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

I am writing to you in objection to the Local Plan Revised Development Strategy, which is currently the subject of public consultation. I am extremely concerned with these proposals and believe them to be wholly inappropriate and an unfair burden on the small areas of Warwick district that will be affected by these developments. I expect you to respond to all of my concerns in detail, justifying your "Revised Development Strategy" with factual and appropriate data. My concerns can be summarised as follows :-

New Housing


Number Of Houses & Impact To Local Infrastructure.

In the 20 years to 2011, the population growth in our area has already been unnaturally high at 18% due to the high level of new housing. This has seen a significant number of new people migrating to the area, many of whom do not work in the vicinity. This is already placing an unacceptable and unmanageable burden on the local infrastructure which in turn is having a negative effect on the local inhabitants. To propose a further increase of 20% over the next 15 years is not only inappropriate but also irresponsible toward all of the existing residents. It is quite clear that the local infrastructure will not be able to manage as it is already failing to cope with the existing levels of traffic resulting in congestion ranging from long slow moving queues to complete grid lock Monday to Friday during rush hour and also on much of Saturday. Significant data is readily available in the public domain that proves this to be the case (Appendix E of the Warwick Strategic Transport Phase 3 Assessment). Typical proposals of widening and adjusting existing roads and junctions will not resolve this problem as is clearly evident around the site of the old Ford foundry which is already a traffic congestion black spot since its completion a few weeks ago. Unless major new roads are built with additional crossings over the natural barriers of the River Avon, River Leam and the railway then your proposals for improving the road infrastructure to cope with these extra homes will fail. Such major developments to break these traffic bottle necks will not only be inappropriate in the areas of Warwick and Leamington due to their aesthetic and environmental impact but will also not be financially viable.

All of the major amenities (shops, hospital etc) are located on the opposite side of the river in either Warwick or Leamington. This means that the existing bridges will become a major bottleneck due to the increase in traffic. For example, Castle Bridge in Warwick has a capacity of 900 cars per hour, a figure which is already exceeded on a regular basis, indicated by the subsequent congestion that occurs. The capacities of the other river crossings in the area are likely to be similar. In addition, the adjacent roads leading to and from these river crossings are also restricted and regularly congested.

The siting of 4000 houses between Warwick Gates and Bishops Tachbrook will also result in large amounts of traffic using the M40. The roads that link the two M40 motorway junctions with this area are not capable of coping with this extra traffic capacity.

I therefore challenge you to demonstrate how the current road infrastructure can cope with an extra 12,300 houses or state in detail what changes to the infrastructure you plan to make in the same timeframe to support these additional dwellings.

In addition to the road infrastructure problems, there is also no indication as to how other key infrastructure improvements will be delivered in the same time frame. An increase in population of circa 40-50,000 that 12,300 homes will bring will require additional capacity for the hospital, doctors surgeries, schools, public transport, police and fire services etc. How will these be delivered in the same time frame as 12,300 houses and how will these be funded ?

Housing requirements based upon the natural growth of the population indicates that only circa 5500 new houses are required and not the 12300 being proposed. A recent housing needs survey in Bishops Tachbrook identified a total housing need of 15 additional properties (from a response rate of 500 homes from a total of 750 in the village). So based upon this, why are so many houses being proposed in the locality of the village ? Building an artificially high number of houses will simply encourage more migration to an area which is a nicer place to live than many inner city urban areas. There is also little need to create more local business and industry in the area since the unemployment rate in Warwick District is only 1.7% so if this is reason being used to justify the number of new houses proposed this is also inappropriate and flawed. Building an excess of new houses will promote more commuting which is something that is already causing a major problem in the area through traffic congestion.


Location Of Proposed Development

It is wholly inappropriate for a few small areas of Warwick District to shoulder the entire burden of the number of houses being proposed. This will guarantee that a small amount of the current population of Warwickshire will be significantly and unfairly affected by the building of these new homes while the majority of the district will not be affected in any way at all. Warwick district is a large and diverse area and the burden of extra home requirements should likewise be shared across all of the district's towns and villages calculated by conducting simple housing needs surveys as already completed in Bishops Tachbrook.

The visual impact of 12,300 houses in the rural area of Warwick District will be very significant, particularly those being proposed on the higher greenfield lands south of Harbury Lane. To back this up, during the previous round of proposals to build new houses in the area, a government planning inspector stated that "no build now or in the future" should occur at the site of Woodside Farm. WDC's landscape consultant, Richard Morrish also referred to the land south of Gallows Hill that "this study area should not be considered for urban extension and that the rural character should be safeguarded from development".

The building of these extra homes in such few areas will decimate two historic villages, Bishops Tachbrook and Tachbrook Mallory. Your previous "Preferred Vision For Warwick District to 2026" contained quotes and statements which are clearly breached by the proposals now being made one of which related to the importance of retaining this rural area, an example as follows :-

"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."

This is a rural community. The building of 12,300 additional houses in this area will result in significant parts of it ceasing to be rural !

My personal view is that you have proposed to build these houses in such a few areas to reduce the overall cost of the project and to limit the number of people that are affected (and hence those likely to object). This then makes it easier for you to secure developers whilst limiting the amount of "fallout" and "challenge" you receive from the residents of Warwick District. Spreading the number of required houses across all of the District's towns and villages would significantly reduce the impact of those houses on the local infrastructure. This is therefore an example where cost and ease of execution have taken priority over what would cause least impact to the District as a whole and therefore be in the best interests of the Warwick District residents.


Location Of Proposed Development Near To Bishops Tachbrook.

Whilst I am in favour of retaining green space between Bishops Tachbrook and the houses proposed South of Harbury Lane, there is little point in this if it results in a major development being within a few hundred yards of the village and being on an elevated site. This will have the affect of dominating the village both aesthetically and from a noise perspective. This area of restraint should be from the Harbury Lane which already forms a natural juncture between the development of Warwick Gates and the "green field" areas surrounding Bishops Tachbrook and Tachbrook Mallory. Any breach of this existing boundary by large housing developments will challenge the criteria of a village and hence negate the green space acting as an "area of restraint" It will also make future development of what will be a smaller area of undeveloped land between the new development and Bishops Tachbrook more likely. I consider the current distance between Warwick Gates and Bishops Tachbrook to be a minimum of that required to protect and maintain Bishops Tachbrook and Tachbrook Mallory as villages. The area of restraint also does not give any protection to the existing mobile home park off Harbury Lane. This is destined to be completely engulfed. Why is no area of restraint being afforded to this existing development. Again, maintaining the current natural boundary of the Harbury Lane as the edge of the area of restraint would also protect these local inhabitants.

The filling in of the various vacant areas around the Warwick Gates site would provide sufficient extra housing in this area if the overall burden of the required increased housing is spread across the whole of Warwickshire as I have previously suggested. The village of Bishops Tachbrook could also accommodate its own requirement for new houses which has already been determined through a housing needs survey.

The reason why I am so passionate about Bishops Tachbrook remaining a real village and not just by name is that it enjoys all of the benefits of an English country village. The local children go to the local school, this then ensures that the adults mix and communicate with one another. The local parents help out at the school, they also run Brownies, Rainbows, Youth Club etc. These organisations then support the local church and vice versa. All of this ensures that the village is a safe, happy and rewarding place to live. This is not something that can simply and easily be created but it can be very easily lost. All of these things will gradually fade away if the village loses its identity. The development of Warwick Gates is a good example where, due to a lack of up front planning and foresight, there is precious little sense of community and engagement between the residents.

The Bishops Tachbrook local history group recently wrote a complete history of the village and sold over 700 hundred copies. I encourage you to read it. You will then get some indication of the depth of feeling towards the village and the number of people who consider it something worthwhile that should be protected. It has developed as a village since before the Norman Conquest (1066) and should not be allowed to disappear into a mediocre suburb of Leamington Spa as Warwick Gates has become.


Use Of Green Field & Brown Field Sites.

In light of the current need to protect the environment as much as possible, it is essential that brown field sites are used for future housing development prior to the destruction of further green field areas. Your plans do utilise a proportion of brown field sites however, as you are planning to build houses in such few areas of the county this is therefore limited. There are also significant brown field sites that have not been proposed. The now defunct Coventry airport site is of significant size which could be utilised to build houses. There are also several smaller areas in the Leamington and Warwick areas such as the Leamington "Arches" area.

I challenge you to confirm the total area of brown field sites within the county and explain why all of these cannot be utilised to provide the necessary building land for the extra houses required to avoid further use of green field areas. Unless it can be shown that there are insufficient brown field areas in Warwickshire and the surrounding West Midlands, it is wholly inappropriate and irresponsible for you to be proposing the use of any green field sites whatsoever.


Gypsy & Traveller Sites.

With regard the proposed gypsy and traveller sites around the Bishops Tachbrook area (Nos 3, 4, 5, 6, 9, 10 & 15) I have the following objections based upon the fact that they do not comply with the Travellers Consultation Document :-

* Sites 3, 4 & 6 are very remote from major amenities.

* Sites 5 & 9 only have access onto a busy road, have no pedestrian access and could result in unacceptable visual impact to Warwick and the listed buildings also on this side.

* Sites 6 & 9 have no pedestrian access.

* Site 10 is close to the Guide Dogs for the Blind National Breeding Centre and so any site could interfere with their sensitive breeding activities ref noise, site contamination (due to business activities) etc. It is also remote from major amenities and has no pedestrian access.

* Site 15 is located on the banks of the Tachbrook so there is a risk of contamination from the site (ref acknowledgement that business as well as domestic activities are likely to occur on the site.

In addition, the school in Bishops Tachbrook Parish is only a single form entry and is fully subscribed in many years. It is therefore not capable of providing schooling for extra 10-30 extra children from local traveller sites.

One area that has not appeared on the list of suggested sites is the caravan / camping site that was installed on the Banbury Road south of Warwick near to Temple Hill Spinney. This area was developed into a campsite / caravan site some years ago and has been unused ever since. A suitable junction and pedestrian access has been provisioned for and its location is close enough to the amenities of Warwick to make this an appropriate site. I don't know if this is a private site or if it was developed by the local authorities. If it was the latter then it is a disgrace that this site has not been used since its creation and demonstrates a total waste of local tax payers money. Its use as a gypsy / traveller site would provide at least some value from the monies already spent. As a brown field site it would also constitute a lesser impact on the development compared to some of the other proposed sites.

In the same way that I expect brown field sites to be used for the proposed 12,300 houses, I also expect you to do the same for the gypsy and traveller sites. There are sufficient sites available for this (Nos 17 & 18 for example). Until all the brown field sites in the district have been used, it is irresponsible and unacceptable for you to be proposing green field sites as an alternative. The environment is coming under increasing pressure and by proposing green field sites you are maximising the amount of this pressure.

Overall I expect you to only propose and develop areas that comply with the Travellers Consultation Document and that have a minimal impact to the environment and those existing residents of Warwick District. Any that don't comply should be removed from the proposal list.


I look forward to your response to my challenges and questions.

As a resident of The Butts, Warwick I am totally against the proposals that have been submitted for the development of housing on the green land close to Warwick for the following reasons:

The projected housing needs of 12,300 new homes to be built is much too high and cannot be justified.

The transportation strategy is car based and will simply be squeezing more congested traffic on to the existing road network which is already totally inadequate for the town.

The additional pollution from the increased number of car exhausts will create even more health problems for the residents of Warwick, and particularly those living on The Butts. The air pollution is already significantly above the legal limits. - This is a major concern that concerns us and as we work with leading respiratory professionals around the world have sought their advice accordingly. The long term health of Warwick residents would be severely threatened. WE thought that it was the responsibility of the District Council to improve the air quality not worsen it.

The additional noise and vibration would be a constant and would damage not only businesses and tourism in the town but also the historic properties throughout Warwick.

The alternatives:

Lower the housing to be built to meet local needs, and especially houses that local people could afford.

Revise the transport strategy that hasn't been thought through clearly at all, to ensure that the number of cars simply passing through the town are reduced not increased, which in turn would also improve the current illegal air pollution within certain streets, The Butts being one of them.

I am writing to object to the Local Plan, Revised Development Strategy. This objection is based on a number of points.

First the plan advocates 12,000 new houses over the period of the plan, when the number required to meet the additional needs based on 2001 and 2011 census plus the increase in Warwick over recent years would indicate a figure of the order of 5,500. This majority of this level of development could be met by utilising land currently earmarked for development and developing brown field sites, without the major development of 4,000+ houses to the south of Warwick.

The requirements of the National Planning Policy Framework include the need for economic, environment and social sustainability. With the likely increase in employment opportunities arising from 22.5 hectares of land for employment being of the order of 2,000, there appears to be an imbalance with the potential inward migration of 10,000+ people who will be seeking employment. The only solution to this imbalance is that these people will seek employment in the surrounding area of the West Midlands with the result that there will be a significant increase in the traffic flow through Warwick Town Centre. With regard to the social and environmental sustainability the area through which these vastly increased vehicle numbers will travel is one of environmental sensitivity and a major conservation area, including a bridge over the River Avon which was opened in 1793 and is a major tourist viewing point for Warwick Castle.

There will be a major increase in the volume of traffic travelling into and through Warwick Town Centre, in the process passing a number of schools, nurseries and play areas with the subsequent increase in pollution due to the restrictions of the 18th Century Bridge already mentioned. The Air Pollution in the town centre is currently above the legal limits, by the authority's own figures, and this increase can only exacerbate the situation. In addition this increase in traffic can only result in slower progress through the town with more hold ups and jams with the knock on effect being people being unwilling to stop in the town or wish to shop in such a heavily congested area thus invalidating any economic sustainability claims.



3A major omission from the plan would appear to be the actions taken in respect of the increase in population on the provision of schools, health services and public utilities other than reference to Myton and Campion being expanded and primary schools being provided. Recent developments in Warwick District have promised such facilities as part of the justification, however people living on these new developments have waited significant periods of time for delivery.

A final point is the fact that Stratford district are proposing significant development to the south of Warwick at Gaydon. This will affect any employment opportunities in the south of Warwick district and add to the flow of traffic into and through Warwick Town adding to the problems created by the Revised Development Strategy.

For the attention of the Development Policy Manager

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

Air Quality

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

Transport

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

Projected Housing

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

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

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

Historic Environment

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

Funding

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

National Planning Policy

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

Gypsy Sites

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

Consultation Process

I was most concerned to hear at the meeting that these plans had been pushed through by councillors who do not live in the area and that politics were possibly involved in the decision making?

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

WDC REVISED DEVELOPMENT STRATEGY LOCAL PLAN OBJECTION

I strongly object to the latest local plan published by WDC for the following reasons.

Any plan should accurately reflect the population growth and demand within the district taking into account the latest data from the `Office of National Statistics`. The proposed plan is thought to massively overstates the demand.

The situation has been made worse in South Leamington and Whitnash by the `immigration` of students from Warwick University.......which is 10-15 miles away, dependent on route - and in Coventry! Many `low-cost` properties suitable for `first time buyers` have been bought to let and been used to accommodate students. Whitnash also currently takes a higher level of Immigration compared to other areas.

Healthcare and education provision is already virtually to capacity.

Transport - at times the roads in this area are exceedingly busy and hazardous around schools especially. If the schools are extended any further then the roads will be impassable at certain times of the day, particularly Golf Lane, Coppice Road and Morris Drive around Briar Hill and St. Margaret`s schools. The potential developer of the Fieldgate Lane area admitted that their traffic survey failed to measure the traffic at the peak time of day i.e when parents are all arriving to collect their children at the same time - around 3pm.

The plan shows the most significant development focussed on the area south of the river. The `green belt` argument used to limit development to the north of Leamington is artificial. `Green belt` status is man-made, created some years ago to meet the needs of the time, and should be varied when circumstances change. An even and fair distribution of new housing across the district is needed.

There is still much `brown field land` in the wider area e.g Baginton and Ryton. Land has been set aside for yet another fuel filling station adjacent to the new Morrisons store.

I object specifically to the proposed development of the field adjacent to Fieldgate Lane / Golf Lane field for the following reasons:-

Drainage / potential flooding

A neighbour has evidence of the flood risk status of Fieldgate Lane which shows that we are within 250m of an area prone to flooding (zone 3).
The drainage channel in Fieldgate Lane connects directly to the Whitnash brook in the flood zone.
The normal flow in the Fieldgate Lane drainage channel is negligible but several times a year at times of heavy rainfall the water level reaches within a few centimetres of overflowing the channel. On several occasions water has come over the top, flowed along Fieldgate Lane, down driveways and has reached as far as garage doors.
The slope of the field and loss of the water soakaway due to development must result in additional water in the drainage channel at peak times.
We have already had house insurance declined by one company on the grounds of flood risk.

We also have the situation several times during a normal winter when the ground is waterlogged to the point where we can have several centimetres of water standing across our gardens and this can take a considerable time to drain away. Fieldgate Lane also often floods with running rain water to part way up the kerbs for short periods during heavy rain. These are actual events seen by local residents.

Currently the field regularly floods in the north-west corner and along its north edge several times a year during heavy rain. Development of roads and hard standing on this sloping site will inevitably result in more runoff towards the Fieldgate Lane drainage channel and will make the current situation much worse.


Traffic hazards
The entrance to Golf Lane from Heathcote Road has long been considered a hazard and, I believe, has formerly been the prime reason for not allowing further development. The main issues are :-
... this part of Golf Lane is on a steep slope and is relatively narrow.
....visibility to the right is restricted when exiting Golf Lane.
....the junction with Home Farm Crescent is at the bottom of the slope, on a bend and visibility is again restricted when turning right into Home Farm Crescent.

The junctions at Morris Drive/Golf Lane, Golf Club entrance/Golf Lane, Golf Lane/ Fieldgate Lane corner and Mullard Drive/Fieldgate Lane are areas which residents consider hazardous. At all of these junctions the issues are the same in that many drivers come through them not expecting to meet other traffic. It is not just strangers who don`t know the roads, but local drivers who only expect traffic from a particular direction. We are aware of the hazards and usually drive through these junctions at around 15mph but regularly have near misses. Many local drivers ignore the road signs and markings and residents can quote daily incidents.

At school times the traffic situation in Coppice Road, Golf Lane and Morris Drive is hazardous and Police are regularly in attendance. Children already have significant difficulty in crossing the roads through parked and moving traffic. We are aware of at least 2 serious incidents outside the schools.

Traffic lights at Heathcote Road/Tachbrook road are already at capacity at certain times of the day with traffic often queuing back several hundred metres.

Traffic flows have recently been measured as part of an application to develop the Fieldgate Lane field but this failed to measure the traffic at school closing time as it was not considered to be a busy time of day. In fact this is the most hazardous time of day and additional traffic from the proposed site will make it worse.

Schools
The local primary schools have been at capacity since the advent of Warwick Gates, and there are regular appeals to accessfavoured secondary schools. Any additional housing locally which fails to increase provision will make the situation worse.

Ecology and wildlife
Bats - there are numerous bats of several species which feed around the local houses and over the Fieldgate Lane field every night during the summer months and sometimes at other times of the year. The roost sites are not known but are certainly local.

Birds - many species use the field continually. My husband has records of 47 species using the hedgerows and fields in Fieldgate Lane alone including Tawny Owls, Herons, Lapwing, Snipe, Buzzards, Sparrow Hawks, Woodpeckers, Bullfinches. In winter time there are migrants including redwing and fieldfare.

Mammals - the field is used by deer, fox, hedgehogs (a declining species) and several species of small rodents. There has been a suggestion of badger activity.

Ridge and Furrow system - the field is a rare and disappearing example of the medieval ridge and furrow system of historic importance and should be preserved.

General
Formerly, the Fieldgate Lane site has been considered unsuitable because of the slope and its contribution to potential flooding. The angle of slope will also mean that the view from Fieldgate Lane properties will be of a succession of house ends and roofs increasing in height up the hill, particularly in winter when there is no foliage on the trees.

The site is an `Area of Restraint` in the current local plan - for many of the reasons quoted.

A current planning application shows the access road immediately opposite our property in Fieldgate Lane This would result in major disruption to access to our property, parking and our way of life for several years. The slope of the land will mean that, at night, headlights will shine directly at our living room and bedroom windows.

Dear Sir

WARWICK DESERVES BETTER

I am writing to object to the Local Plan, Revised Development Strategy. This objection is based on a number of points.

First the plan advocates 12,000 new houses over the period of the plan, when the number required to meet the additional needs based on 2001 and 2011 census plus the increase in Warwick over recent years would indicate a figure of the order of 5,500. This majority of this level of development could be met by utilising land currently earmarked for development and developing brown field sites, without the major development of 4,000+ houses to the south of Warwick.

The requirements of the National Planning Policy Framework include the need for economic, environment and social sustainability. With the likely increase in employment opportunities arising from 22.5 hectares of land for employment being of the order of 2,000, there appears to be an imbalance with the potential inward migration of 10,000+ people who will be seeking employment.

The only solution to this imbalance is that these people will seek employment in the surrounding area of the West Midlands with the result that there will be a significant increase in the traffic flow through Warwick Town Centre. A recent traffic survey has calculated this to be 76% thereby increasing congestion and noxious fumes in the area.

With regard to the social and environmental sustainability the area through which these vastly increased vehicle numbers will travel is one of environmental sensitivity and a major conservation area, including a bridge over the River Avon which was opened in 1793 and is a major tourist viewing point for Warwick Castle.

There will be a major increase in the volume of traffic travelling into and through Warwick Town Centre, in the process passing a number of schools, nurseries and play areas with the subsequent increase in pollution due to the restrictions of the 18th Century Bridge already mentioned.


The air pollution in the town centre is currently above the legal limits, by the authority's own figures, and this increase can only exacerbate the situation.
In addition this increase in traffic can only result in slower progress through the town with more hold ups and jams with the knock on effect being people being unwilling to stop in the town or wish to shop in such a heavily congested area thus invalidating any economic sustainability claims.

A major omission from the plan would appear to be the actions taken in respect of the increase in population on the provision of schools, health services and public utilities other than reference to Myton and Campion being expanded and primary schools being provided. Recent developments in Warwick District have promised such facilities as part of the justification; however people living on these new developments have waited significant periods of time for delivery.

A final point is the fact that Stratford district are proposing significant development to the south of Warwick at Gaydon. This will affect any employment opportunities in the south of Warwick district and add to the flow of traffic into and through Warwick Town adding to the problems created by the Revised Development Strategy.

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. 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 ore evenly (even if the number of houses required is a correct projection). Projections are estimates and surely it is better to make smaller incremental changes rather than sweeping over-reaching change, which may not be needed or desirable. The Ray Bullen paper in 2012 stated that ONLY 5400 would be required (not all at once) , which is more than 50% less than the now increased number that WDC are suggesting of 12300.
2. Why are brownfield sites not being utilised before new greenfield developments - is it "easier" for developers to go for greenfield sites?
3. 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 Warwick
4. 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.
5. 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 and akin to Milton Keynes or similar, 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. Towns and villages evolve they are not dropped into some Greenfields, 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.
6. 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

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 (see 1 - 3 above) 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.

I am oposed to the level of deveopment planned for Warwick and the area to the south. I do understand that there is a need for housing develoment and that many first time buyers cannot find affordable housing. The new planned housing is not aimed at these people in the main. The likelihood is that these houses would attract people from urban centres aiming to live in the country while continuing to work in the urban areas. Soon our countryside will also be urban. When road congestion and enviromental concerns are seen as detrimental to the health of the planet you will be adding to both as people commute to work.
How many properties already in existence in towns and cities are unoccpied, what sites could be redeveloped.
Barford is a village with few amenities, no doctors, dentists, library and onlt the village shop manned by volunteers. We have recently had quite a large development of housing to assimilate, The accompanying office devlopment lay largely empty for months, further development will change the villge into a small town. We have witnessed this happen in Wellesbourne, soon we will not be a villge and another bit of our heritage lost forever. There are many houses upfor sale here and have been for months, if the need for housing was so great they would have been snapped up readily.
Traffic through the village at peak times is horrendous, try crossing the road! The increase in traffic is going to make this situation worse and there is no way it can be improved.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

see attachment

We are writing to object to the Draft Local Plan concerning the development of housing at sites south of Warwick and Whitnash.
The reasons we object to these plans are:
* There is far more housing planned for than is actually required. The plan would increase the population by 20% within 15 years. This is far more than would be needed to cater for a natural increase in population in the area. A study by Warwick DCs own consultants gave a figure of 4405 new homes being required.
* The plan concentrates most of the new housing into the area south of Leamington Spa and will result in there being almost continuous housing estates between Warwick, Leamington Spa, Whitnash and Bishops Tachbrook. Much of this land is currently agricultural land. There seems to have been no consideration to providing a more equitable distribution of growth across the county.
* There will be an adverse visual impact in the area. This will change from being a pleasant, green area of the county to a large urban sprawl of housing estates making the area less attractive for the current residents and also to people thinking of moving to the area.
* There will be an increase in traffic to the north (into Leamington and Warwick) and to the south (onto the M40/A46). Traffic is already very heavy in these areas.
* The levels of air pollution are already illegally high in Warwick and the building of this large number of houses, with the increase in traffic this will also bring, can only make this worse.
* Warwick and Leamington Spa town centres will suffer from more congestion and poor air quality as a result of the massive increase in population in the area. This will make the towns less attractive to visitors and shoppers.
* There will need to be significant investment in the local infrastructure to support the influx of such a large number of people to the area. It is not clear how this will be achieved.

We were shocked and appalled to read of the development proposals to this area. We moved here recently after five years looking for somewhere to live in this area. We chose Bishops Tachbrook as it is in a beautiful location with outstanding views and beautiful countryside on our doorstep. We chose this area as it has just the right balance of amenities, housing, retail parks, two historic town centres and beautiful countryside. It seems a shame that the District Council is planning to destroy what makes the district so appealing.

Please accept this objection in addition to any others as it contains other information that has come to my notice.
1. There is no supporting Local Plan to allow this application.
2. The existing 2007 Local Plan is still in force and is still relevant to this application.
3. This application has been made by the developer knowing that the current Local Plan would not support it.
4. The application by the developer/land owner has been made with prior knowledge that a new Local Plan was under consultation but not approved.
5. The application is for 220 dwellings but makes no reference to the phasing over the next 17 years. As this is common to all applications that have been made and most likely will be made then it should fail on this point and be rejected.
6. WDC should have made this clear in any discussions with developers but failed to do so.
7. The NPPF came into force in 2012 and should not be assumed or considered to be out of date.
8. WDC have identified and recommended this site as being acceptable for development without any consideration of the harmful effects on the surrounding neighbourhood.
9. This application must not be taken in isolation. It is part of a large number of present and future applications to satisfy WDC's poorly researched information on housing numbers. This may be due to numbers they have accepted from the Minister of the Environment or their own numbers from GL Hearn.
10. The 12,300 is the latest number that is now being quoted by WDC. This has been challenged as being pure guesswork without any positive proof. It has been suggested that 5,400 is closer to the truth following work by a local councillor.
11. It is not being truthful or fair of WDC to invite individuals to object only to the application sites adjacent to their homes, as indeed that is the case of this development. They should be objecting to the total applications under the umbrella of the Local Plan. If that is seen as unsustainable then all applications should be rejected.
12. WDC have put themselves in the position of having to consider many applications to build a large number of houses. It is now a rat race by developers as to who can get in first. This should not be run on a 'first come first served basis'. Applications should be in abeyance until after the Local Plan has been properly consulted.
13. Consultation meetings I have attended all have the same theme. That is to give the public details of what has been decided and ask for questions. There is indication that the massive objection that is taking place will stop the intention of the Local Plan.
14. The Local Plan as seen by the public for the first time was in its final and intended form with no facility to consider alternatives. Therefore it is not a consultation document seeking approval. Rather it is a statement of intent. This must be referred to a Public Enquiry.
15. There are alternatives to creating urban sprawl. A - Proportional distribution throughout the district over 90 to 100 small sites in or adjacent to villages, with no increases for Leamington Warwick and Whitnash that have received the bulk of development over many years. B - Two or Three medium isolated sites to the North, East and West of the District with zero housing South of Leamington and Warwick. C - A new town in Green Belt that is completely independent of neighbouring towns and villages. This would be a challenging but exciting alternative that would give established towns and villages a chance to stabilise.
16. It has never been made clear by WDC that they have supported or facilitated the applications by various developers even though they deny this.
17. WDC are aware that the Local Plan now under consultation has not changed from the previous 2007 Local Plan and are now attempting to convince the public it is a viable and acceptable plan.
18. WDC are in full knowledge that this application is just a part of a massive urban sprawl they have recommended as being suitable for the 12,300 houses they have stated are needed to 2029, without any proof of the needs of those houses.
19. WDC have failed to recognise the severe impact on the present incumbents of a very large area South of Leamington and Warwick that the combined applications would have. So this application like all of the others must not be permitted.
20. By encouraging the various developers (including Gallagher Estates) to submit applications in order to show that the 12,300 houses are deliverable they have effectively isolated each development application from the residents who are not directly joined to every site.
21. By not carrying out a fair and just consultation on this application and con-joining it as part of the overall intent of the New Local Plan, WDC are minimising the effects on the unwitting public of all the applications when combined under the 'Master Plan' .
22. The consultation period for the Local Plan has been extended after public protest. There is still not enough time to complete an effective consultation because of the large area covered by the Local Plan.
23. This application must only be judged in combination with all other present and known future applications. Each application must be placed in a Local Plan Group and considered as such.
24. If the 12,300 number is successfully challenged and kept within a suggested 5,400 this total can be shown to have satisfied the 5 year and beyond requirement.
25. This application being part of the New Local Plan that is to provide housing needs up to 2029 is for 280 dwellings. That should only permit an application for 17 houses each year. Any application in excess of that should be rejected.
26. The laws of supply and demand should be accepted as being the meter for providing houses for those who not only need them but can afford them. The 12,300 number being quoted by WDC is a mythical number with no proof. Therefore the New Local Plan should have recognised this fact and factored the numbers accordingly.
27. Owning a house is the biggest single commitment anyone takes. It is undeniable that of all those who want a house, there will be many who will never afford to do so. Their only recourse is to rent. The houses in this application (and all others) are not aimed at the low cost rental market.
28. The number of people living in the vicinity of 75% of the 12,300 houses who need or will need a house do not represent the need for this number of houses. The truth is that developers are speculating on selling these homes to anyone outside of the area who can afford them. WDC should have recognised this and should only allow developments that are for the local people
29. A result of the above, is that anyone who lives in the area concerned who will be looking to buy will not be able to do so as they are out of their price range.
30. This application will destroy the protecting green area that protects the ancient town of Whitnash. There is considerable wildlife in the neighbouring woodland and the farmland that will be gone forever. This is important and needs protection.
31. The actual site of this application will further disruption to an already extremely busy road.
32. A further proof of supply and demand is that the estate agents are overflowing with houses for sale, but only a few that are affordable.
33. Another fact is that present house owners wishing to move or upsize cannot afford to due to the squeeze from government spending cuts. Their only answer is to extend and even that is very restricted due to the high costs involved and petty restrictions imposed by District Councils.
34. Warwick District Council should not cave in to government demands but should use the ability of elected councillors and the public to protest to the Minister of the Environment.

BPC has carefully considered the paper by Ray Bullen, which was supported by Rural Parish Councils, and the response from WDC on 18th July 2013. Budbrooke Parish Council regards the overall estimated residential development growth in the Local Plan to be significantly out of proportion to the local need.

The District Council has failed to acknowledge, address or take account any of the issues identified in Budbrooke Parish Council's response to the first consultation in this second document.

In respect to development in Budbrooke:
* All proposed development is in the green belt and there are no special reasons for using the green belt [reference: NPPF 2012 development in green belt is inappropriate.]
* Taking land out of green belt for development, i.e. re-drawing green belt boundaries, is tantamount to a gross misapplication of NPPF 2012. To do so is not a special reason.
* Loss of green belt will mean a loss of prudent use of land potential loss of value to special/ high landscape value
* Identifying potential sites in green belt, when there is other unused land outside the green belt and outside the local plan, constitutes a breach of NPPF 2012, referenced above.
* Budbrooke Parish Plan has not identified any significant demand for development locally.
* Hampton Magna is surrounded by high grade agricultural land
* Negative effects on strategic siting such as increased levels of traffic
* Air, Light & noise pollution will increase especially in the construction phase
* Presence of Railway will be a nuisance to potential development

People live here because they like the area, any development, and in particular an up to 25% increase, will have a significant impact on the nature and locality. This issue must be considered as it has previously been accepted by WDC in its dealings with other councils.

Capacity of the Infrastructure
Hampton Magna was built on the site of an army barracks in 1960s to the standards that prevailed at that time. Little or no improvement has been made since the site was first built on.
* Minor road improvements were made to accommodate a substantial increase to traffic due to the building of Warwick Parkway Station. Car parking since originally built has increased 3 fold with no change to roads or traffic management.
* Consequently, traffic is already extremely heavy. Approaches - Birmingham Road, Old Budbrooke Road, Woodway, Church Hill and roads to Hatton via Ugly Bridge, and through Hampton on the Hill. Any additional development will have a considerable negative impact on roads and traffic
* Traffic issues have not been addressed or even assessed
* Sewage arrangements is a major concern of the PC - Although adopted prior to privatisation the system falls below the standard normally required.
* The main local electricity supply arrangements area the same as those for the barracks which left nearly 50 years ago. Supplies into the village are subject to frequent fluctuations and outages.

Budbrooke School, with only around 50% children resident in Hampton Magna, already draws traffic from surrounding areas -Hatton, Hatton Park, and Chase Meadow - and the county lanes are increasingly congested and hazardous. Increasing the size of the school to accommodate the 25% increase increases the congestion and hazard, and fails to address the Green Agenda unless additional resource is allocated in the current catchment areas, which idea has been discounted.

Sustainability
The argument that additional development will help address the sustainability of local facilities and services is flawed. There is no evidence that this would be the case.

We cannot find any justification for sites in Hampton Magna.

A new Local Plan will be examined by an Inspector to ensure compliance with the NPPF.
6. says "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system."
The plan will have to be sustainable in these terms.

2. The existing 2007 local plan is, by virtue of NPPF 211, "not to be considered out‑of‑date simply because it was adopted prior to the publication of this Framework." And further NPPF212. says "However, the policies contained in this Framework are material considerations which local planning authorities should take into account from the day of its publication. The Framework must also be taken into account in the preparation of plans."

3. NPPF215 requires that "due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework (the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given).

4. The existing local plan was adopted in 2007 following a Public Inquiry during 2006 into objections to the proposed plan. The Inspector produced a 562 page report. Some of the issues are relevant to the new local plan proposals. Some senior Planning Officers seem to be of the view that because the current local plan was adopted in 2007 under the 1990 Town & country Planning Act Part II, it is of less value than a plan adopted since 2004. It needs to be pointed out that the Planning & Compulsory Purchase Act 2004, which came into force on 13th May 2004, did, by virtue of Schedule 6 of that Act, amend the Town & Country Planning Act 1990 to take into account changes made by the 2004 Act. So, for the purposes of NPPF214, it was in accordance with the Planning & Compulsory Purchase Act 2004 when the current local plan was adopted in 2007.

5. The local plan was adopted only 6 years ago. It settled many questions of concern for the community, in effect setting a contract with the community, up on which many people made decisions about their lifestyle arrangements. The Revised Development Strategy with a dramatic change to the size of the district and the concentration of very large amounts of new housing on land that is currently subject to Rural Area policies, is seen by many as a breach of that contract. As a result there is much concern and indeed, anger, at the proposals being consulted on and in the way that the door has been left open by the District Council for planning applications to be made that negate the purpose of any local plan and the consultation process to establish it.
The purpose of Local Government is to serve the community in the district that it covers. It is not to impose in a dictatorial manner changes that will erode the quality of life of those that live in that District unless there should be a very good set of reasons that carry greater weight than maintaining and improving the Strategic vision of the authority. At the many meetings that I have been to in the last 6 weeks, I have not found anyone that supports the proposals.
6. Since the Inquiry was only 6 years ago, I would like to draw your attention to certain key findings of the inspector, particularly where he talks about the plan after 2011.
In paragraph 11.3.8, in respect of the housing land supply position and of the need to allocate sites for housing, he finds "This Local Plan only covers the period to 2011 in the absence of firm housing or employment figures for the period beyond. The housing figures derived from the RSS for 2011-2021 are indicative only. Nevertheless, the District Council is able to show that there is no need to identify further housing sites. The balance of 2,210 dwellings to be provided between 2005 and 2021 equates to 138 dwellings per year. The District Council's estimates of windfall sites (based on past trends and emerging Local Plan policy) equate to an annual average of 282 dwellings in the urban area and 11 dwellings per year in the rural area. On the basis of these figures, I am satisfied that the District Council is justified in not identifying sites to meet the requirement to 2021. "

In paragraph 11.3.10, in respect of whether the Plan should identify a 10 or 15 year supply of housing, he finds that "New Table 5 of revised Appendix 2 shows how the residual housing requirement for the period 2005-2021 can be met. This particular objection is therefore satisfied. "
Table 5 in appendix 2 of the 2007 local plan states the following

source Dwellings
RSS housing requirement 2001 - 2021 8,091
Dwellings completed 2001 to 2005 3,324
Remaining dwellings to be provided 4,767

By the end of 2011/12 the dwellings completed had increased to 6,084. Deducted from the original requirements this leaves 2,007 remaining to be provided by 2021.

If 2,007 is the plan for 10 years, then for 18 years until 2029 it might be 200x18= 3,600.
The latest Hearn figure for the 18 years is 8,500 persons (see section 8 below) or 3,705 dwellings, so it looks as though we should be getting back the anticipated plan.

This ties in with census findings

Census House
holds % increase Homes built Running % increase population % increase Running % increase
1991 (to 1995) 48,202 856 116,522
('96 - '01) 3,537
2001 ('01 - '05) 53,356 10.69% 3,324 125,931 8.07%
2011 ('06 - '11) 58,679 9.98% 2,760 21.74% 137,648 9.34% 18.13%

The 21.74% increase in households compares with 15.32% over the whole of England for the same 20 year period. So The District has not been lagging behind but has done more than most.

7. So how did 2,007 become 12,300? Somehow in 2008 the RSS came up with a figure of 8,300 for the next 20 years up to 2029. That caused demonstrations outside the Council offices. Then came the banking and economic crisis and a change of government, with the abolition, eventually, of the RSS. Views were sought from the public and 58% agreed low growth. The first consultation was for 10,800 homes, higher than the RSS. This was rejected by 87% of respondents. A reasoned assessment based on ONS data was done that indicated a figure of 5,400 homes by 2029 was the housing need for the locality. By this time we also had the Localities Act 2011. The intention of Government was to give local people a chance to influence the way that development grew. The NPPF, in describing the way that local plans should be prepared is clear that -
150. Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities.
151. Local Plans must be prepared with the objective of contributing to the achievement of sustainable development
152. Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued.
154. Local Plans should be aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where.
155. Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.

These are important matters that the plan so far fails to do. The vision and aspirations of the local communities, the definition and implementation of sustainable development to achieve net gains on all three dimensions thereof avoiding adverse impacts on any are not only not demonstrated, they seem to be ignored.
Local plans should be aspirational but realistic and address the spatial implications of change. If 2,007 homes by 2021 was considered to be realistic by the Inspector in 2006/7, and shown to be so by the District council at the time, what are the reasons for the unrealistic numbers now? This was only 6 years ago, so within living memory.

With regard to 155., local plans should as far as possible reflect a collective vision and a set of agreed priorities for the sustainable development of the area, collaborating with neighbourhoods, local organisations and businesses. A wide section of the community is engaged and would wish that it was proactively so. But this requires a listening district council.

8. 156. Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver the homes and jobs needed in the area.

Homes and jobs go hand in hand.

In December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn updated the forecast for population growth. It starts with the following statement
5.52 The projection based on past population trends (PROJ 5) indicates modest population growth of 6.2% over the 18-year plan period - an increase in population of around 8,500 persons. Comparing the trend-based projection in this report with that contained in the SHMA we see that population growth would now be expected to be lower. This projection suggests an annual increase in the population of 473 people which compares with a previous estimate of 914.

The reasoned assessment of 5,400 homes needed by 2029 included migration trends as well as natural changes due to births and deaths, totalling 590 persons per year. Now Hearn have used later data that shows 473 persons per annum. ONS data is based on 25th September 2012, 3 months before Hearns report. It should be expected that when it is brought up to date it will use the same data as Hearn or possibly even later.

The Economic and Demographic Forecasts Study prepared by GL Hearn also states that

4.5 The District has a jobs density of 0.95 - this means that for every person of working age (16-64) living in the District there are 0.95 jobs in the District. This is significantly above average for the West Midlands or England (0.75 and 0.78 respectively). Overall there is a relatively good jobs-homes balance currently.

The conclusion I draw is that until the joint SHMA is received, the 12,300 household cannot be considered as a valid consultation. Across the neighbouring authorities, jobs ought to follow unemployment so far as it is sensible to do. Since our unemployment count is very low, and job availability is still very fragile, then building a larger volume of homes than we have ever done does not seem to be a good strategy. It could give us a dramatic employment problem.

9. Duty to cooperate with Neighbouring authorities - I understand the Inspectors rejection of Coventry's proposed plan and it clearly ties in with the joint SHMA. I note that Stratford is not part of the joint SHMA and wonder whether, due to the Gaydon dimension, which will invalidate their plan and possibly our joint SHMA as well. Since Gaydon to Nuneaton is seen as the motor industry technology banana by the district, that may be the reason for the ambition for jobs and homes in Warwick. But if Gaydon has a new town for JLR, coupled with the proximity with Banbury, then Warwick's need to grow is less.

10. Maybe part of the plan is to grow homes to get new homes bonus. But this is not a material consideration in NPPF terms. It is not a good business plan either, because the infrastructure needed to support a 29,000 or so population increase has yet to be provided. I note that the CIL paper acknowledges that there will be a funding gap unspecified. I have no detail to work with, but some quick guesstimates indicate that there could be a £100m capital cost shortfall between total public infrastructure costs (County, District, NHS, & central government) compared with CIL, section 106 and other charges to the developers after accounting for 40% number reduction for CIL-less affordable housing and approvals already given.

With a reduced housing target of 5,400 the infrastructure need would to be less because it is a smaller volume and can be spread more evenly around the district spreading not concentrating infrastructure overload.

11. The planning Inquiry in 2006/7 looked particularly at sites both in Areas of Restraint and subject to rural area policies. The decision made then needs to be seen in the context of the NPPF54, 55, 109 to 125. In particular,
NPPF54 agrees with the existing local plan rural area policies by requiring that, "In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs."

NPPF55. Would extend those policies " To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby." To do this, the local plan should have specific rural area policies. It may be that neighbourhood plans would customise such policies for particular reasons relevant to that parish.

NPPF109 requires that "The planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
* remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

NPPF110 requires that In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework.

NPPF111. 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.

NPPF112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.

The sites selected for development to the south of Warwick & Leamington do not appear to meet these requirements. The councils own Landscape consultant in 2009 has some very strong recommendations that should be taken into account.

Looking at the particular sites the inspector made the following conclusions.

11.1 Woodside Farm should remain in an area of restraint. In a lengthy and detailed consideration he concluded that
10.11.41 The AoR designation has been carried forward from the adopted Local Plan. It was established to maintain separation between Bishops Tachbrook and Whitnash. When preparing the earlier Plan the District Council successfully argued that any extension of built development to the south of Whitnash, beyond the ridge line that defines the present edge of the town onto the south facing slope, would create a major incursion into the countryside that would be highly visible and intrusive. Since that time a number of physical changes have occurred in the locality. Extensive housing development has taken place at Warwick Gates on the opposite side of Tachbrook Road. Although anticipated through a Local Plan allocation, this has affected the character of the area by bringing development to the west as far south as Harbury Lane. In addition, playing fields, open space and woodland have been laid out to the east of the objection site giving enhanced public access, and overhead electricity lines have been put underground. The objector argues that in light of these changes the objection site should be excluded from the AoR. The request is supported by a Landscape and Visual Impact Assessment and a Development Principles Plan.
10.11.42 I consider that the AoR still performs essential functions. It helps safeguard the character and setting of Whitnash, prevents urban sprawl and assists in maintaining the integrity and separation of Bishops Tachbrook as an independent settlement. The objection site is an important element of the broader AoR. It occupies an elevated position with views of it obtaining from certain directions. They include limited views driving northwards along Tachbrook Road from Bishops Tachbrook, from Harbury Lane to the east and long distance views from public locations on the northern edge of Bishops Tachbrook. From each of these positions housing development would be clearly visible for many years while structural landscaping matures. This would intrude into the rural surroundings and noticeably reduce the open gap that remains between Bishops Tachbrook and the urban area.
10.11.43 I conclude that this land should remain open as part of a more extensive AoR and that it should not be allocated for housing development within the Plan period or be identified for longer term development.

I concur with the Inspectors view. It is an essential part of the distance between Whitnash and Bishops Tachbrook and an important part of the valued change from town to country along the Tachbrook and Oakley Wood Roads and in particular their junction with Harbury Lane going east rising up through the trees up a double incline hill some 15metres high as the road reaches Mallory Court on the right hand side. Housing on Woodside would be completely counter to the NPPF

11.2 Fieldgate Lane/Golf Lane should remain in an area of restraint. In a lengthy and detailed consideration he concluded that

9.4.16 I take a rather different view. Looking first at the boundary of the AoR, I acknowledge the previous Inspector's uncertainty about whether the golf course and land to the east contribute to the AoR objective of preventing Whitnash from merging with Bishops Tachbrook. However, the south-western part of the golf course is highly visible from Harbury Lane where it forms a backdrop to the new playing fields and pavilion such that any development there would significantly close the gap between these settlements. Moreover, while the rising nature of the ground at Fieldgate Lane/Golf Lane from north to south means that development would not be visible from Bishops Tachbrook, it would be clearly seen from southern parts of Whitnash where the land contributes to the rural setting of the town. It would also, I feel, be intrusive in long range views from east of the railway line. I find that the whole of the area (that is, the golf course and the land at Fieldgate Lane) contributes to the objectives of the AoR. The land has a role to play in the structure and character of this part of Whitnash, provides open areas in and around the town, safeguards its setting and helps prevent urban sprawl. In addition, the south-western section of the golf course maintains separation between Whitnash and Bishops Tachbrook. Consequently, I see no case for excluding the golf course or the Fieldgate Lane site from the AoR. As regards land south of Harbury Lane, this land forms part of the sensitive gap between Whitnash and Bishops Tachbrook. But I believe it to be less at risk of development because Harbury Lane/Gallows Hill provides a strong boundary to the urban area. In my view, there is no need for AoR designation to extend south of Harbury Lane.

9.4.18 Finally, the objector considers that as the Fieldgate Lane site is bordered by housing to the north and south it should be considered as part of the urban area, rather than one where the Plan's Rural Area Policies apply. I do not agree. As the District Council points out, all rural areas have an urban edge. In my opinion, that boundary is properly set by the suburban housing to the north of Fieldgate Lane.

9.4.19 The objector's proposals were subject of the Omission Sites Consultation undertaken in January/February 2006. Responses received from Whitnash and Bishops Tachbrook residents, CPRE (Warwickshire Branch) and Whitnash Town Council were against any removal of the golf course or Fieldgate Lane site from the AoR, any residential allocation at Fieldgate Lane and any exclusion of the proposed development site from the application of Rural Area Policies. I note that 251 responses were received against the Fieldgate Lane site and 496 objections in relation to the golf course (of which 240 were by way of a petition from members of the Leamington and County Golf Club). This is a clear indication of the strength of local feeling.

Residents of Whitnash agree with the inspector that the site is part of the Golf course, Woodside Farm Area of Restraint set out by paragraph 9.4.19 of the inspectors report. I agree and object to this proposal.

11.3 Grove Farm (called Harbury Gardens by the developer) should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & west of Oakley Wood Road.

In the 2012 consultation, this site was described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge as part of the separation of Whitnash and Bishops Tachbrook was welcomed. Dismay ensued with the current 2013 proposal for 200+ homes.

Reacting to an objection seeking this land be included in an area of restraint, the inspector found that

9.4.4 I agree with the District Council that a cautious approach needs to be taken in respect of the AoRs in order to avoid their devaluation and to ensure that they perform a specific function. Unlike the other AoRs included in the Revised Deposit Plan, much of the land identified by Bishops Tachbrook Parish Council (even with the reductions in area put forward at the hearing) is relatively remote from the urban area and not under immediate threat from urban expansion. The gap between Harbury Lane and Bishops Tachbrook is about 1.4km compared with only 300m or so between Leamington Spa and Radford Semele. Although there are objections before this inquiry that seek to allocate or designate sections of the land in question for other uses, and anecdotal evidence of options taken by developers, this is by no means unusual when a Local Plan is under review. I consider that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for additional protection. It is not the function of AoRs to give an added layer of protection to open countryside where appropriate policies already exist to control development. Should land have to be released in the future for urban expansion then the District Council says that this exercise would be done by a review of options on all sides of the urban area including sites subject of Green Belt and AoR designation. Land south of Harbury Lane outside an AoR would, it is argued, be placed at no disadvantage.

9.4.6 I conclude that while additional development has taken place to the south of Leamington Spa during the last 10 years or so since the previous Local Plan Inspector reported, his findings remain pertinent. Given the strength of the Rural Area Policies of the Plan, the current housing and employment land supply position and the degree of protection afforded to the most critical areas by the AoRs already identified in the Revised Deposit Plan, there is no need for a further AoR south of Gallows Hill/Harbury Lane. To designate such an area in the absence of any serious threat would be premature at least and at worst a misuse of policy.

The Inspector clearly considered that rural area policies were strong enough to prevent such development. Nothing has changed that alters the communities view. Housing in this location will be very visible across the Tachbrook Valley from the south, being on the ridge line as can be seen from this photograph. Housing will be prominent half way down the field in the distance. The top of roofs to Warwick Gates can just be seen behind the hedgerow on the horizon and stretch from the coppice of trees on the left side of the picture to Grove Farm buildings to the right of centre of the photo. The photo was taken from the public footpath to the Asps from St. Chads Church and this is a prominent view along most of the path. The suggested country park to the south of the housing, because it is on the slope down to the brookstray will not hide the housing as it will be the same height as the trees that can be seen running along the Tach Brook from left to right. The NPPF paragraphs quoted at the head of this section are intended to conserve, protect and enhance landscape such as this wonderful piece of Warwickshire.



It is essential that this piece of landscape is protected as there is no credible case for housing in this location. So we object to the proposal in the 2013 consultation and support the 2012 consultation to keep this area as a green wedge. In my view, however, it does not need to be converted into any sort of country park, at considerable cost no doubt, as it is perfectly acceptable as it is. This would retain a valuable piece of agricultural land, meeting the needs of the present without compromising the ability of future generations to meet their own needs.

11.3 Lower Heathcote Farm should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & east of Europa Way.

In the 2012 consultation, this site was also described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge running from Castle Park in the west through to Radford Semele incorporating paths along the side of the Tach Brook presents recreational potential for village and urban walkers. Dismay ensued with the current 2013 proposal for 720+ homes.



The photograph shows the view north across the Tach Brook Valley from New House Farm. Housing will come down from the hedgerow along the Harbury Lane covering the top half the field between that hedgerow and the trees along the brookstray, the tops of which can just be seen. The undulating form is a 'trademark' of the rolling Warwickshire countryside that is part of the tourist attraction experience on the approach to Warwick Castle from the south and is seen as a backdrop along the Banbury Road. It is highlighted in the Morrish Landscape consultants report of 2009.

4.4 Paragraphs 109-125 of the NPPF outline conserving and enhancing the natural environment. They state that the planning system should contribute to and enhance the natural and local environment by protecting / enhancing landscapes; by recognising ecosystem services; by protecting/improving biodiversity; by avoiding pollution or environmental degradation and by remediating degraded land. LPAs should set criteria-based policies by which to judge potential impacts to wildlife, landscape, etc. and set out a strategic approach to green infrastructure in local plans.

This requirement expects that the new local plan will have such policies and implement them.

The landscape consultant also advises

5.1 Some of the elements that contribute to landscape character include the shape and scale of topography, the presence and pattern of natural geology, outcrops, water bodies and vegetation and, the patterns and features of man's intervention - including land management and settlement.
How and from where the landscape can be viewed greatly influences how it is perceived - so that the availability of access becomes influential in determining landscape character. A variety of views (long vistas, wide panoramas, framed focal points) generally adds to our enjoyment of a landscape. Landmarks are of particular value/interest in any landscape - even if they have disputed amenity value (e.g. Eden Court flats at Lillington).

This paragraph describes exactly the situation with this site. The landscape value of this area is very high. It has a large variety of views, long vistas wide panoramas and framed focal points. It shows an interesting shape and scale of topography. The brutal insertion of the development proposed is totally insensitive, tantamount to municipal vandalism. The existing landscape is an asset that everyone in Warwick District can enjoy and is part of the package that makes Warwick District a Great Place to Live, Work and Visit.

The Inspector "consider(ed) that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for the additional protection of an Area of Restraint. This set of policies should be included in the new local plan to meet the NPPF clauses referred to above.

11.4 The former Severn Trent Sewage Works between Lower Heathcote Farm and Grove Farm to the south of Heathcote Park is listed in RDS 5 and shown on Map 3. It claims to provide 225 homes.



This photo shows the site from the site across the Tach Brook Valley. It is the central greener area. At the top of the hill on the skyline there is a mature area of trees which provides a wildlife oasis to a number of mammals including deer, birds and woodland insects. The former sewage tanks are, according to old plans, many and closely aligned. The tank depths and ground contamination is likely to make this a difficult site to develop for housing and add to that the steep fall as the ground slopes down towards the brook it is unlikely to provide any practical housing land at all.

The site would however be an ideal site to develop as woodland as part of the low carbon environmental sustainability objective of the Councils Corporate Development Strategy. Carbon dioxide sequestration of woodland is calculated on the basis of 25m2 absorbs 1 tonne of CO2 per annum. If a normal house produces 4 tonnes of CO2 per annum, this provides sequestration for about 1000 of the homes to be built. Bishops Tachbrook Neighbourhood Plan is seeking sites of this nature within its boundary and will be including this site in discussions with neighbouring towns and parishes as part of its duty to cooperate with them. AS far as the NPPF is concerned paragraph 109 requires development to conserve and enhance the natural and local environment by remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

11.5 Land south of Gallows Hill between Europa Way and Banbury Road, north of the Tach Brook.

The northern section is the other half of the Tachbrook Valley and to build upon it would detract from the southern part which it has been accepted should be kept. Given that the RDS does accept that the Asps is an important part of the Warwick Castle approach, so is this northern section. it can be seen from the Warwick Castle Towers and the mound. Any development on this site will have a direct impact on the views available to visitors to the castle.

This photograph was taken from the top of Guys Tower in Warwick Castle, looking south-east, earlier this year and shows the site south of Gallows Hill in the foreground with two oak trees in the centre of the field and the hedgerows running along Europa Way. Behind the hedgerow there are fields of yellow oil seed rape which is the site south of Harbury Lane in 11.3 at Lower Heathcote Farm. To the right of the poplar tree on the left of the photo is the farm cottage to the former Heathcote Farm with, to its right, the roofs of the bungalows in Heathcote Park, mostly hidden in the trees. Beyond that are the trees bordering Oakley Wood Road with the hill rising behind them, through the Grove Plantation rising to Highdown Hill Plantation on the skyline. This is a view that has been available to Kings, Earls and visitors since 1395 when the Tower was constructed, so is significant for Tourism and should not be lost to development. No amount of landscape 'mitigation' will compensate.



The 2009 Landscape area statement by the councils Landscape Consultant Richard Morrish clearly concludes that

This study area is principally well preserved farmland that creates an attractive rural setting for the south side of Warwick and should be considered an important part of the setting for Castle Park. Any development that 'jumped' the Heathcote Lane / Gallows Hill frontage would set a major landscape precedent in extending the urban area so far south. Although it is considered that the Warwick Technology Park has possibly diminished the value of the Area of Restraint north of Heathcote Lane, its general style of low density development in a strong landscape setting makes for a reasonably successful transitional environment on the urban fringe - as do the adjacent school sports fields. To extend the urban area beyond these sites would make for a disjointed urban structure and possibly encourage intensified development at the Technology Park and around the schools. Smaller blocks of isolated development are also likely to be incongruous in this landscape.
Our conclusion is that this study area should not be considered for an urban extension and that the rural character should be safeguarded from development.

The Inspector at the 2006/7 Public Inquiry considered this site for employment purposes. In a lengthy and detailed consideration he concluded that

10.3.49 The objectors maintain that the Gallows Hill site would provide continuity in the forward supply of employment land beyond 2011. However, I believe it would be inappropriate to identify such sites now when the future employment requirements of the District are uncertain pending completion of the sub-regional employment land review and the partial review of the RSS. Until then, the RSS requires that greenfield sites, like this land at Gallows Hill, should only be released when there is no alternative previously developed land available. The WMRA, commenting on the Omission Sites Consultation, remarked that new sites being promoted involving the development of greenfield land "appear to be inconsistent with the principles of the RSS" and requested that the Inspector rigorously scrutinise such proposals. I agree with the District Council that as and when further greenfield land releases are necessary this should be done through a DPD where a full comparative assessment of all potential sites can be made in the context of a sustainability appraisal and following a process of public consultation. In this regard, I note that the objection site is classified as very good (Grade 2) agricultural land and that a full Transport Assessment would be required in respect of development on this scale. I believe that the ad hoc release of a large greenfield site like this located on the urban fringe and currently in agricultural use would not be in the best interests of the District. The Council's Local Development Scheme commits it to begin preparation of a Core Strategy DPD immediately following adoption of this Local Plan. That will tie in with completion of the partial review of the RSS, enabling up-to-date employment requirements for the District to 2021 to be accommodated.

10.3.50 I conclude that land at Gallows Hill should not be allocated under Policy SSP1 for employment (Class B1) purposes, nor should the site be excluded from the rural area defined on the Proposals Map. To do so would result in an over-provision of employment land relative to the Structure Plan requirement, at the expense of the surrounding countryside.

The site is shown in the RDS as residential and employment but this we believe is wrong because all the advice is that it should be retained as agricultural land with a high landscape quality, hidden for the most part behind hedges on Harbury Lane but with occasional glimpses through it at gates and breaks in the hedge. It is on the only high quality approach road to the Castle

12 Separation of settlements.

The District Council to date has rigorously resisted any development that reduced the gap between Bishops Tachbrook and Whitnash/Warwick. We believe that the NPPF requires the district to continue to implement those policies as part of the social role within sustainable development, supporting strong, vibrant and healthy communities.





13 Conclusion.
We strongly request that you reconsider the quantity of housing needed by the plan, limiting it to no more than 5,400 homes by 2029. This will produce all the homes needed by the locality, gives achievable 5yr land supplies through the plan period, reduces the infrastructure cost and spreads traffic volumes, avoids the need to take valuable greenfield sites and restores the confidence of the electorate in the local authority. It has been produced as an objective assessment, that takes all the requirements of the NPPF as well ONS projections into account, establishes a realistic employment strategy that recognises greater problems in neighbouring areas but allows a controlled and realistic amount of economic growth.
That should then mean that we have a sustainable local plan that will fit well into the limited space we have available.

The housing boom proposed in the latest W.D.C. Local Plan is unacceptable to the residents of Warwick, and is demonstrably against all government (local and central) and European Union policies.
The perceived demand for housing is based on false data and the aspirations of, and pressures brought on the Council by developers and central government, with no regard for local needs or the wishes of residents. The number of new houses proposed is twice that required to meet local demand. The demand data used is an extrapolation of past housebuilding in a boom period when mortgages were easy to obtain, and bears no resemblance to actual demand in the current economic climate.

Half the sites proposed for development are on greenfield land to the south of the built-up areas of Warwick and Leamington, and would thus require the new residents to travel through these two towns to the new expected employment sites south of Coventry. The resulting air pollution in the centre of Warwick, already above the legal limit, would increase even further, endangering the health of residents and visitors alike. No ameliorating proposals are being considered.

The infrastructure required for development on this scale is substantial - health services (including Warwick Hospital), schools, leisure and community facilities - but all are ignored in the Local Plan. From past experience of similar developments the provision of adequate infrastructure after the completion of the housing has not materialised.

I ask you to bring pressure to bear on the District Council to rethink the strategy and
1. revise downwards the quantity of new housing proposed;
2. reconsider the location of new housing to take into account the location of employment;
3. insist that the requisite infrastructure is completed before the housing is occupied.
4. make public its proposals to ameliorate the damage to health of residents and visitors alike by the increase in traffic pollution inherent in the suggested location of new housing.

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The proposed site allocations for the new Local Plan result in an overall imperative to ensure that policing infrastructure expands proportionally with the delivery of new development growth, in order to ensure the continued delivery of policing services to a significantly growing population. Warwickshire Police expresses no preference amongst the growth options presented, but there are a number of observations to make about the new Local Plan that will be vital to helping us work in partnership with the Council and applicants to deliver required policing services into the future.

Observations
Strategic Vision: This currently makes no reference at all to the need to ensure safe, secure and low crime communities and places are created and maintained in Warwick District. This is at odds with paragraphs 58 and 69 of the National Planning Policy Framework (NPPF) and the Council's forthcoming Sustainable Community Strategy, described at paragraph 3.6 of the Local Plan. Unless this is addressed, support for the infrastructure and design measures necessary to create and sustain such places and communities is critically undermined.

Section 3 makes a number of references to the importance of sustainability. Low crime & disorder is vital aspect of sustainability, as stated above, which must be included in any definition or statement regarding this term.

Revised Development Strategy: Please see the enclosed representations, prepared by consultants Boughton Butler LLP, regarding this topic.

Strategic Development Sites and Infrastructure: All of the strategic development sites detailed in the Local Plan will require the proportional growth of police infrastructures to maintain equivalent levels of service in the areas concerned. However, the police service does not receive funding to cater for the infrastructure needs and associated costs that come with the delivery of development and associated population growth. This is because with population growth there is a corresponding increase in crime and the number of incidents requiring a police response. This places demands not just on the 'front line', but on the whole spectrum of support and specialist police services, e.g. forensics, roads policing or armed response team to name but a small number, that will be called upon during the lifetime of a development.

Further, policing is a countywide, regional and national service and it is not practical or sustainable to develop an infrastructure on a piecemeal basis. The recognition (such as in paragraph 5.1.14) that cumulative impacts must be planned for at the strategic level is vital to achieving the most effective infrastructure, both for individual agencies and for joint agency partnership working and shared services is consequently a very welcome inclusion and represents a big step forward in the provision of cohesive public service infrastructure, including policing.

We therefore request that the Local Plan includes specific policy recognition of the need for additional police infrastructures in relation to strategic and other development sites. We intend to provide details on the precise infrastructure required as work on the Council's Infrastructure Delivery Plan progresses over the course of this year.

Secured by Design - Strategic Development Sites and Infrastructures - Housing Mix: The Lifetime Homes standards include safety in terms of both traffic and crime. It should therefore be a requirement that all homes should be designed and built to the Association of Chief Police Officers (ACPO) Secured By Design accredited standard. Also, achieving the best possible traffic safety of any new roads development should involve consultation with the Warwickshire Police Road Safety Unit.

5.1.27: Highlights the potential for 12,300 new homes in Warwick District. This represents an increase of approximately 23% increase in the District and approximately 5.4% increase in Warwickshire as a whole. It is logical to conclude that this will lead to a proportional increase in demand to policing services. This is in addition to significant housing growth elsewhere in the Warwickshire policing area. Accordingly, the Warwickshire Police infrastructure will require expansion in response to the planned housing and other development growth in Warwick District.

Whilst this will not, in most cases, lead to the visible structures of new police stations, there remains a fundamental requirement to provision expanded infrastructure capability in policing through mobility (police vehicles), communications (radio systems and IT infrastructure), support functions (crime recording, strategic planning, judicial services, HR, Finance, Fleet Management, Estates and others). Wherever possible these will be developed in partnership with other agencies, and should be a core component of CIL planning.

Map 4: Whitnash and south of Sydenham: There is a potential need for a neighbourhood policing base within the housing developments proposed for the South of Warwickshire & Witnash. Ideally this will be a shared facility operated in partnership with other public service agencies.

Conclusion
The Warwick District Local Plan Revised Development Strategy presents police infrastructure and Secured by Design considerations that need to be addressed. The significant growth in housing, employment and population also requires continued engagement between the Council and Warwickshire Police in infrastructure planning and CIL scheduling to ensure proportional provision of flexible police infrastructure into the future.

Conservation Advisory Forum
Comments on Local Plan Consultation Housing Sites

CAF Meeting 18 July 2013


* Scale of development. Concerns expressed about impact on Warwick . There will be a 40% increase in the population of Warwick which will have a dramatic effect on the existing settlement and on traffic passing through both Warwick and also Leamington along Europa Way.

* Sustainability. It is not considered to be a sustainable development rather suburban sprawl.

* Traffic impact . Significant concern expressed about the impact of traffic on the Conservation Areas in particular the increased use of Banbury Road and the need for upgrading of the road system and the impact on Castle Hill roundabout and the bridge over the River Avon which is a Listed Building.

* Increase in car usage .This type of development reverses the trend over the past 20 years a small scale infill and the reduction of car usage. These proposals will increase car usage which will impact upon the historic Town Centres, as all the sites are only accessible by car. This will have a roll on effect in terms of the transport infrastructure and will make everyone else use cars.

* Impact on cycling . It was felt there was no scope for cycling because of the intensity of traffic.

* Release mechanism for sites .The release mechanism of sites was questioned. It was felt that the present system will lead to sites being built on regardless of whether there is any infrastructure to support them. A staged approach is needed for any sites within the district.

* Impact on historic buildings .The impact of traffic entering the Town Centre will impact upon all the major junctions and will impact upon the Historic Buildings themselves and the setting of them.

* Thickthorn , Kenilworth .It was pointed out that Kenilworth did their own consultation and have come up with the Thickthorn site as the best of the options if we have to meet the five year housing supply.

* Infrastructure for Kenilworth . Kenilworth needs to have adequate infrastructure of eco houses and appropriately relocation of the various clubs that use the Thickthorn site before development commences.

* Integrated transport system. Kenilworth needs an integrated transport system with a proposed new station, each house being provided with two parking spaces.

* New Hospital .It was felt that to support the level of development a new hospital would be needed in Warwick.

* Transport mitigation measures .The impact of transport mitigation measures on Warwick would include a 3-4 lane Banbury Road development, traffic signals at Bridge End roundabout, effects on Listed Castle Bridge, gyratory system at the Castle Hill roundabout and traffic lights. All roads will have a greater amount of traffic; there will be significant effects on air pollution and the quality of air in the Town Centre. Congestion charges were suggested. It was felt that if traffic was removed completely the High Street shops would suffer.

* Station Approach site - it was felt that it should follow the SBD for that site.

* Student accommodation . It was felt that if more students were to be housed on Warwick and Coventry University sites this would release more houses in Leamington Spa for use by families and would reduce the housing need overall.

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My main objection is that the local towns are not capable of dealing with the current volume of traffic at peak times without adding several more thousand houses.
In addition our local schools and hospitals are already at or very near capacity and there are no definite plans to increase the capacity of either.

I am also very much against the provision of either permanent of temporary transit camps for itinerants from any source. The council must be aware of the state that Myton Fields were left in after a fairly recent visit from them. I don't understand why we are constantly bending to the "needs" of minority groups when a democracy should be for the needs of the majority. If it is the government who is driving the issue of camps then I suggest that there should be one large permanent camp next door to David Cameron's house in the Cotswolds as I am sure that the itinerants would welcome the opportunity to live in a very pleasant rural community.

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