While the National Planning Policy Framework requires the approval of 'sustainable development' to meet 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 alreadt has the five year supply of sites, balancing housing with employment growth and matching the housing market.

4. The land between Warwick, Whitnash and Bishop's Tachbrook is rural and agricultural .It has so far been respected as a buffer zone being an area of restraint. Building on it would create a single suburban sprawl effectively joining Warwick and Leamington and destroying the unique character of each. This green land is as important to both towns as the Green Belt to the North of Leamington and Warwick and it should be safeguarded just as strongly.

5. Suburban sprawl is inevitably car-dependant. Transport strategy is car-based, just squeezing more traffic on to an already congested road network. A recent survey indicates that over 70% of traffic in Warwick is through traffic. Widening Europa Way and various traffic islands including the Myton Road/Banbury Road Junction would not solve the problem as traffic would still need to cross the narrow bridge over the River Avon,and proceed through the narrow historic streets of Warwick town including The Butts, in order to complete its journey through the town. Stopping on road parking in order to facilitate two-way traffic (as has been suggested for Smith Street) will only succeed in killing our beautiful historic town. This is not what visitors come to see. They don't come to sit in a traffic jam as they pass slowly through a congested polluted town devoid of atmosphere and charm. This is not sustainable development!

6. Regarding air quality, pollution from car exhausts in many streets in Warwick town centre and some in Leamington already exceeds legal limits. The District Council is required to improve air quality to meet its legal obligations but this plan would actually exacerbate the situation damaging the long- term health of residents. Recent research indicates that pollution from traffic fumes is closely linked with increased incidence of asthma and is implicated in some forms of cancer. Children walking to and from school and visitors to the town will all have their health threatened by this deterioration in air quality as well as those who live and work in the towns. The District council is legally obliged to ensure that is does not happen and that pollution is decreased rather than being increased.


7. While in theory development would be conditional on it funding schools and healthcare facilities, the Councils predicted funding is insufficient. Additional teachers and Healthcare workers will need to be paid in the future as well as the long term costs of maintaining and heating the buildings. There is also the question of whether the water supply , sewage and drainage could cope with additional demand as well as the very real concerns regarding potential flooding.

For the reasons outlined above, the Revised Development Strategy is unacceptable. It is not 'sustainable development'.

The people of Warwick deserve better.

I feel it necessary to write to you in the strongest possible way concerning the proposals for the development to the south of Warwick especially the area bounded by Myton Road and Europa Way. This land owned by the Oken Trust and King Henry VIII Trust was an area of restraint. Why has this now changed and for that matter who had the right to change it? The proposed desecration of the land is unforgiveable for many reasons which I would like to outline.

The first point to highlight is the vastly extravagant estimate of new homes needed. The projected number far exceeds the reality. Also the fact that the numbers have been quoted up to the year 2029. How can you forecast that far ahead with any accuracy. If we are talking government figures I think we all know what past mistakes have been made through cavalier ministers' ideas and the fiascos which resulted.

Secondly the air quality, which even now is at danger level, would be made even worse by the number of extra cars resulting from all the new inhabitants into the area. This brings me to the third point which is the road network which is barely adequate at present. From my experience Myton Road is virtually at a standstill during the morning and evening rush hours. Even if extra capacity on incoming routes was to be provided, the traffic would still need to cross Castle bridge, Portobello bridge and other roads which is unfeasible. The phrase 'A quart fitting into a pint pot' comes to mind.

The ratio of homes to employment at present, whilst not perfect, is nevertheless manageable. The proposals suggest creating employment to match the need for extra housing. How?

All infrastructure would be affected. Schools, health, water and drainage which all at the present time are stretched would be pushed to breaking point. The land alongside the cycleway off Myton Road is already prone to flooding. Building on this land would exacerbate the problem.

Warwick is a beautiful market town. It is not a city and its residents do not want it to become one huge urban sprawl. This is the reason we choose to live here and for many of us this has been for a long period of time. The suggested area south of Myton Road and bounded by Europa Way is a necessary buffer to keep Warwick as a separate entity. It is good farmland with copious wildlife. Do not destroy it for some Political and Developers Charter.

This is an ill-conceived plan and it has disastrous consequences for everyone. It cannot happen. We as residents deserve our say and we deserve better.

I have read the 70 odd page document and I feel it does not do enough to protect the open spaces and countryside that we currently have in the district. I am shocked at the amount of housing that it is said we need and do not believe these forecasts. In addition I do not believe we should build even more homes than is required if neighbouring districts cannot build their quota, I think this is called "cooperation" in the document!

The document also says it wants to avoid coalescence of settlements yet this is exactly what it is doing with almost 70% of this 12,300 homes being in the south. The only justification I can see in the document is that there was opposition to development on green belt in the north, there is opposition to development on all green belt not just in the north. I live in whitnash and we successfully opposed a plan for 250 more homes and there was major transport concerns yet this was overturned by national government who are agreeing to everything regardless of the impact now and in addition your plan has 600 more homes on this site creating even more traffic, in addition to the thousands of new homes in the south. I do not believe that there is sufficient justification that the majority of the homes should be in such a concentrated area.

I would also like more information on the mitigation on traffic issues, information on here is very light and I cannot find any maps etc.
I think the cycle routes should be improved so people can safely cycle from leamington to Kenilworth or Coventry. Usually homes built have the minimum of everything and I expect that safe communting by cycle will not be available in 2026 and once all these changes have taken place the roads will be even busier.

In addition I do not believe that all brownfield sites have been fully explored, there just seems to be these for current planning applications like the fire station there doesn't seem to be anything or much at all in the localplan which is new development on brownfield sites, why is this, can you explain what has been done to review the sites available?

Unfortunately due to the power of national government to blindly agree to any planning application even if it has significant local opposition and a massive impact of the environment, I am not hopeful that any changes will be made as a result of consultation on the local plan, however I do hope that some of the holes in the plan will be addressed and the inbalance will be addressed