RDS2: The housing requirement of 12,300 homes will be met from the following categories of sites

Student housing continues to be an issue within the area, with a lot of houses occupied by students, if more purpose built accommodation, like the new development (Station House) opposite Leamington Train Station was created then houses currently occupied by students could either be made available to rent or buy on the open market.

Figures should be collated to show the number of houses currently occupied by students in the area to see if changing these use of these properties and building additional purpose build student accommodation will help.

In addition how many properties are currently empty in the area. Although I doubt this number is significant, it would help in understanding if this could also assist in achieving the housing requirement

I am writing to register my objection to the development of any Greenbelt land to the north of Leamington Spa.

I am aware that the revised Local Plan has proposed moving development of this land elsewhere within the Leamington Spa region, and I am very pleased that all the very valuable aspects that the Greenbelt offers may now be protected.

I do, however, very strongly wish my objections to any future development of this land to be registered, as I understand that WDC are consulting with Coventry City Council about providing housing for Coventry, and the Greenbelt land to the north of Leamington may still be considered as a potential development area.

Please acknowledge receipt of my objection and I wish to be kept informed an matters relating to this very important area surrounding the north of Leamington which should be preserved as Greenbelt.

A sensible mix of what is required.

The District Council's proposal for 12,300 new homes by 2029 exceeds the local need which is for about 6,000 new houses. I belive that concentrating 4,500 of these homes on land south of Warwick would create a huge new built-up area. This would result in a rapid growth in population that would put unsustainable pressure on the road infrastructure, hospital and school services, local water supplies and drainage. It would also increase traffic congestion and pollution. Siting these houses on existing agricultural land would leave brownfield industrial sites in the area underexploited.

Sport England can not and will not support the release of any land for housing which is currently used or was formally used for sport unless the land in question is shown to be surplus for sport through a robust assessment. Sport England is aware that WDC is producing a Playing Pitch Strategy, but until it is adopted Sport England would expect any planning application to show through a robust assessment, that the sports land/facilities are no longer required.

As I believe the number of homes required is only around 5,000-6,000 there is no need for any further allocation of development.

1. The increase in housing estimates from 10,800 to 12,300 is without foundation, being still subject to review against adjoining authorities (e.g. Coventry and Stratford) and being based on challengeable methods. Indeed an alternative authoritative report by Bishop's Tachbrook Parish Council suggests a likely requirement of 5,400 homes, less than half the WDC estimate. Even this number will add over 10,000 people and some 15,000 vehicles to the area, resulting in additional traffic congestion and air pollution, both already at unacceptable levels.
2. An increase from 100 to 150 new homes has been included for Hampton Magna, resulting in additional population higher than the total at this time in the adjoining village of Hampton on the Hill. Amenities for these villages are already overstretched. The single road through these villages is a "rat run" by speeding traffic to Warwick Parkway and the M40. More and urgent attention should be given to improving the existing infrastructure.
3. The alternative estimate of 5,400 homes requires no development to take place in the villages mentioned in the Plan, thereby protecting the Green Belt and the Rural nature.
4. Local MP Chris White has written to Cllr. Doody on 24 June 2013 expressing concerns about the housing estimate and urging WDC to "respect the views of local residents".
5. The selection of 20 proposed sites for Gypsies and Travellers has caused unnecessary alarm among residents. Six of the sites are within two miles of Hampton on the Hill and Hampton Magna, an area with already overstretched amenities. The 31 pitches required should be placed on the fringes of other, much larger, proposed housing developments, which will provide convenient access to better amenities.

1. The increase in housing estimates from 10,800 to 12,300 is without foundation, being still subject to review against adjoining authorities (e.g. Coventry and Stratford) and being based on challengeable methods. Indeed an alternative authoritative report by Bishop's Tachbrook Parish Council suggests a likely requirement of 5,400 homes, less than half the WDC estimate. Even this number will add over 10,000 people and some 15,000 vehicles to the area, resulting in additional traffic congestion and air pollution, both already at unacceptable levels.
2. An increase from 100 to 150 new homes has been included for Hampton Magna, resulting in additional population higher than the total at this time in the adjoining village of Hampton on the Hill. Amenities for these villages are already overstretched. The single road through these villages is a "rat run" by speeding traffic to Warwick Parkway and the M40. More and urgent attention should be given to improving the existing infrastructure.
3. The alternative estimate of 5,400 homes requires no development to take place in the villages mentioned in the Plan, thereby protecting the Green Belt and the Rural nature.
4. Local MP Chris White has written to Cllr. Doody on 24 June 2013 expressing concerns about the housing estimate and urging WDC to "respect the views of local residents".
5. The selection of 20 proposed sites for Gypsies and Travellers has caused unnecessary alarm among residents. Six of the sites are within two miles of Hampton on the Hill and Hampton Magna, an area with already overstretched amenities. The 31 pitches required should be placed on the fringes of other, much larger, proposed housing developments, which will provide convenient access to better amenities.

I dispute the need for 12,000 houses in Warwick District as independent
sources indicate less than 6,000 required and ask what is in it for the
council to build so many houses.

Such a massive development would turn the historic town of Warwick into an
urban sprawl.

The already overstretched infrastructure cannot cope with what would be a
massive increase in traffic, being out of town most people would have a
car, working couples possibly two. The road bottlenecks at Castle Hill and
the viaduct cannot cope with thousands of extra vehicles.

I dispute that no building can take part on the green belt to the north as
the council have already allowed green belt land to to be included in the
Gateway project.

I object to large areas of farmland being built on as this will have a
serious impact on wildlife with the removal of hedges.

There also a serious risk of flooding in the Aragon Drive / Saumur Way area
if the adjacent farmland is cleared.

Allowing traffic to access any new building behind Saumur Way will increase
the risk to the many school children who use the cycle path that runs past
the proposed development.

The council is being less than open about the developments as the plan
calls for 12,000 homes but only 6,000 identified so far. With no building
in the North of the district the other 6,000 can only be built in the South
but WDC have been evasive when asked the question about this

Windfall Sites: Concern about the estimate number of windfall sites and the lack of clarity at this stage as to where these would be - they would have significant impact on village sites in addition to the numbers already proposed for these locations

The existing identification of 6,000 homes is sufficient for natural growth and can be accommodated without the need for massive infrastructural changes. An additional 6,600 homes are simply unnecessary. Any growth should be incremental to existing settlements and distributed evenly.

An estimate of 2,800 windfall sites has been made, but there is no clarity on either their location or their nature other than I understand that WDC has stated that the rural figure is 504. The possible implications for a village, such as Lapworth, are not clear and are of concern.

You are seeking to allocate far too many homes within this plan - with no assurance that they are or will be needed. You should reconsider other lower suggestions and increase numbers later only if further need is identified.

Stagecoach Midlands has no comment to make.

The whole of this strategy is based on a false set of figures which do not reflect the population growth of the resident population. This will give rise to the possibility of a judicial review on the grounds that the figures have been incorrectly prepared and, if that was a deliberate act by councillors, could lead to either a surcharge on the councillors or proceedings for misrepresenting the statistics in a manner causing damage to the local environment and ignoring the wishes of the electorate expressed in the previous consulation..

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Dear Dave

Warwick Local Plan consultation - Duty to Cooperate

Thank you for consulting us on a number of documents. Please note that this letter has not yet been formally endorsed by Members, I will confirm for you in due course as this happens.

Revised Development Strategy

We welcome the recognition that the interim housing target is subject to change as a result of the joint SHMA and Duty to Cooperate. We have no comments to make as regards the locations that you are considering for large scale site allocations, notably for housing development. I am sure that we will agree that the scale and location of housing provision is a strategic issue, and we intend to come to a formal agreement between us (including the wider housing market area) in due course following publication of the joint SHMA. We wonder whether the windfall sites allowance is optimistic, given the 'policy on' trend, but anticipate this issue being resolved following the joint SHMA. We do not anticipate any significant direct impact on the infrastructure of Coventry to result from any of your proposed site allocations.

We may wish to consider the relationship between the committed employment schemes of Friargate in Coventry City Centre, Warwickshire Gateway, and the proposed office allocation at Thickthorn, Kenilworth.

Sites for Gypsies and Travellers

The approach being taken, to seek to accommodate the entire projected need for permanent and transit sites, is welcomed as the most responsible way forward. It is not clear to us whether it is intended that a 6-8 pitch, or 12 pitches, be provided on transit site/s.

We have no comments to make with respect to the specific sites that you are considering.

Planning policy for houses in multiple occupation and student accommodation

We note that a substantial number of students attending University of Warwick in particular reside in Warwick District, and further that there are concentrations of shared student housing in south Leamington. You may be aware that we are currently undertaking a rigorous evidence gathering exercise, including evidence from the University of Warwick, about this issue. We note the existence of an "Article 4 Direction" relating to HMO's in the south of Leamington, and have no evidence of any adverse impact of that on Coventry.

The proposed policy criteria set out appear to us to be appropriate and reasonable, and therefore raise no objection.

We look forward to continuing to work together to resolve strategic issues, to our mutual benefit. Should you have any queries, or wish to discuss the content of this letter further, please do not hesitate to contact me.

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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


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

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

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

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

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

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


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

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

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

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

I move for this plan to be rejected in its entirity

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I write to support the overall shape of the New Local Plan Revised Development Strategy (RDS), certainly compared to the original Plan, although with some reservations, in particular about its overall scale. I very much support the absence of development on the North Leamington Green Belt around Milverton and Blackdown.
I am pleased that the Council has recognised that the Exceptional Circumstances to develop the Green Belt to the North of Leamington do not exist and that as a consequence the risks of the Local Plan being found unsound at public enquiry are reduced. It is vital to preserve the limited green space between Leamington and Kenilworth, otherwise there is a real risk that Leamington and Warwick will merge with the West Midlands conurbation.
The Green Belt in this area meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. It would be worth referencing the Joint Green Belt Review 2009 which confirmed the high value of this stretch of Green Belt and is key evidence, more clearly in the Plan document. Development in Kenilworth, Baginton and Lillington may already take land from this essential Green Belt and further development on it would not be sustainable. It must not be permitted.
But I am also opposed to any encroachment into other Green Belt designated land in the District if it can possibly be avoided and believe a further review of some assumptions and principles could make this unnecessary. Certainly if it goes ahead the Council should seek to designate additional Green Belt land of the same size or greater than the Green Belt being developed - for example in the Asps area for the reasons highlighted in 4.3.8
My reservations and suggestions for further review are:
1. Windfalls
There is a large increase between the original and the revised Plans in the number of units being added through windfalls within existing planning boundaries, reducing the units required on new land by 1500 or almost 20% (the change was very clear in the public presentation). This huge revision suggests that the assumptions made for windfall or infill developments coming forward during the Plan period of slightly under 200 units per year (page 13 table 2) - there were 600 in the last year alone - may be significantly understated. 50 additional units a year would remove a further 750 from the newbuild total, roughly equivalent to the proposed greenbelt expansion. The assumption should be carefully reviewed.
2. Brownfield sites
The assumption here also looks modest.
Does the Plan include any assumption here or elsewhere about development of the old Potterton site and possibly greyhound track land alongside the Avon in Warwick ? Only phase 1 has been completed and filled (with difficulty - see below).
Has the recreation ground alongside the river, which is linked to the Edmonscote sports track been considered as suitable underutilised open space ?
Given shop vacancy rates and forecast trends, has sufficient allowance been made for conversions to residential in shopping areas, especially if major projects such as Chandos Street were now assumed to be available for high density accommodation ?
3. Building Densities
It is not clear if the new planning framework will specifically encourage higher density developments eg 4-8 storey townhouses/apartments within existing planning boundaries and in particular close to public transport services. It certainly appears not for newbuild proposals (5.1.3) but presumably this could also be adjusted in the new homes criteria at least in part. This would both be in line with the character of central Leamington and Warwick and take further pressure off the need to build on agricultural land. This option should be given further consideration.
4. Impact on Agriculture
It is not clear from the RDS what the impact would be on agricultural production and whether this has been considered in any judgements about possible alternatives, such as a higher density strategy outlined in point 3.
5. Building Quality and Mix
The criteria set out in 5.14 are sensible as far as they go. If there is any scope in the Plan for specifying higher standards of architecture (innovation, variety, local character etc) and of minimum living/garden space requirements I would strongly support those additions. Such criteria would help developers - and planners - avoid the costs and embarrassment of high vacancy rates on newbuild. The best recent example of this locally is probably the unattractive, rabbit-hutch sized first phase development on the old Potterton site. How the Plan might specify or aim to influence such desirable criteria should be considered.
6. Southern Green Park
It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than for development in the North. For instance putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible and if possible larger. It could be crossed by cycle-ways and would act as a green-lung to reduce air pollution.
7. Transport
The cycling plans look convincing. However the enhanced public transport outlined in the RDS seems unambitious and sketchy. Frequency of links should be at least as good as the current G1 and G2 services (every 8-9 minutes) with evening and weekend improvements throughout the District, if congestion is to be convincingly minimised. More detail is required in the Plan demonstrating how services will attract sufficent use to achieve this (coverage, frequency etc).
Two further points might be usefully touched on as part of a wider discussion of transport needs for a growing District:
- planned improvements at the slightly out-of area Gaydon interchange with the M40 will already be in place to assist flows to the south of Leamington (5.1.15)
- how will bus services (new and existing) connect to Railway stations and what is expected in the way of improved rail connections across the District (eg frequency to Coventry, a Kenilworth station) in order to reduce overall road use, pollution and congestion.
Subject to these reservations I broadly support the revised strategy and would make the following points:
8. A Joint Strategic Housing Needs Analysis is currently being performed with Coventry City Council. If this review identifies that it is necessary to increase the number of houses above those currently proposed, as I hope it wil not, I believe that there is sufficient non Green Belt land to accommodate this additional development.
9. The RDS has a fair distribution of new housing across the District. 16% of the new houses will be in the Green Belt North of Leamington, at Thickthorn and Lillington. (However see the fourth paragraph of this letter and point 1 above). 15% of the proposed development will be in Warwickshire Villages.
10. Given that the RDS will no doubt require some building on new land, even after possible adjustments arising from points 1-3 and 8, the proposal that most of the new development is located close to where employment opportunities already exist (e.g. industrial parks to the South of Leamington & Warwick) is logical. It provides an opportunity for people to live close to their place of work, reducing or eliminating commuting for many people, reducing pollution & improving quality of life. Furthermore there is ample space to build to the south of Leamington as the next nearest town is Banbury.
11. Focusing development in the South, in one broad area, ensures adequate public services can be provided and developed to meet the needs of the new population. These services can be designed to meet the exact needs of that new population and planned within easy walking and cycling distance, minimising traffic congestion. If development were to be more spread across the district public services would have to be developed in an inferior and unacceptable "make-do-and-mend" fashion which would provide poorer levels of service to both existing and new residents in those areas.
12. The RDS provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district as it would have forced people to travel south to employment land, shopping (e.g. supermarkets) and the M40. Loss of vital Green Belt recreation land would also have resulted in more people travelling by car for recreation.
Less overall development outside the present limits - and particularly within the Green Belt - should be the main objective.

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