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

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I refer to the Revised Development Strategy for the Local Plan and write to register my objection to the proposed development of land to the south of Warwick as follows:

Introduction
It is noted that in the Introduction reference is made in para 1.2 to "the need to take in to account what our neighbours and partners are planning to do over the next 15 years."

The Revised Development Strategy appears to completely fail to take in to account the proposal by Stratford on Avon District Council to build 4800 houses at Gaydon/Lighthorne. The effect on Warwick and Leamington Spa of such proposal will be immense in respect of increased traffic, pollution and use of the hospital and other amenities. Such an increase must be taken in to account in preparation of the Local Plan, as it will impact on the local infrastructure.

Para 1.3 refers to "some work regarding the evidence base to support the final proposal for the Local Plan is on going."

We have not been advised as to the nature of the evidence that is not yet available. It is noted that no reference is made to the Environment Agency and the undoubted problem that the area has in respect of flooding. At the present time the Environment Agency places the postcode in which I reside as "moderate risk." What impact is anticipated if the proposals contained in the Revised Development Strategy are implemented? The last Flood Report obtained by the Council appears to have been undertaken in 2008. Since then the country has been subjected to the highest recorded levels of rainfall. The fields upon which the proposed homes are to be built remained water logged for several weeks after the winter storms and absorbed rainfall, which would otherwise have come down in to Warwick. Has there been/will there be any report prepared based on the proposal to build on such a large site situated south of the River Avon and on high ground? Will the District Council provide a flood plan and appropriate compensation should the need arise?

How can a plan be formulated when not all the relevant evidence is available? Surely no decisions should be made until the Strategic Housing Market Assessment has been made, and this would appear to be the view of the Inspector appointed to review Coventry Council's Core Strategy. It is disputed that number of homes proposed are actually required, and there is a suspicion that the wishes of the Developers is being put before actual need.

At the present time it is understood that homes are required to accommodate the proposed employees at the Gateway Project close to Coventry Airport at Bagington. Situating housing for those employees on the other side of Leamington and Warwick, two established and historic towns with existing traffic problems, is totally inappropriate. If the Government's wish to reduce car usage and pollution are to have any credence then the housing should be situated closer to the Gateway Project site.

Para 1.4 confirms that not all topics are included and it is sincerely hoped that no decisions will be made until all the evidence is available.

The Local Plan and Consultation
The issues referred to in respect of process are noted. There is however considerable concern locally that there is now a degree of 'panic' by the District Council as they have radically changed the proposed areas for development from the Preferred Options consultation. There appears to have been a failure to consider changes to the greenbelt to enable the obvious and more appropriate development to the north of Leamington Spa. Whilst the earlier proposal of development to the south of Warwick was not welcomed, the massive increase now proposed appears to be an attempt to do something, indeed anything, even if it is wholly inappropriate. It has is also unfair to the local community, who have now been presented with a significantly increased area of proposed development with only just over six weeks (in the holiday period) to respond.

Strategic Vision
Although certain paragraphs have been included in the Revised Development Strategy that are referred to in the Sustainable Community Strategy, the document itself refers to "A shared vision", and refers at length to the different local groups/agencies with whom it proposes to consult. However, it is clear from the District Council's own research that the local community were hardly aware of the Preferred Options Consultation yet alone the Revised Development Strategy. We are further advised that all Warwick Town Councillors and the two representatives on the District Council have unanimously opposed the proposed development south of Warwick. How then is the proposal to build south of Warwick "a shared vision"?

Page 16 of the Housing Strategic Aim refers to issues including "working closely with Community forums/neighbourhood groups..." and yet the District Councillors responsible for planning have been unavailable to attend meetings with concerned residents.

Level of Housing Growth
Until the Joint Strategic Housing Market Assessment with neighbouring authorities has been completed, such a large development south of Warwick should not even be contemplated. The figures the Council intend to rely upon in the interim are not accepted and cannot be until the Gateway Project has been finalised.

It has been noted that the Chase Meadow development in Warwick had not yet been completed and again, no reference is contained in the Revised Strategy to the planned development at Gaydon/Lighthorne.


Broad Location of Development: Housing
The concerns raised in para 4.3.3 remain, and have not been answered by the additional research. Indeed, RMA Consultants recommend in relation to the land south of Gallows Hill and The Asps that "...this area should be protected from development."

The Council's own research in to local issues confirm that traffic and environmental pollution are of concern. The Strategic Transport Plan does not address those issues. The plan for four lanes of traffic along Banbury Road will not produce a solution to the two lanes available over the Bridge. Myton Road is already acknowledged to have excess traffic and the location of two schools in the road will make any increase in traffic extremely dangerous. The same applies in respect of additional traffic funnelled through the centre of Warwick. The existing level of traffic and the delays caused are of grave concern to the residents and inappropriate in a town containing historic buildings. The proposed plans seem to completely ignore the issue of Conservation Areas.

If Warwick is subject to an even greater level of traffic it is inevitable that the existing pavements will have to be reduced in size and safely barriers will have to be constructed. To ignore the location of the schools in the centre of Warwick is to ignore obvious safety issues. Will visitors wish to come to Warwick when it is no longer safe to walk, and pollution levels make it unpleasant and dangerous to do so?

The Overview of Development - Map 2 indicates the completely disproportionate level of building proposed to the south of Warwick. The infrastructure will not be able to cope. The Council refer to 'mitigating' the effects of traffic, but the proposals to do so are totally inadequate. The same applies to their response to the concerns for the historic centre of Warwick and the environmental impact.

I regret that I have not been able to respond in detail to all of the documents referred to on the Council website as the requirement to register my objection on time has been my primary concern. I am however deeply troubled by the Council's approach to earlier concerns raised, and the implications for opposition to the Revised Development Strategy in that problems with infrastructure, environment, traffic, pollution etc appear to have been dismissed with the term "this will be mitigated." There are no solutions to a plan, which places a disproportionately large development on the wrong side of a river, with increased levels of traffic passing through an historic town with inadequate roads and infrastructure to cope.

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

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

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

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

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


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

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

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

9 Conclusion
9.1 In objecting on these strong and numerous grounds to the Revised Development Strategy, the Society offers its assistance to the Council in the necessary task of devising a better alternative, with the full involvement of a wide range of residents and business interests.
1.1 In its document Local Plan Preferred Options, May 2012, at para 3.3, the Council invites the views of all interested parties to help shape a draft Local Plan.
1.2 Here are the views of The Warwick Society. They refer to the Full Version of the Preferred Options and in some cases to some of the supporting documents made available on the Council's website. The Response Form, which we have not found effective for structuring our comments, uses the words 'support or object' rather than the Preferred Options' 'the Council is keen to hear the views'. While we have phrased our comments as views, it will be clear that many would be objections to firmer proposals, and will become formal objections if the next stage of the plan-making process does not respond satisfactorily to them.
1.3 The Warwick Society, the town's civic society, was founded in 1951, and has as its first aim to conserve, for the benefit of the public, or to encourage the conservation of, the natural, artistic and cultural amenities of Warwick and its neighbourhood. It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people.
1.4 Warwick is no stranger to development. The mediæval town was largely destroyed by fire in 1694, though many timber-framed buildings at its fringes survived. Rebuilding followed a plan to widen the streets and to improve fire-resistance with stone and brick walls. It took place at the start of the Georgian era. So the High Street, the Cross, Church Street, St Mary's Church and Northgate Street form an elegant and coherent architectural ensemble. It is the juxtaposition of the mediæval with the Georgian which makes Warwick distinctive. More recently, C19 industrial development based on the canal and then the railway has been followed by more extensive C20 sprawl based on the car and the road network. In the decade 2001-2011, the population of Warwick grew from 23,000 to 30,000, a rate of increase of 30%, among the very fastest rates of any town in the UK. Assimilating this growth and building new communities takes a generation.
1.5 The new Local Plan gives a new opportunity to make the town, and the district around it, a finer place, and a better place to live, be educated, and to work in. Its population may grow, because it is attractive, and well-located at the south-eastern corner of the West Midlands. Its future residents, and those who work here or visit, need a vision which ensures that it continues to be attractive, and to function well.
1.6 This means:
1 Developing the local economy sustainably, both facilitating growth in jobs and income and reducing the impact of climate change;
2 A pattern of development which reduces dependence on the car, congestion and pollution;
3 Transport and social infrastructure which enables people to live sustainably and economically;
4 Walking routes, cycle routes, schools, health centres and shops which allow people of all ages and capabilities easy and healthy access to them;
5 A mix of housing which meets local needs, especially affordable housing for families;
6 A rate of development which allows the towns and their communities to absorb change and make each a socially and personally contenting place to be; and
7 Protecting the natural and historic environment, especially the green hinterland of towns, green spaces within them, and the historic buildings which make them special places.
1.7 The Preferred Options fail by a long way to achieve this. The Issues [para 4.8] identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.8 In the following sections, we consider the three main ways in which the preferred options fail to meet the expectation of those who live in the District, and suggest changes which, if introduced to the draft Local Plan, could make it a very much better direction for the District to follow.

2 Population Growth and the Demand for Housing
2.1 The Preferred Options' emphasis on growth in jobs and housing, each matching the other [para 4.10], is founded on a circular argument and on mere assumptions.
2.2 The Strategic Housing Market Assessment [para 5.13] 'projects' (not forecasts) future growth in the District's population. It explains [SHMA figs 2.13 and A2.4] that 'in-migration' has been much the most important cause of population growth in the fifteen years 1996-2010. Of a total population increase of 18.9k (from 119.8k to 138.7k), 16.5k has been net in-migration, and only 2.4k the natural change. The report notes [para 2.33] that 'past migration trends will have been influenced in part by past levels of housing delivery.'
2.3 The SHMA assumes the average rate of in-migration of the last five of those fifteen years, 2006-2010, and projects it for the next twenty. There is no quantified analysis of the causes of the in-migration, nor any quantified forecast of its future level. It is simply an assumption.
2.4 The SHMA goes on to assume an age profile for the in-migrants, again basing its projection on neither evidence nor analysis, but on assumptions, in this case those of the ONS [SHMA para 2.17]. The projection of net in-migration is the difference between two much larger numbers, gross in-migration and gross out-migration, and the in-migration figure is produced only by adding that assumed net projection to the ONS assumption of out-migration. The projection is not a forecast, just an arithmetical exercise, and its predicted growth in population is no more solid than the assumptions and extrapolations on which it is based.
2.5 The extrapolations have as their base the after-effect of rapid housebuilding in the years before the market collapsed in 2008. All that they show - as described at the end of para 2.2 above - is that if houses are built, people will move into them; in a second circularity, if the mass housebuilders do not believe that their output will be sold, they build little. A third circular argument then enters the Plan as it stands: if the population rises, employment will rise, as those who buy and occupy the new houses are very likely to have jobs - without which they do not have the means to buy the houses.
2.6 We conclude that the preferred level of 'growth' is simply a bid for growth, rather than a forecast for which there is either evidence or action plan, other than almost free-for-all development with all of the negative impacts on existing residents and the environment that that will bring. The alternatives of more modest levels of growth, in both housing and employment, with much lower damaging impacts, would be equally valid for the Council to choose. We urge that it should reconsider its preference in the light of the absence of evidence in support of it, and take a broader view of both growth and all its consequences.

3 Infrastructure
3.1 The infrastructure proposals do not provide for sustainable development. The modelling of the existing network against possible locations for development consists only of modelling vehicle flows. It does not reflect the national polices and Local Transport Plan which require priority to be given to reducing the demand for transport, and to walking cycling, and public transport.
3.2 Except for the possibility of Kenilworth station (which would have a negligible impact on demand for road use in the peaks) all of the significant infrastructure proposals are for increases in the road network. They have been selected to deal with some of the local congestion created by increase in demand of the various housing site options. They do not provide a coherent transport network for Leamington, Warwick and Kenilworth, rather a continuation of the existing mismatch between traffic and the capacity available to accommodate it.
3.3 Good railway services are already provided at Leamington and Warwick Parkway stations. The level of service at Warwick station is significantly inferior to that of Warwick Parkway, even though it serves a much more substantial population within walking distance. Conversely, almost all access journeys to Warwick Parkway are by car. For journeys to and from work, Birmingham and London are significant destinations and there is some commuting in to Warwick and Leamington which is badly served by Warwick Parkway. The basis of a sustainable infrastructure plan should be to improve train services at all three of these stations, and especially at Warwick station, and to concentrate development close to them, minimising car use. This possibility does not appear to have been considered.
3.4 The conclusion of the modelling is that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, in particular to meet the Air Quality Management Area requirement to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings all require that the legal requirement to restore air quality should be given absolute priority.
3.5 Instead, the infrastructure plan proposes spending almost all of the potential developers' funding contributions on major expansion and 'improvement' of the road network. The lesson was learned decades ago that changes of this kind, increasing capacity on some congested sections, simply increases congestion on adjacent parts of the network, through the traffic that the improvements generate.
3.6 We are disappointed and concerned that the preferred options do almost nothing to allow transport demand to be met more sustainably, rather simply try to accommodate it at the expense of the environment and of existing residents and road users. We consider that the whole emphasis of the plan should be above all on sustainability of transport, not just for its environmental impact but also because the prosperity of residents of the district depends on accessibility to services without having to meet the increasing costs of car use.

4 Locations for Development
4.1 Much of the criticism of the Preferred Options has been directed towards the allocation of particular areas of greenfield land at the fringes of the urban area on which large-scale house building is proposed. These sites represent a major misdirection of development. We consider that, rather than the strategy of the Preferred Options, the pattern of development in the district should be dramatically different.
4.2 The total level of development should be substantially lower, of the order of 250 dwellings per annum, Option 1, which is sufficient to meet local needs and not to encourage in-migration.
4.3 Unbuilt existing permissions themselves provide nearly five years' supply to meet this level of requirement.
4.4 Beyond these absolute priority should be given to brownfield sites, as provided for by the NPPF. The Preferred Options propose only that brownfield sites should be used at the end of the plan period, the effect of which would be to consume greenfield sites rather than to bring forward brownfield sites by increasing their value. Some brownfield sites may provide for small numbers of dwellings, but these should not be dismissed: there are potentially many of them.
4.5 Brownfield development should include the intensification of existing development within the urban areas. We do not rule out 'garden development', which can often be in locations close to existing facilities and employment and easily served sustainably. There are extensive areas of development carried out mainly in the second half of the twentieth century where more intensive use of existing housing and employment land would be entirely feasible - were the market signals to encourage it. The proposals for much more intensive office use of the IBM/Opus 40 site on the north-west edge of Warwick go too far in this direction, but demonstrate that intensifying development on a site well connected to the transport network can be attractive to developers.
4.6 Only as a last resort should greenfield land be allocated. The suggestion that it can produce high-quality environments by applying the principles of the garden cities is spurious. The garden cities were planned around local employment and services (in the era before the car, competing supermarkets, choice of school admissions, and two-income households became the societal norm): that is not how we live now. All of the greenfield sites at the urban fringe would be largely car-dependent. As well as their damaging impact on infrastructure and on existing settlements, they would not produce stable, happy communities of their own. The rapid growth in population of Warwick in the last decade requires a period of much gentler growth while the new communities gel.
4.7 The allocation of land south-east of Warwick between the Banbury Road and Europa Way does exactly what the Preferred Options say that they wish to avoid, merging the built-up areas to their east and west. The northern part, north of Gallows Hill, would make Warwick, Leamington and Whitnash into a continuous, sprawling urban area. The southern part, between Europa Way and the Banbury Road would extend this sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would have a directly damaging effect on Castle Park, Grade 1 registered landscape.
4.8 The Green Belt was established to end the outward sprawl of the major conurbations. Circumstances change and there may be exceptional reasons for declassifying Green Belt land: the expansion of Warwick University may be a virtuous case of this. But it is essential that its edges should not be eaten into by extending urban sprawl, for example at Loes Farm and north of Leamington, in the opposite direction from that which it was originally intended to prevent. Similarly, when the Green Belt was designated land south of Warwick and Leamington was not seen as threatened by sprawl from the conurbation simply because the towns stood in the way. Now, that land requires the same level of protection as the post-war Green Belt gave to the edge of the Birmingham and Coventry built-up areas.
4.9 Instead, the Green Belt has become the guarantor of favourable surroundings for the few residents in and outside villages scattered across it. Given the severe damage to the existing urban areas that would follow from their outward extension, an entirely different approach is required to find acceptable greenfield sites. The possible 'Gateway' development around Coventry Airport is an example of this approach: it must concentrate employment and housing close to good transport links without creating undue pressure on the existing urban areas. Planned new or enlarged settlements outside Warwick, Leamington and Kenilworth, and in some cases outside the district - delivered through cooperation with neighbouring authorities - should also be preferred. The substantial employment at Gaydon is not matched by housing provision in the locality, rather met by car-borne commuting to it. Warwick Parkway station and the nearby A46 provide an opportunity not for an urban extension but for a new settlement outside the existing urban boundary, which would not damage what lies within it. Hatton and Lapworth, with existing railway stations, could also be the focus of much more extensive development than is proposed.

5 Conclusion
5.1 We have concentrated on the three main ways in which the preferred options would both worsen the quality of life of the district's residents and damage the historic environment.
5.2 In the copious supporting documentation, there are many more details of the proposed policies which we cannot support.
5.3 But we have limited our comments to these three main issues to try to persuade the Council that the eventual draft Local Plan must be very different from the Preferred Options now proposed.
5.4 We urge the Council to reconsider its preferences and to recognise its long-term responsibility to both the environment and the quality of life of Warwick district.

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. The proposed removal of parking in Smith Street would adversely effect the viability of the shops in this street.

Projected Housing

The projected 12,300 homes is 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 and these should 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 unjustified 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.

Parks

I understand that the new Local Plan does not have any policy to protect our parks. When this is adopted there will be no protection for our parks from developers - only National Planning Policy Framework which I believe is insufficient. This could mean that developments could go ahead on exceptional circumstances (which was the basis for the Gateway application).

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.

We wish to respond to this consultation with considerable objections to the proposed development allocations south of Warwick and Leamington.
We also wish to make it clear that, as a result of the agreement between the Garden History Society and the Association of Gardens Trusts, this should be considered as a response from the Garden History Society.
The objections relate to:
* The impact of development adjacent to the Grade I registered Warwick Castle Park (area 6 in the WDC leaflet, but area 14 in the Arup traffic document)
* The impact of traffic generated by all of the south Warwick proposed development, and of the proposed mitigation measures in the Arup traffic document as they affect both Warwick Castle Park and the historic fabric of Warwick itself.
* General observations on the justification for the proposed allocations and the economic impact. These are within our remit inasmuch as the background calculations have led to the pretty pass in which the future of the setting of Warwick's heritage now finds itself. In that respect we consider we are entitled to comment.
1. IMPACT ON WARWICK CASTLE PARK
Warwick Castle Park was initially created in 1743 to form a landscaped setting for Warwick Castle. It was developed incrementally during the time of the first Earl (Francis Greville, d1773) as the gardens were progressively extended. The park, in its form up to 1773 was much influenced by Capability Brown, brought in to advise and supervise much work from 1849 onwards.
The second Earl (1773-1816) was responsible for the extension of the park to the east, creating the present boundary, and the further extension of the gardens, closing Castle Street and creating Castle Lane adjacent to the present line of the castle wall. It might be supposed that the present line of Banbury Road was simply devised to enclose the enlarged park and particularly a greater length of the Ram/Tach Brook so that its lake could be lengthened and widened by enlarging its dam.
In fact, examination of the boundary demonstrates that it was carefully aligned to be part of the design of the park. The road rises from the viaduct which crosses Ram/Tach Brook to the ridge of Temple Hill, from which it can be seen to be aligned directly on the spire of St Nicholas's church.
The "Approach" to Warwick Castle formed part of the plans of the second Earl from as early as 1773, when he discussed them with other proponents of the "Picturesque" style, so there can be no doubt that the alignment of the road which formed the perimeter of the park was as much a part of the design of the park as the rides and walks within it.
The Castle first comes into view, in a way which was clearly planned, on the approach to Castle Bridge. The bridge had been enabled by an Act of Parliament of 1788, when the line of the road from the Asps had been completed, and was encouraged by an engineer's report to the council, that the only way to avoid the continuing maintenance problems of the old bridge was to re-locate it upstream of the castle mill. Apart from £1000 paid by the town council, whose responsibility the bridge legally was, the expense of the work was undertaken by the second Earl. It is therefore quite clear that the alignment of Banbury Road from the Asps to Castle Hill was part of the designed landscape of the park, culminating, after the bridge was completed, in the creation to the new gatehouse on Castle Hill and the present entrance drive.
The development of the eastern side of Banbury Road as a "garden suburb" would therefore be extremely detrimental to the historic landscape of the Grade I registered park.
2. IMPACT OF TRAFFIC GENERATED BY THE SOUTH WARWICK PROPOSED DEVELOPMENTS
The Arup traffic impact and mitigation study essentially demonstrates why development in this location should not take place.
This is a document of which Arup, as its authors, should be ashamed, and the County and District Councils, as its commissioners should be ashamed to have accepted. People with two degrees find it virtually impenetrable, and it is disgraceful that such an obscurely written document (and ill-proof-read, with sentences without verbs, for instance) should be offered for consultation by the public.
However, it is apparent that Arup are offering mitigation proposals for the adverse traffic impact of the proposed development, without which the impact would be even worse.
These mitigation proposals are totally barbarous and unacceptable for the environment of a county town which has main roads passing over one of the most famous viewpoints in the country, and along historic streets crammed with listed buildings.
The fact that such measures are proposed in mitigation demonstrates that the development which makes them necessary should not and cannot proceed.
The setting of not only the castle and its park, but of the whole town, is defined by the presently open areas of the proposed development and the tree-line highways of the approach roads to Warwick. In recent years this has been defiled by widening and the creation of a turning lane at Ram Brook (apparently implementing an old permission to prevent its expiry) and the new junction at Gallows Hill (apparently not needing consultation because purely highway works).
The highway works proposed by the County Council to mitigate the proposed development would have an infinitely more devastating impact on the setting of the town. The widened junctions and increased lanes would make it much more difficult to experience the famous views on foot. The view from the bridge and the entrance at the 1800 gate house would lose their impact. The open space of St Nicholas Park, protected by covenants when initially transferred to the Council, would cease to have the semi-rural character with which it was planned.
The economy of Warwick town centre depends significantly on visitors. Many businesses would fail to prosper without the addition of tourists, while others would not exist at all. It takes little effort in examining websites and twitter feeds to see that in recent years Warwick has pulled itself up by its bootstraps and made itself into a vibrant community, with a heavy reliance on "cafe culture" promoted in the previous Local Plan. But it is dependent on the ambience of the town to continue to thrive. The leisurely but quality environment on which these trends depends would be totally undermined by the level of traffic forecast in the Arup report. The so-called mitigation measures which it outlines are entirely directed at improving traffic flow, with no consideration of the impact on quality of life and the environment of the town. The beneficial results of the recent work on High Street and Jury Street in making the roads ore inviting to cross, would be lost.
It seems most probable that the proposed development would have an adverse effect on the delicately balanced economy of the town, leading to reduced maintenance of historic buildings as more of them became difficult to let.
GENERAL OBSERVATIONS
We find that the closely argued calculations of the real need for housing development in Warwick District as presented by objectors to these proposals are compelling. The District Council's calculations appear to be based on what would sell if built, rather than what is actually needed. This might appeal to the vanity of some councillors and officers, in increasing the population base of the council, but would adversely affect the attractiveness of the district and would be particularly detrimental to existing residents.
Although this might increase the Council Tax base of the District, it would undermine the viability of the town centre and old suburbs, potentially leading to neglect and loss of attraction to the town.
The proposed development is not sustainable. Firstly, there is little likelihood of people choosing to live in the new houses working locally. There is only a very small allocation of employment land, while allocations from the last and the previous local plans are still not being taken up and are being canvassed for a change in allocation from employment to housing. Other current employment land is being proposed for housing development (Such as the Eagle site) This means that the ratio of housing to employment is constantly being eroded, leading to the prospect of Warwick and Leamington becoming dormitory towns. Even if the (disputed) prospective jobs at Coventry Gateway are factored in, residents of south Warwick would have to drive around 10 miles to work there. There is a limited number of crossings of the Avon and the Leam which are already highly congested at morning and evening peaks. The existing infrastructure cannot cope without more traffic needing to make these river crossings. The situation would only be mitigated by the brutal Arup proposals, so that the ambience of the town, with higher pollution, noise and vibration would be set on a downward spiral.
We consider that the proposals for development allocations south of Warwick will be unacceptably detrimental to Castle Park and to the setting of the historic town and should be abandoned.

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

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

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

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

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

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

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

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

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

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

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

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

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

I hope these few comments should be added

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

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

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

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

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


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

Scale and proportion

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

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

Effect on local road traffic/infrastructure

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

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

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

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

Effect of local services/amenities

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

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

Flood Risk

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

Alternatives to the Local Plan

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

Alternatives that should be considered include:

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

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

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

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

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

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

I have serious concern over many of the proposals made in this plan.
The stated aim of this New Local Plan is "to make Warwick District a Greater Place to Live, Work and Visit." I was born in Leamington and have lived all my life here. However over the years I have seen many lost opportunities, and mistakes, to make the area more environmentally acceptable.
While I have to accept that areas regarded as Urban Brownfield Sites should be developed for Housing and some of the smaller Greenfield Land, ie Kenilworth (Thickthorn) and East Whitnash provide natural extension of existing housing areas. However the overdevelopment of the area South of Leamington could eventually become a planning disaster.
Taking the Plans objectives in a slightly different order:-
Work
The outlook for British Industry will not be as it was in the past. Large Industrial Plants, like Automotive Products will not be sited in this area of comparative affluence. The Government, no matter who is in power, will provide incentives for any such major plants in area of high unemployment. The future for Industry in this area will be in small to medium units supplying other major manufactures. One only has to see the units on the old AP site are Distribution Warehouses and the many empty units on the Heathcoat, Sydenham and Queensway sites. In fact the Queensway site is being cleared of existing Industrial units to build retail units (Aldi) and Housing Association Units. If there is a demand for Industrial Units why have the planned units on the Ford Foundry site been abandoned?
One has to question why we want all the new Housing Developments. Even with the large number of available factory units the Unemployment Rate for the area is 1.7%, some 1,340 people. It could be assumed that even a modest improvement in the Economy would absorb most of the people.
"A Grater Place to Live"( Traffic)
The Projected 12,300 new homes are much too high. Particularly when one considers that the majority of this building will be on the south of both Leamington and Warwick. This in itself will cause traffic problems but when combined with Stratford District Councils plans to expand LIghthorne Heath, KIneton, Southam and Wellesbourne by a total of 4,800 dwellings which will all used Leam/Warwick for many of their shopping, recreational and school journeys, the increase in traffic will be considerable.
The ability of all this traffic moving about is seriously restricted by the number of bridges that cross the Avon and the Leam. There are 4 in Leamington, Willes Road, Victoria Terrace, Adelaide Road and Princees Drive. Of these Bridges the first 3 have reasonably free flowing traffic as they are not directly connected to the north/south route through the Town. However the Princes Drive Bridge is another matter, being directly link to the M40 by Europa Way. It is further complicated by the restricted height involved in the 2 Railway Bridges that are in the vicinity of the Bridge. This junction with its "unique" road makings which are open to various interpretations, within days extra mini cones had to be installed to prevent illegal turns. In addition the misleading lane markings that results in Europa Way traffic having to get back into the correct lane has resulted, so far, in only minor collisions. The congestion coming into the area therefore funnels a large amount of traffic onto the Banbury Road Bridge over the Avon at Warwick. How long this Bridge will withstand this traffic is a matter of conjecture but it must be a matter of concern to the Highways Department. (To appreciate the possible volumes of congestion you only have to witness the problems in Warwick when there is a road accident in the vicinity of Warwick on the M40 or the A46.)
While Air Pollution in Leamington is at a Low Level at the present during a holiday period with the Schools closed, a spike in the level of Nitric Oxide have occurred in the last week, Nitrogen Dioxide has been recorded at 30 m/metre cubed and Particular Matter 40m/metre cubed. (Ricardo AEA). If the full number of projected house were to be built it could conservatively be consider that an extra 20,000 private vehicles would be added to the daily movement which at peak times of the day would escalate the volumes of pollution.
Studies across the World have linked short term exposure to Air Pollutants to the increased admissions to hospital and increased cases of Heart Failure. (The Lancet)
A Great Place To Visit
While in the process of composing this letter I had to travel through Warwick from the Stratford Road to the Banbury Road, at midday on a Summer Friday. It was chaos, Jury St was packed from end to end with one must assume on a summers day were visitors to the Town. It would have been quicker to walk from West Gate to East gate. There were 3 delivery vans parked half on the pavement, and as I approached East Gate an Ambulance had to force its way through the traffic taking the opposite carriageway.
It is indicated that Traffic Improvements are to be made to the Jury St, Butts, Smith St, road junction. Well practically what can be done, nearly all the Building are Grade 1, or 11 Listed, and whichever way the traffic is going it passes into a further restricted highway.
The remaining life blood of Warwick is its Tourism. Over my lifetime I have watched it disintegrate from a thriving Market Town of great charm with many interesting streets and shops. It is now has County Hall and the Castle with limited parking, which on any reasonably busy day most tourists have to park in Myton Fields and walk into the Town.
Surely Warwick is a place that many Tourists only visit once, and do not recommend to their friends. The building of more Factory Units and Residential areas south of the Town can only make the situation worse.
Location of Traveller and Gipsy Site south of Warwick and Leamington
Anybody who has a plot of unfenced land lives in dread of this problem. I have had personally experience of the disruption, filth and sheer antisocial result of a Travellers site. I presume that the situation at Meriden in the last few of years has resulted in the pressure to accommodate a site in this area of the County. If the County Council is forced by Law to make provision for such a site why is it necessary to have 3 sites in this area and so many of the potential sites in the area south of Warwick and Leamington?
Conclusion
It is the nature of our society that the building of dwelling places is cheaper on open land. The fact that the land to the South of Warwick and Leamington, while being good agricultural land is not designated as Green Belt, and therefore can be developed with minimal legal restrictions. This is unfortunate because the expansion of our small conurbation over the Harbury Lane towards the M40 I feel is a mistake. The Government has applied pressure for reason that I will not explore to make more sites available for building and this wrongly has been taken as a the easiest option without the infrastructure to support the addition buildings successive Administrations have always taken the easier, and above all cheapest option. Hospitals, Schools and Main Services can be adapted and enlarged after the expansion of our Towns. If the Heathcote area produces flooding of the Myton Road after a thunderstorm the drainage can be modified.
However once the Application is approved, the increased traffic starts moving there is no going back. The health and quality of life of Warwick and Leamington will be forever irreparably damaged.

I live on St Nicholas Church Street in Warwick and worry about the effect this plan will have on the town and the area I live in.

More vehicles on this road will lead to severe congestion and levels of pollution even higher than the current illegal levels.

The infrastructure around Warwick is already unable to cope with any kind of incident on nearby roads such as the M40 and A46; I have been caught up in traffic resulting from incidents on the M40 causing it to back-up into the town and surrounding roads and it has taken more than 1 hour to travel only a few miles home.

I also can't understand the need for such a number of homes unless the Council is expecting an influx of new residents from outside the district. Where are all these new people going to work?

We already have a significant development taking place on Chase Meadow and don't need the additional number of homes proposed.

I strongly object to this plan and ask the Council to vote against it.

We have been advised to write to you regarding objections to the Revised Development Strategy Local Plan. Having studied documentation and attended meetings I wish to object to the overall plan to build the number of new homes suggested in Warwick district and in particular the 3420 planned in the south of Warwick (zone 6).

The whole basis for the homes is population growth nationally. The amount of employment land within the plan would not fulfil the amount of local unemployment and create enough for the amount of housing proposed. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people.

Warwick District has already seen much development over recent years, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

I have lived in Warwick most of my life and still live at home with my parents. I would like to continue to be able to live in the area with my own family in the future and for my children to have green fields around them and affordable homes, not to be surrounded by and urban sprawl of commuters.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands.

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion being at Warwick Gates which is in South Warwick where the majority of further development is now proposed.

By only building the amount of houses currently required for Warwick district this will discourage migration from other areas as has happened with past developments.

As it stands, I wish to object specifically about the development zone 6 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an


untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry, including up to 14,000 new jobs speculated at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick.

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times.

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road. The alterations made to the roundabout with the addition of Morrisons has made some current improvement but will not be able to handle the extra traffic created by the number of dwellings proposed for zone 6.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 2-3000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way, the area of restraint, is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc.

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

I ask, is developing the ASR a sustainable development? "Much rubbish is talked about sustainability, usually by developers. It does not mean that estates are built near to a bus stop or a primary school or a doctor's surgery; this is just moderately intelligent planning. To get to the correct definition it is necessary to go back to the source of the concept of sustainability which was the United Nations commission chaired by the Norwegian Prime Minister Gro Harlem Brundtland in the 1980s. This said that sustainable development is that which meets the needs of the present without compromising the

ability of future generations to meet their own needs; in more simple terms it means that we should not destroy something which future generations would find valuable." (www.stortfordcf.org.uk)

Surely if all this land is built on to the south there will be nowhere that the future generations can use in Warwick for recreation other than St Nicholas Park. If the land was made into recreational use, as it was designated to be, that would serve not only our generation but those of the future too.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road.

The most disturbing consequence of the proposed development of zone 6 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remained in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf and particularly page 17:

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

It was pointed out at a public meeting in 2009 that part of this area may not be needed for development in the future but we learnt at the recent Warwick Forum that 2,000 homes planned for Milverton had been transferred to zone 6, the worst area for infrastructural needs and more importantly the area of restraint.

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the proposed site at zone 6.

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses, many having been 3 form entry 30 years ago now down to 1 form


entry, whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton into whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

Warwick hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run.

Stratford District have now put this area forward as part of their Local Plan. Can District Councils not communicate with each other? To have this large area developed as well as the south of Warwick District will create even more stress on the road structure towards Warwick.

There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Local Plan?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. I know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and reclaim the hundreds of dwellings (including Station House, Union Court, Chapel Cross and The George) in the South Town of Leamington to private affordable starter flats, homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.

Warwick District Council's original Strategy to 2026 stated that 90% of the population live in the urban areas and 10% in rural areas. The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.



According to http://warwickdc.jdi-consult.net/ldf/readdoc.php?docid=15&chapter=4 the Preferred Vision for Warwick District to 2026 will be

"Warwick District in 2026 will be renowned for being:
1. 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, contributed towards creating high quality safe environments with

low levels of waste and pollution, and made a meaningful contribution to addressing the causes and potential impacts of climate change;"

If this building work is allowed to go ahead as it stands, it will be far from that.

The Core Strategy also pointed out that the development should be directed towards the south of the urban area and this has been carried forward into the Local Plan apparently to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry. What this is in fact doing is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

If Green Belt land was taken to the north of Leamington and south of Kenilworth, to the east and west, to build the bulk of the houses required for Warwick District and included a supermarket for the residents of north Leamington, Lillington and Cubbington this would alleviate the need for them to travel to the south of Leamington or Warwick to shop and would not cause incursion into the West Midlands and Coventry or encroach on the current residents of those areas.

This Green Belt land could then be reclaimed to the south of Warwick and Whitnash and residents of the new dwellings would be a more central position for employment in Warwick, Leamington, Kenilworth and Coventry.

I urge Warwick District Council to revise the whole plan taking into consideration the views of the residents of Warwick, not allowing any further planning applications to be passed on land within the Local Plan until it is fully agreed and finally to consider the overwhelming number of objections received from Warwick residents at previous consultations.

I am a resident of Bishops Tachbrook, where I live with my wife and family.
We have lived in the village for 9 years and chose the location because we wanted to live in a quiet village location away from the town centre.

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

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

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

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

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


The local infrastructure cannot support such a significant number of houses in one area. The Southern Site already has significant issues in terms of volume and flow of traffic. The RDS does not contain any evidence to show that the proposed infrastructure improvements would alleviate any of the problems that would come with such a large development. No number of dual carriage ways will improve the flow of traffic through the 'pinch points' such as crossings of canals, rivers and railways and the RDS does not provide any realistically deliverable to solutions to these problems. There are major problems for traffic trying to get into Leamington on weekday mornings when the traffic backs up all the way onto the main carriage way on the M40. Appendix E of the Warwick Strategic Transport Phase 3 Assessment shows traffic speeds of only 0-10 mph in large parts of Warwick. Any increase in traffic, never mind the exceptionally large numbers proposed in the RDS, will make this situation worse. Rather than increasing trade in the town centre it is likely that people would be put off visiting the shops because of the volume of traffic. This view was supported by the Chairperson of the Warwick Chamber of Trade, who echoed this point at the public meeting I attended.

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

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

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

Why are we insistently building on prime agricultural land? Surely this land is needed to feed the ever growing population of the country or we will become more reliant on importing food and pushing prices up even further. Obviously the developers prefer this option as it's easier and means more profit for them.

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

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

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

I am also concerned about the negative impact these sites will have on local house prices and increases in house and car insurance. Statistics show a rise in crime rates.

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

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We are writing to express our concern about the proposed development of land south of Warwick. We've attended public meetings and attempted to provide feedback through that channel (in fact the first one held at Warwick Gates Community Centre which was somewhat a debacle, offering little chance for proper discussion or feedback from the panel).

As residents of Warwick Gates since 1999, we have felt the impact of the ever increasing traffic congestion and the quick fixes which have not resolved the problems (i.e. new junction at Gallows Hill and the road layout near Morrisons). At the public meeting it was suggested that traffic wouldn't be a problem as people would be heading out to work towards Banbury, and that adequat infrastructure would be put in place but this really is not the case - the new proposals are simply going to add pressure through Warwick and Leamington town centres which are barely coping as it is and do not have room for road widening for instance. Neither have we been provided with any evidence that the sheer number of homes proposed are necessary, nor why the area near Milverton cannot be developed better placing residents to have access to the A46 and other routes to Coventry, an equally valuable employment region alongside Banbury.

Having resided at Warwick Gates for over a decade, and in fact moving in in the first year or so of devlelopment, we've already lived through the empty promises of locating a primary school on the estate - which never happened. As such we have this year also experienced the school places shortage - when our son was not given a place at his priority school of Briar Hill. The Local Plan proposes several schools but we have little faith that even one will be provided - as ever more land is given over to lucrative deals with property developers.

It seems that WDC are determined to take what was once a beautiful area and cram it full of new builds that need cars to get from A to B, as public transport links are poor (we've tried using the local buses but they are infrequent and ridiculously expensive compared to the car, particularly if there is more than one passenger).

We would also welcome further information as to why the proposed traveller sites have so much land attributed to each plot, when we, as private purchases, have half that available space on what is deemed a large property. It seems unnecessarily 'generous' given that the beneficiaries are not tax payers or contributing to the wider community.

We look forward to hearing your response,

OBJECTION TO THE LOCAL PLAN FOR THE REVISED DEVELOPMENT STATEGY

This is not a plan or a Consultation Document it is a mish-mash of isolated ideas and unconnected thoughts without any joined up thinking. I am repeating what I said at the meeting held at Hill Close Gardens a year ago. Fundamentally my views have not changed.

My major objections are as follows:

1. There cannot be any development in this area without the building of

* A new hospital which is fit for purpose as Warwick Hospital cannot cope with potentially 20,000 - 30,000 new patients
* Two new secondary schools need to be built and I can only see a site for "possible Secondary School". This has other implications on both schools in the area and on traffic flows at peak times.
* Where are these people going to work? Is it Sir Peter Rigby's new Gateway scheme that the WDC planners are so keen on?

2. No traffic assessment can have been done because if that is the case then the overwhelming case cannot be in favour of bringing traffic over a Grade II listed bridge that is already crumbling as the 7.5 tonne weight limit is regularly ignored. You only have to stand at the end of Myton Road between 8.00am and 9.00am or between 5.00pm or 6.00pm and you can see the effect. Warwickshire County Council's record in traffic management schemes is not one to have confidence in considering the mess they made of the recent "improvements" to the High Street and Jury Street. Indeed if these plans come to fruition then many of the streets in Warwick and surrounding environs will be just be arteries and I think here of Smith Street, St Nicholas Church Street, Bridge End, Myton Road, High Street, Jury Street, Castle Hill, Europa Way etc. The list is almost endless.

It has been suggested that the junctions become traffic light signal controlled. If they are anything like the new scheme that has been put in place at Princess Drive and the Recycling Centre then they will be an accident waiting to happen. It also adds nothing to the traffic flow and is far too complicated.

If the Gateway scheme is to be the major employer then again it is naïve on the part of the traffic planners to say there will be little impact on traffic flows. Most people will therefore be making their way to the A46 Trunk Road and either Avon Bridge or Europa Way will become very congested indeed. It is already indicated that traffic at the morning peak will be moving at less than 5mph. This means maximum pollution for very little reward.

3. At a previous meeting at Hill Close it was indicated that traffic issues at peak times would be a real problem issue due, in part, to school starting and finishing times. It was suggested that schools could be spoken to stagger their start and finish times. This I felt was naïve in the extreme as many parents drop their children off on the way to their place of work and this will not change. Thus that will not improve.

4. Developers will only build houses if they can sell them. Do people want to buy them and are they affordable. However once planning permission is in place then it is very difficult to stop it. This will be like having the 'Sword of Damocles' hanging over us.

5. Surely 12,000 houses are excessive. I would have thought a maximum number of half that amount is what is actually required which would have a dramatic effect on the plan. Why is the vast majority of the development on Greenfield sites and not Brownfield ones. I understand that only 9% of Britain is developed but when cuts out most of Scotland, Wales some areas of Derbyshire, Yorkshire, Northumberland, Cumberland and others then the picture looks vastly different. We are already overcrowded as an island. Why must the residents of Warwick (mainly) and Leamington be made to suffer?

I am not a 'serial' objector but a very concerned resident of what is a jewel in the crown of Warwickshire that is likely to be desecrated by this plan.

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

* I cannot see any reason why the green belt should be built upon.
* The area off Old Milverton Road is used for exercise (walkers, joggers and dog walkers). The fields are heavily used in this way and have many public footpaths crossing them.
* Any building would mean that Leamington, Kenilworth and Warwick will just merge into one sprawling blob. This will not be attractive to those wanting to continue their businesses in Leamington.
* We need to keep Leamington attractiver and to provide for a range of housing. I understand that Londoners thinking of moving to the area complain that there is not enough
* this end of Leamington is saturated with housing
* the allotments must remain.
* any development in this area will mean additional infrastucture which will further degrade the area (roads,schools, waste collections etc)
* any housing would be on higher ground than the existing ones and would dominate the houses and the landscape
* once the area is developed it will be gone FOREVER
* we need our green spaces, we need our 'lung'.
* if there is further building here the reasons why people want to come to Leamington will be negated.
I would argue that we need so many more houses in this area anyway.

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