RDS3: The Council's Preferred Option for the broad location of development is to:

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Dear Sirs,
I must object in the strongest terms to the plans to turn Sydenham, Whitnash, Warwick Gates, Bishops Tachbrook and South Warwick into one giant horrendous conurbation.
Who do expect to buy all of these houses?
The banks aren't lending and people aren't spending. There is a risk of building a ghost town.
We simply DO NOT NEED this many houses
I have lived on Warwick Gates since the early days in 1999. It is my observation that over half of the houses built were not occupied by local people, but people moving into the area because of its proximity to the M40 and convenience for commuting to Birmingham, London, Coventry, Banbury, Oxford etc. If you believe that there is a local housing shortage, this is not the answer. I guarantee you that the houses will be filled by people moving into the area. Now more people moving into the area might be great news for Morrisons who (for some reason) have been allowed to build yet another supermarket that we neither want or need, but it is terrible news for the current residents that you are supposed to be representing.
It's not fair
I heard in last week's meeting at Whitnash Primary School that just saying 'it's not fair' will be ignored even if it is blatantly true. However, as my representatives in local government, I firmly believe that being fair to local residents is absolutely your duty and your obligation. This ISN'T FAIR. I feel as though I am being told that I am going to get 10-20 years of disruption, development, dirt. Followed by permanent increases in pollution, traffic, destruction of countryside on a massive scale in a circle around my house! This IS NOT FAIR and MUST NOT be allowed to happen. If we really need the houses (which I dispute) then it is your duty to share them around the area, it cannot be OK to imprison our houses inside this planned circle of destruction.
Brownfield sites
In the presentation at Whitnash Primary school, we were told that the council is taking a 'Proactive approach to brownfield sites'. How can this be true when the biggest and best brownfield site in the area has been used to build yet another unnecessary supermarket. What a golden opportunity wasted to build in-town housing and start addressing the alleged housing shortage. Instead we get a plan to destroy more countryside. Your plan has no credibility.
Massive increase in traffic
There WILL be a huge increase in traffic. To be honest, just telling me that you have a computer model that says everything will be fine doesn't wash. The traffic congestion is already terrible. There is no way that throwing another 12,000 cars into the mix is going to be OK. Building dual carriageways to squeeze more cars in more quickly will clearly make everything worse.
Air pollution
I am told that air pollution in Warwick is already at unacceptably high (illegally high someone said?) levels. There is no way that throwing another 12,000 cars into the mix is going to be OK.
Emergency services
We heard that there are only 4 points to cross the river. All of which are single lane bottlenecks. All of the services are north of the river, yet you are proposing to massively increase the population South of the river. Not only would this ruin our countryside, our air, our roads, our views, but you will adversely affect our access to emergency services. On this plan I would expect to see a new hospital, a new fire station, a new police station south of the river to address the problem.
Further decay of Leamington town centre
I believe that the prospect of huge population growth south of Leamington is driving the expansion of the Shires retail park and surrounding area. Clearly Morrisons, Aldi, Debenhams, John Lewis etc would not be moving in without being pretty sure that the developments will go ahead. This will continue to drag shoppers away from the town centre and we will get yet more boarded up, closed down units.
Local community & identity
I fear that because I can't put a monetary value on quality of life, it doesn't matter to the planners. It does. Whitnash IS Whitnash, Warwick Gates IS Warwick Gates. This is our home, our identity, where we belong. It MEANS something to us. Your plans destroy all of that permanently and there will no going back.
Gypsies
If all of the above wasn't enough, I'm also being told that you plan to create 20 gypsy sites in Warwick District. Why is the vast concentration in a circle around my house again! You know this is unfair. Why must you keep dumping from a height on my area? ITS NOT FAIR. You cannot look at the plan and think that it's OK. You exist to look after the interests of the district - LOOK AFTER MY INTERESTS! It's not OK to keep dumping on one corner while the rest of the district do not take their share. Yes I am worried about crime, yes I am worried about house prices, insurance costs, quality of life and safety.
Final plea!
I can see that there is massive commercial pressure to build 1000s of new houses. It can't be a coincidence that we have more supermarkets being built a stone's throw from the 'proposed' developments.
I guarantee you that 99% of the local population do not want this. It is disturbing to think that it's probably going to happen anyway. This is supposed to be a democracy.
This madness has to stop. You can't just keep building more and more houses for ever. Enough is enough. Please be strong, please be brave. Fight central government, fight the big businesses, save our home.

We are writing to register our objections and give our views on the suitability of the following Gypsy and Traveller Site Options together with the Revised Development Strategy.

GT05 - Land at Tachbrook Hill Farm, Banbury Road - (Site 5)
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would place further pressure on the local highway network infrastructure and is unsustainable.
* Development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (e.g. Site 12) totally unviable.
* Development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
* Warwick District Council have disregarded their own Rural Area Policies, especially RAPs1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and Caravan Sites). In all respects the site fail to meet the policy criteria to allow any form of development.
* The development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the site.
* This site is not a location which allows peaceful and integrated co-existence with the local community.

Cont/d .....

GT06 - Land at Park Farm, Spinney Farm - (Site 6)
* This site is situated on historic landfills which though closed still has the potential to release greenhouse gases and are unsuitable for any form of permanent habitation and occupation.
* This site sits immediately approximate to the Asps which Warwick District Council decided, after further research regarding the landscape and transport impact of development, that the site should remain open due its value as a backdrop to the historic Warwick Castle Park. The Revised Development Strategy, therefore, excludes the Asps and should also exclude the adjoining Sites 6 and 9 for the same reasons.
* There have been a number of reported wild deer sightings on this land and there is a population of deer that roam freely across the Castle grounds on to this site and beyond.
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors' surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would place further pressure on the local highway network infrastructure and is unsustainable.
* Development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (e.g. Site 12) totally unviable.
* Development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
* Warwick District Council have disregarded their own Rural Area Policies, especially RAPs1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and Caravan Sites). In all respects the site fail to meet the policy criteria to allow any form of development.
* The development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the site.
* This site is not a location which allows peaceful and integrated co-existence with the local community.


Cont/d .....

GT09 - Land to the north east of M40 and south of Oakley Wood Road - (Site 9)
* This site is situated on historic landfills which though closed still has the potential to release greenhouse gases and are unsuitable for any form of permanent habitation and occupation.
* This site sits immediately approximate to the Asps which Warwick District Council decided, after further research regarding the landscape and transport impact of development, that site should remain open due its value as a backdrop to the historic Warwick Castle Park. The Revised Development Strategy, therefore, excludes the Asps and should also exclude the adjoining Sites 9 and 6 for the same reasons.
* There have been a number of reported wild deer sightings on this land and there is a population of deer that roam freely across the Castle grounds on to this site and beyond.
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* Development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (e.g. Site 12) totally unviable.
* Development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
* Warwick District Council have disregarded their own Rural Area Policies, especially RAPs1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and Caravan Sites). In all respects the site fail to meet the policy criteria to allow any form of development.
* The development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the site.
* This site is not a location which allows peaceful and integrated co-existence with the local community.

Cont/d .....

GT10 - Land at Tollgate House and Guide Dogs National Breeding Centre - (Site 10)
* This site is situated on historic landfills which though closed may still have the potential to release greenhouse gases and are unsuitable for any form of permanent habitation and occupation.
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* Development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
* This site is not a location which allows peaceful and integrated co-existence with the local community.

GT12 - Land at north and west of Westham Lane (area of search) - (Site 12)
* This site sits within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk.
* A number of residents have reported the existence of water voles in and immediately adjacent to these sites. Water voles are, of course, now a legally protected species.
* There are inadequate pedestrian crossing facilities for safe access into the village.
* Vehicular access to this site is from the A429 trunk road which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of accidents on it since its opening, including a fatality. The existing access into the site is entirely inadequate.
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* Development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (e.g. Site 12) totally unviable.
* Development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
* Warwick District Council have disregarded their own Rural Area Policies, especially RAPs1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and Caravan Sites). In all respects the site fail to meet the policy criteria to allow any form of development.
Cont/d .....
* The development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the site.
* This site is not a location which allows peaceful and integrated co-existence with the local community.


GT15 - Land to east of Europa Way - (Site 15)
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* This site is not a location which allows peaceful and integrated co-existence with the local community.


GT16 - Land to north of Westham Lane and west of Wellesbourne Road, Barford - (Site 16)
* This is actually the flood compensation area from the Barford bypass build and contains a permanent central pond and is unsuitable for any form of development.
* This site sits within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk.
* A number of residents have reported the existence of water voles in and immediately adjacent to these sites. Water voles are, of course, now a legally protected species.
* There are inadequate pedestrian crossing facilities for safe access into the village. Vehicular access to this site is from the A429 trunk road which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of accidents on it since its opening, including a fatality. The existing access into the site is entirely inadequate.
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* Development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (e.g. Site 12) totally unviable.
* Development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
* Warwick District Council have disregarded their own Rural Area Policies, especially RAPs1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and Caravan Sites). In all respects the site fail to meet the policy criteria to allow any form of development.


Cont/d .....
* The development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the site.
* This site is not a location which allows peaceful and integrated co-existence with the local community.


GT17 - Land of Southbound carriageway of A46 (former Little Chef) - (Site 17)
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* This site is not a location which allows peaceful and integrated co-existence with the local community.


GT18 - Land on Northbound carriageway of A46 (former Little Chef) - (Site 18)
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* This site is not a location which allows peaceful and integrated co-existence with the local community.


GT20 - Land at J15 M40/A46 - (Site 20)
* This site is situated on historic landfills which though closed may still have the potential to release greenhouse gases and are unsuitable for any form of permanent habitation and occupation
* Vehicular access to this site is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.
* The site is not sustainable in terms of multi modal accessibility. It does not offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycles routes, or by bus. The only means of accessibility is by car which would lace further pressure on the local highway network infrastructure and is unsustainable.
* Development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (e.g. Site 12) totally unviable.
* Warwick District Council have disregarded their own Rural Area Policies, especially RAPs1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and Caravan Sites). In all respects the site fail to meet the policy criteria to allow any form of development.
* The development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the site.
* This site is not a location which allows peaceful and integrated co-existence with the local community.

Availability
Only 3 of the sites listed are available, namely sites 15, 17 and 18. By definition the remaining sites are not deliverable.

Ecology and Environment
All of the sites have some ecological value and environmental issues which does not appear to have been assessed.

Warwick District Council should have identified Brownfield sites within the existing urban areas of Kenilworth, Warwick and Leamington for Gypsies and Travellers. These sites would be more suitable ad sustainable and would enable better integration in to the local community. Despite such sites existing, they are all being proposed for redevelopment for more valuable uses.

Warwick District Council should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments in Kenilworth, Warwick and Leamington. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, doctors surgery and shops which are accessible on foot, on bike, by bus and by car.

Warwick District Council should revisit its Greenbelt Policy and release sites to the north of Warwick and Leamington which would reduce the pressure to allocate land for all forms of development during the new Local Plan period to the south of the District.

Warwick District Council should consider allocating an area of land to the south of Warwick and Leamington including The Asps and Sites 5, 6, 9 and 10 as Greenbelt to provide a "buffer" to the proposed developments to the south of Warwick and Leamington and/or to extend the proposed Bishops Tachbrook Country Park as far as the Banbury Road near to Warwick Castle Park. This would ensure the villages in the south of the District retain their identity and are not allowed to be "swallowed up" by Warwick and Leamington over time.

see attached

My comments relate to 6 main areas: scale of development, distribution, infrastructure, flooding, quality of life and listening to residents.

Scale of development

Previous Local Plan projections in 2012 suggested 10,800 houses needed to be built in Warwick District by 2029; new 2013 figures suggest 12,300. I have concerns that neither of these figures are accurate and, accounting for natural growth and an allowance for migration, only 5400 homes are required. This calculation was undertaken using 2011 census data by Bishop's Tachbrook Parish Councillor Ray Bullen. In support of a much lower figure, in December 2012 Warwick District Council's own consultants G.L. Hearn gave an Economic and Demographic Forecast Study projection of 4405. Given the low unemployment rate of 1.7% in Warwick District, growth for employment is not a valid argument to explain this level of growth. I believe there is a very strong case that the scale of development is far in excess of what is required through natural growth and reasonable levels of migration.

Warwick District Council's 'Strategic Housing Land Availability Assessment' states that the total capacity of the District is approximately 13,385 homes between 2014-2029; this Local Plan's projections use up 91.8% of total capacity. As this would leave virtually no room for future expansions, the local environment would undoubtedly be negatively impacted by future developments.

The level of growth proposed is unsustainable and according to the Local Development Framework, Annual Monitoring Report 2011, 'the majority of this [housing] growth has resulted from people moving into the District from other areas, notably the urban areas of Coventry and Birmingham...[a] key factor behind this trend has been the particularly high level of house building that has taken place within the District during that period.' If migration has been fuelling the housing growth then the more homes that are built, the more people are likely to move out from Coventry and Birmingham to live in Warwick District. This in turn will put more pressure on housing stock as these new residents have families who will require housing if they are to remain nearby. This means large scale development will exacerbate rather than solve the local housing issues. Warwick District Council needs to revisit the scale of development to bring it down to sustainable levels.

The Bishop's Tachbrook housing needs survey identified a local need for only 14 homes; 10 'affordable and 4 'market' homes. A mixed development of 25-30 homes could provide the 10 affordable homes required so why have the numbers 100-150 homes been chosen for Bishop's Tachbrook against the local evidence base?

Distribution

The consultation document shows that 70% of the proposed housing is concentrated in the south of the district, in Leamington, Warwick and Whitnash. The Green Belt in the north of the district has been protected but insufficient provision has been made for the green field sites in the south. This leads me to question the fairness of this distribution, with the residents of the south bearing a greater burden than those of the north.

Infrastructure
The distribution of the proposed new housing raises concerns regarding infrastructure. A number of improvements over the last 12 months have not been project managed effectively, namely the High Street/Jury Street roadworks and the Morrisons development roadworks. Additionally, it took over 10 years for improvements to the Gallows Hill junction to be implemented so I have serious concerns regarding when any proposed infrastructure improvements will be undertaken to complement the housing developments. The knock on effect for existing residents whilst waiting for improvements to take place would be unacceptable. I also believe that even with the planned upgrades, the strain on local infrastructure will be intolerable and whilst the upgrades are taking place there would be a considerable inconvenience placed on local residents and businesses.

Flooding

The Tach Brook runs parallel to Harbury Lane, approximately equidistant from Bishop's Tachbrook and Warwick Gates. The Warwick District Council and Warwickshire County Council Flooding Review in Warwick District Final Report of the Joint Panel June 2008 reported that properties in Bishop's Tachbrook were affected by the floods. If houses in Bishop's Tachbrook already flood without housing being built on the Tach Brook flood plain then it is likely that it will only get worse if the water has fewer fields to run off into. If new housing is built on the land between the Tach Brook and Harbury Lane the new housing will be built with new anti-flood defences. This would leave the existing housing, built when such technology was neither available nor necessary, more vulnerable to flooding. I lived in Cubbington village when that flooded in 2007 and the extent of the flooding was exacerbated by the inadequacy of flood defences since new housing had been built.

Constructing large areas of housing on the banks of the brook will increase the water flow and in periods of prolonged heavy rain will increase flooding risks to neighbouring authorities such as Gloucestershire and Stratford. Recognising that only 5,400 homes are required, dispersing them more fairly around the district and not directly connecting them into the river system (except by the upgraded drainage system in Leamington) would be more acceptable to downstream neighbours such as Gloucestershire and Stratford.

Quality of life

Bishop's Tachbrook is a rural village separated from Leamington town by Harbury Lane. Having lived in what was Cubbington village and seeing the erosion of quality of life as a result of infill I would not want the same happening to Bishop's Tachbrook. It has a rural character which I would like preserved by maintaining the geographical barrier of Harbury Lane. The suggestions for a country park are paying lip service to the real issue which is that the edge of Bishop's Tachbrook is a mile from the edge of Warwick Gates and if the urban sprawl comes any closer than that then the rurality of the village is lost. A country park may provide a minimum level of separation but the undulations of the land will make the new housing highly visible from Bishop's Tachbrook thus negating this token separation.

The Planning Inspector who reviewed the current Local Plan in 2006 reported that Woodside Farm should not be built on now or in the future. Warwick District Council's landscape consultant Richard Moorish in the Landscape Area Statement in 2009 wrote the following with regards the land south of Gallows Hill 'this study area should not be considered for urban extension and that the rural character should be safeguarded from development'. However, this new Local Plan appears to go against its own consultant's advice.

Listening to residents

A Neighbourhood Plan has been issued by Bishop's Tachbrook Parish Council which reflects the survey undertaken to gather residents' views. Bishop's Tachbrook residents such as I are concerned that our views will not be taken into account during this consultation. The previous 2012 Local Plan was altered after the consultation process and became much more acceptable to residents in the village. However this new Local Plan rips up any compromises made last year and in fact proposes more housing, with more of a burden borne by villagers. Consultation should not be a token gesture and the Local Plan should be altered if residents are clearly opposed to its proposals.

My comments relate to 6 main areas: scale of development, distribution, infrastructure, flooding, quality of life and listening to residents.

Scale of development

Previous Local Plan projections in 2012 suggested 10,800 houses needed to be built in Warwick District by 2029; new 2013 figures suggest 12,300. I have concerns that neither of these figures are accurate and, accounting for natural growth and an allowance for migration, only 5400 homes are required. This calculation was undertaken using 2011 census data by Bishop's Tachbrook Parish Councillor Ray Bullen. In support of a much lower figure, in December 2012 Warwick District Council's own consultants G.L. Hearn gave an Economic and Demographic Forecast Study projection of 4405. Given the low unemployment rate of 1.7% in Warwick District, growth for employment is not a valid argument to explain this level of growth. I believe there is a very strong case that the scale of development is far in excess of what is required through natural growth and reasonable levels of migration.

Warwick District Council's 'Strategic Housing Land Availability Assessment' states that the total capacity of the District is approximately 13,385 homes between 2014-2029; this Local Plan's projections use up 91.8% of total capacity. As this would leave virtually no room for future expansions, the local environment would undoubtedly be negatively impacted by future developments.

The level of growth proposed is unsustainable and according to the Local Development Framework, Annual Monitoring Report 2011, 'the majority of this [housing] growth has resulted from people moving into the District from other areas, notably the urban areas of Coventry and Birmingham...[a] key factor behind this trend has been the particularly high level of house building that has taken place within the District during that period.' If migration has been fuelling the housing growth then the more homes that are built, the more people are likely to move out from Coventry and Birmingham to live in Warwick District. This in turn will put more pressure on housing stock as these new residents have families who will require housing if they are to remain nearby. This means large scale development will exacerbate rather than solve the local housing issues. Warwick District Council needs to revisit the scale of development to bring it down to sustainable levels.

The Bishop's Tachbrook housing needs survey identified a local need for only 14 homes; 10 'affordable and 4 'market' homes. A mixed development of 25-30 homes could provide the 10 affordable homes required so why have the numbers 100-150 homes been chosen for Bishop's Tachbrook against the local evidence base?

Distribution

The consultation document shows that 70% of the proposed housing is concentrated in the south of the district, in Leamington, Warwick and Whitnash. The Green Belt in the north of the district has been protected but insufficient provision has been made for the green field sites in the south. This leads me to question the fairness of this distribution, with the residents of the south bearing a greater burden than those of the north.

Infrastructure
The distribution of the proposed new housing raises concerns regarding infrastructure. A number of improvements over the last 12 months have not been project managed effectively, namely the High Street/Jury Street roadworks and the Morrisons development roadworks. Additionally, it took over 10 years for improvements to the Gallows Hill junction to be implemented so I have serious concerns regarding when any proposed infrastructure improvements will be undertaken to complement the housing developments. The knock on effect for existing residents whilst waiting for improvements to take place would be unacceptable. I also believe that even with the planned upgrades, the strain on local infrastructure will be intolerable and whilst the upgrades are taking place there would be a considerable inconvenience placed on local residents and businesses.

Flooding

The Tach Brook runs parallel to Harbury Lane, approximately equidistant from Bishop's Tachbrook and Warwick Gates. The Warwick District Council and Warwickshire County Council Flooding Review in Warwick District Final Report of the Joint Panel June 2008 reported that properties in Bishop's Tachbrook were affected by the floods. If houses in Bishop's Tachbrook already flood without housing being built on the Tach Brook flood plain then it is likely that it will only get worse if the water has fewer fields to run off into. If new housing is built on the land between the Tach Brook and Harbury Lane the new housing will be built with new anti-flood defences. This would leave the existing housing, built when such technology was neither available nor necessary, more vulnerable to flooding. I lived in Cubbington village when that flooded in 2007 and the extent of the flooding was exacerbated by the inadequacy of flood defences since new housing had been built.

Constructing large areas of housing on the banks of the brook will increase the water flow and in periods of prolonged heavy rain will increase flooding risks to neighbouring authorities such as Gloucestershire and Stratford. Recognising that only 5,400 homes are required, dispersing them more fairly around the district and not directly connecting them into the river system (except by the upgraded drainage system in Leamington) would be more acceptable to downstream neighbours such as Gloucestershire and Stratford.

Quality of life

Bishop's Tachbrook is a rural village separated from Leamington town by Harbury Lane. Having lived in what was Cubbington village and seeing the erosion of quality of life as a result of infill I would not want the same happening to Bishop's Tachbrook. It has a rural character which I would like preserved by maintaining the geographical barrier of Harbury Lane. The suggestions for a country park are paying lip service to the real issue which is that the edge of Bishop's Tachbrook is a mile from the edge of Warwick Gates and if the urban sprawl comes any closer than that then the rurality of the village is lost. A country park may provide a minimum level of separation but the undulations of the land will make the new housing highly visible from Bishop's Tachbrook thus negating this token separation.

The Planning Inspector who reviewed the current Local Plan in 2006 reported that Woodside Farm should not be built on now or in the future. Warwick District Council's landscape consultant Richard Moorish in the Landscape Area Statement in 2009 wrote the following with regards the land south of Gallows Hill 'this study area should not be considered for urban extension and that the rural character should be safeguarded from development'. However, this new Local Plan appears to go against its own consultant's advice.

Listening to residents

A Neighbourhood Plan has been issued by Bishop's Tachbrook Parish Council which reflects the survey undertaken to gather residents' views. Bishop's Tachbrook residents such as I are concerned that our views will not be taken into account during this consultation. The previous 2012 Local Plan was altered after the consultation process and became much more acceptable to residents in the village. However this new Local Plan rips up any compromises made last year and in fact proposes more housing, with more of a burden borne by villagers. Consultation should not be a token gesture and the Local Plan should be altered if residents are clearly opposed to its proposals.

1. First of all, I want to register my agreement with the proposed plan in principal which was discussed at the meeting - I agree that there were no exceptional circumstances which would allow for the inclusion of the green belt land to the North of Leamington Spa to be used for building purposes.

2. Queries:

2.1 With regard to the sites for gypsies and travellers, how does the Council propose to deal with the management and maintenance of the sites, collection of rent etc from the gypsies and travellers who will be using the sites.

2.2 As I understand that it is proposed that some of these sites might be allowing for permanent or semi-permanent sites for the gypsies and travellers and that schools, doctors etc. should be accessible to these sites, how is it proposed that the gypsies/travellers will be contributing to the cost of providing schooling etc. in the form of council tax and how will that be collected?

2.3 If it is the Council's intention for these sites to be used rent free/council tax free by gypsies/travellers, please explain to me why they should be allowed to have the use of these facilities (paid for by the local taxpayers) free of charge.

2.4 In response to one of the questions raised at the Forum, the Council representative said that the Council has no say in how the builders will develop the sites and what they will build on them. This caused some consternation and confusion because of the following:

(a) of course the Council has to consider any planning applications and plans put forward by the builders and therefore has a significant power to agree, disagree or amend such plans;

(b) in the years before the slump in the housing market, a great deal of flats were either purpose-built or converted out of the old Victorian/Edwardian buildings - these were in the main bought by investors for rental purposes and there is a significant number of students as a result based in Leamington Spa/Warwick. In light of this there was general agreement in the room that amongst the properties to be built, the requisite proportion of affordable housing should not take the form of flats but should be freehold properties with a minimum of two bedrooms and with a garden. It was therefore disturbing when the Council representative indicated that the Council has no say in what the builders build.

(c) There was concern that in light of the current difficulties in first time buyers (or indeed generally) obtaining mortgage funds, there was a risk that a significant number the houses which are to be built might be bought by corporate or private investors (as they have easy access to funds) for rental purposes which could start another building boom and result in an increase in house prices to the continuing detriment of first time buyers. The question I wished to raise was what steps the Council might consider taking to ensure this could be avoided e.g. by requiring the builders to come up with a scheme to help finance the sale to first time buyers and perhaps take steps to discourage builders to sell houses en masse to investors i.e. require any buyer to be the owner/occupier of the houses.

Dear Sirs,
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.

Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.

Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".

The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.

The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.

It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.

Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.

The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.

The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs,
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) to be incorrect because of the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.

Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.

Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".

The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.

It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.

Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.

The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.

The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs/Mesdames
I write to express my concern about the rationale of the Revised Development Strategy (RDS).
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.


Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.


Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a
66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".


The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
Part of the Gateway site (6.5ha) around Baginton and Coventry
Airport; [Green Belt]
And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]


The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.


The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.


It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.


Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment.
Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed.
By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.


Instead WDC projections provide space for 10,200 new jobs to be created.
Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.


The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.


The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbersare not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
*    Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
*    Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
*    And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn puts further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030. 48ha of available employment land already exists so there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound. Additionally, there are huge implications for existing infrastruscture as well as schools, access to GPs etc., as well as housing.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply.
All the above points mean that the RDS should be completely revised in order to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I consider the Revised Development Strategy (RDS) unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

Dear Sirs
I consider the Revised Development Strategy (RDS) is unsound due to the excessive allocation of employment land and the inclusion of the sub-regional employment site which in turn put further strain on the provision of housing within the District. This creates problems rather than solutions and makes the Development Strategy unsustainable and undeliverable.
Within the consultation document it identifies a need for 36ha of employment land for the period 2011 - 2030 and there already exists 48ha of available employment land, therefore there is in fact an excess of employment land already available in Warwick District. The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample contingency.
Warwick District Council's approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in a 66 hectares unsubstantiated need for employment. By a combination of land re-allocation and unreasonable 60% contingency it is claimed that "it is reasonable to provide an additional 22.5 hectares of employment land".
The misleading claimed deficit is then used to try to justify development of new employment land in the open countryside and in the Green Belt:
* Thickthorn (8ha) between Kenilworth and the A46 and; [Green Belt]
* Part of the Gateway site (6.5ha) around Baginton and Coventry Airport; [Green Belt]
* And Southern sites (south of Warwick and Whitnash) (8ha) [Greenfield]
The RDS goes on to allocate a "Sub-Regional Employment Site". The Regional Spatial Strategy has been abolished but the justification still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with Government policy on the abolition of the RSS and makes the proposed strategy unsound.
The "Sub-Regional Employment Site" described in the consultation document, which written before the planning application for Gateway was considered in June 2013, demonstrates clear pre-determination of that application. The development would have a detrimental effect on many existing employment sites throughout the region that remain largely undeveloped. These provide perfectly adequate alternatives and the Gateway would undermine their redevelopment. This would be contrary to NPPF policies on urban regeneration and "brownfield first" another reason why the Strategy is unsound.
It was estimated by GL Hearn that around 8,200 jobs might be created by the development around Coventry airport of which 6,000 might be new jobs. Of the total, it is estimated that 1,200 jobs will be taken by people living in Warwick District, the remainder from elsewhere.
Warwick District has low unemployment and by contrast, Coventry, North Warwickshire, Rugby, Nuneaton and Bedworth have high unemployment. Therefore, the Gateway site is clearly remote from the main areas of unemployment. In considering employment need and in cooperation with neighbouring Local Planning Authorities WDC and those neighbouring LPA's should seek to direct employment land allocation where it is most needed. By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.
Instead WDC projections provide space for 10,200 new jobs to be created. Warwick District has a low unemployment claimant count of less than 1,500 people. Therefore, in order to fill these employment places, it will be necessary to import people from outside the District. This in turn results in equally inflated housing requirements in order to accommodate these expected immigrants to the District. Housing numbers in the RDS have risen from 10,800 to 12,300 dwellings where natural growth within the District would require only 5,400. This is not planning for the objectively assessed needs of the District and it is therefore unsound.
The National Planning Policy Framework (NPPF) summarises sustainable development principles including "avoiding coalescence". But the RDS fails to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". The false employment land requirements put additional strain on housing numbers are not justified and would irrevocably damage the local environment.
The NPPF requires that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to change, unless any adverse impacts would significantly outweigh the benefits, when assessed against the policies taken as a whole, or where specific policies indicate development should be restricted. For example, those policies relating to sites protected under the Birds and Habitats and/or designated as Sites of Special Scientific Interest, land designated as Green Belt, Local Green Space, and Area of Outstanding Natural Beauty. These are commonly referred to as areas of 'development restraint' where the presumption in favour of sustainable development does not apply. The RDS should be completely revised to reflect the actual needs of the District.

I am writing to express my support of the Revised Development Strategy.

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 Revised Development Strategy proposes that a substantial proportion of the new development is located close to where there are employment opportunities (to the South of Leamington & Warwick) providing an opportunity for people to live close to their place of work. Furthermore there is almost unlimited green space to the south of Leamington where the nearest town is Banbury.

The Revised Development Strategy removes the proposal to build 2000 houses on the North Leamington Green Belt. Through the better use of Brownfield sites only 325 further houses are proposed on Greenfield land than was proposed in the Preferred Options for the Local Plan published last year.

The Revised Development Strategy provides improvements to the road network South of Leamington to relieve the existing congestion and to cater for the new development. It is important that these road improvements are carried out as part of a coordinated plan. Traffic surveys show that road improvements can cope with the planned new development and that locating the majority of the development South of Leamington will reduce traffic movements, ease congestion and reduce pollution. This is not only an area which could cope with additional traffic but also benefit from improvement to the existing infrastructure.

The Revised Development Strategy provides for the necessary schools and other infra-structure to support the new development.

The Revised Development Strategy 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. 15% of the proposed development will be in Warwickshire Villages. The Revised Strategy is spreading the load.

I do not wish to challenge the number of new houses included in the Revised Development Strategy, which I understand has been estimated in accordance with guidance issued by the coalition Government, but I ask the Council to keep the housing requirement to a minimum - no part of Leamington should undergo more expansion than deemed necessary. Should more houses be required because of the Joint Strategic Housing Needs Analysis being performed with Coventry City Council, I believe that there is sufficient non Green Belt land to accommodate this additional development.