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

Whilst in general I support these proposals I would wish to re-emphasise that there remain no exceptional reasons for building on Green Belt land immediately north of Milverton.

In view of the lack of provision of a primary school for Warwick Gates when it was built I would also hope that providing proper infrastructure is an absolute priority for the proposed developments south of Warwick in particular roads and schools.

The rationale behind 4.3.3. was valid and the efforts made following objections north of Warwick to justify the "easy" option of using lands to the south by finding consultants, 4.3.4;4.3.6; to justify using these lands is reprehensible. This would still be an impossibly huge impact on the environment of Warwick if this area becomes built up.

It would appear from Section 4.14 of The Draft Settlement Hierarchy Report that there is not a criterion to determine whether a village is in the Primary or Secondary Service Village Category and that the categorisation is subjective rather than objective.

You state that your preferred option is to "avoid development in locations which could potentially lead to the coalescence of settlements", but by locating the majority of the new housing south and south west of Leamington you are encroaching on Barford and Bishop's Tachbrook, as well as yet further filling the gap between Warwick and Leamington.

Your preferred option is to "distribute growth across the District...", but the Green Belt - 80% of the District - is not being revised so the remainder of the District needs to provide 4 times the growth to compensate. Although the Plan details a series of mitigation methods these are concentrated on moving traffic from the new developments northwards which will move congestion to the town centres. When these roads become blocked (as already happens) traffic will use alternative routes and attempt to by-pass the town centres using narrow village roads villages unsuited to these volumes of traffic.

Your preferred option is to "distribute growth across the District...", but the Green Belt - 80% of the District - is not being revised so the remainder of the District needs to provide 4 times the growth to compensate. Although the Plan details a series of mitigation methods these are concentrated on moving traffic from the new developments northwards which will move congestion to the town centres. When these roads become blocked (as already happens) traffic will use alternative routes and attempt to by-pass the town centres using narrow village roads villages unsuited to these volumes of traffic.

You state that your preferred option is to "avoid development in locations which could potentially lead to the coalescence of settlements", but by locating the majority of the new housing south and south west of Leamington you are encroaching on Barford and Bishop's Tachbrook, as well as yet further filling the gap between Warwick and Leamington.

I agree that most new homes should be within or adjacent to the main urban areas. Too much is focused south of Leamington/Warwick - more should go north, relaxing Greenbelt if need be. More use should be made of existing brownfield sites which appear to be being underutilised.

Ref: The Warwick DC Local Plan
I write to raise my strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.
This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.
Scale and proportion
 Keeping Bishop's Tachbrook as a village  massive long term coalescence of settlements,  loss of significant open space,  loss of local countryside,  loss of agricultural land,  lead to significant urban sprawl.  excessive bulk and scale,  significant overdevelopment of the area
The effect of these potential developments on the existing local communities and infrastructure will be devastating, and I believe have been grossly underestimated by both Warwick DC and the developers. How many more homes need to be built before Bishop's Tachbrook is no longer a village and is absorbed into Whitnash and Warwick gates. We pay a premium to live in a village, house hold bills are higher and in our home in Holt Avenue which backs onto a field where you wish to put new homes we will hear an increase in traffic volume and pollution. We suffer already in the summer with low water pressure and this has affected my home twice in the last week alone with the warmer weather.
Effect on local road traffic/infrastructure
The road infrastructure south of Warwick/Leamington and around Whitnash is already stretched.
 2 or more cars per household,  9000 extra vehicles using the local road network.  The local road infrastructure is inadequate. (e.g congestion on various local roads)  traffic heading towards the town centers is already a major problem,  Gridlock, increased pollution etc.  congestion on rural roads outside the town at peak times is also already a problem  traffic noise,  Potential increased danger to pedestrians and children.
The National Planning Policy Framework, Policy DC7 states: "Policy DC7 goes onto highlight that development will not be permitted where it generates significant road traffic movements, unless mitigation measures are used to avoid adverse impacts."
These developments will generate significant road traffic movements, and I do not believe that mitigation measures will alleviate the problem, certainly on a local level. If all the developments in the area are given the go ahead as part of the Local Plan, the situation will become untenable.
Effect of local services/amenities
The National Planning Policy Framework, Policy DP2 states: "That development will not be permitted where it has an unacceptable adverse impact on the amenity of nearby uses and residents and/or does not provide acceptable standards of amenity for future users / occupiers of the development."
 pressure on local schools/teachers  primary schools already oversubscribed year on year  increased pressure on the local secondary schools  effect on catchment areas  effect on applications from siblings of children already in one school  new schools not "guaranteed" to be built as part of the developments  limited access if any to doctors and dentists surgeries in Bishop's Tachbrook,Whitnash, Warwick Gates and Myton areas already  effect on increased numbers on the local hospitals
Flood Risk
 Field backing onto Holt Avenue floods on a regular basis like my own back garden  already flood issues in Whitnash and Warwick Gates  scale and density of proposed housing,  large areas of paved/concreted or tarmac surface etc,
Alternatives to the Local Plan
There are many reasons why the Local Plan represents a disaster for the whole of the South Warwick/Bishop's Tachbrook/Leamington/Whitnash areas, predominantly because of the sheer concentration of most of the districts proposed new housing in one relatively small area.
Alternatives that should be considered include:
 Identifying existing housing that is derelict or currently unoccupied,  Identifying empty industrial units with a view to use the land for brownfield site housing.  Identifying an area in the surrounding countryside to use to build an entirely "new town".  Spreading the numbers of new homes evenly around the district, with lots more much smaller developments.  Smaller developments given to local builders rather than large national firms, thus helping the local economy.
Applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed.
Therefore, I hope you listen to the concerns and suggestions of the residents of your district, and act accordingly. This Local Plan cannot be allowed to come to fruition, and I hope Warwick DC come realize that, withdraw it, and refuse all the various planning applications relating to it, namely:
W/13/0776 - 280 homes at Woodside Farm fields W/13/0606 - 720 homes on Lower Heathcote Farm land, south of Harbury Lane W/13/0603 - 370 homes on land west of Europa Way/South of Gallows Hill W/13/0607 - 220 homes on Hawkes Farm fields W/13/0036 - 200 homes on Grove Farm fields (application on hold) W/13/0464 - large Retirement Community development on Gallagher Land near Heathcote W/13/0858 - upto 100 homes at Fieldgate Lane/Golf Lane, Whitnash
I hope Warwick DC would also refuse any new applications relating to the following:
Myton Garden Suburb - upto 1250 homes Further development South of Gallows Hill - upto 260 homes Former Severn Trent Sewage Works - 225 homes Further development at Grove Farm - 375 homes Whitnash East/South of Sydenham - 500 homes

Some principles in Policy RDS3 and subsequent Section 4.3 are to be supported, such as concentrating growth within, and on the edge of, the existing urban areas and protection of the Green Belt where alternative non-Green Belt sites are suitable and available. The potential consolidation of employment land, intensifying use to free up brownfield land for residential development, is also positive.

It is therefore bewildering to see that these ideas have not followed through to the Housing Allocations in Section 4.4, which impose rural development with no sequential testing for brownfield, greenfield and Green Belt land.

The lack of residential development on the new Morrisons site in Leamington is a terrible missed opportunity.

In RDS3 WDC claim to be distributing the development across the District. This of course means across 20% of the District as the Green Belt is not being revised. Paragraphs 4.3.4, 5 and 6 attempt to support this. The Green belt is there to prevent the spread of major conurbations into the countryside - The downside of maintaining the GB is additional development in the south, allowing Warwick and Leamington to spread and encouraging them to coalesce with villages. Putting all the development in 20% of the area of the District puts unnecessary strain on infrastructure and is not equitable.

4.3.5 expresses a 'general desire for more development to take place on brownfield land'. BRA fully supports this principle - but the figure of 5.7 % of development quoted in RDS4 seems to suggest that WDC may express a desire - but are not proposing to do very much to make it happen.

This level of development will fundamentally change the rural character of the area, including the setting of Warwick, Leamington and the historic surrounding countryside. This is not just a question of aesthetics, I am concerned that communities in this area will loose identity and cohesion as they become subsumed within a wider conurbation.

These proposals do not appear to be supported by local residents, who are still working to build a sustainable community on Warwick Gates. It takes time for an estate of this size to become a viable community, with vibrant groups and networks that help sustain a decent quality of life. To plan to build almost the same number of houses every two years adjacent to Warwick Gates, does not allow for normal community life to be nurtured.

This Plan is unfair. To lump so much development on the southern reaches of Warwick and Leamington is punitive. It places a significantly disproportionate amount of stress and dislocation on just one part of the District, on the supposed justification that this area is not part of the Green belt. While this solution may work politically, it unfairly burdens one area for the benefit of others.

Too much developement is being aimed south of Warwick and Leamington which will destroy the rural character of the histroic towns and countryside and nearby villages plus the physical impact such greater population numbers will have in the area and surrounding environment. The idea of a proposed county park may have merit but it should be established before any development takes place.

The concentration of the development in the south of the district - 4550 houses in sites on the edge of Warwick and most of the 1000 village developments will cause severe strain on the local infrastructure. Traffic is already a problem and the mitigation proposals do not address the problems South of Warwick and Leamington. The road through Barford is already grid-locked at peak times with traffic avoiding the direct routes and further large developments in this area will only make the problem worse. If this area is to be developed a major new road south in needed

Para 4.3.8 states that 'The area known as The Asps provides a historic context to the castle park -- It is recommended that this area is protected from Development'.
If this area is included in the 'Country Park' designation specified to the East then it might be more likely to remain undeveloped in future plans that if it merely a recommendation in the RDS.

In section 4.3.3 concerns were expressed about the impact of a large amount of development south of Warwick on traffic along Europa Way, the town centres and the M40. No concern has been raised about the impact of this upon villages to the south. Traffic avoiding the main roads and going through Barford as an alternative route already causes problems at busy times.
A major new road is needed to enable traffic from the proposed new Development to travel south.

HOUSING
I wish to object most strongly to the proposed housing allocation ( up to 5000 homes south of Leamington/ Warwick Banbury Road vicinity. Why has such a huge number of house been dropped on this location. The local roads can't take the increased volume of traffic. More homes need to be put in the Green Belt Area to the north of the District.

Wholesale review of Green Belt policy is required. Spread the housing allocation across the whole district.

Para 4.3.8 states that 'the area known as The Asps provides a historic context to Castle Park.... and as open land provides a valuable setting for the town of Warwick. It is recommended that this area is protected from Development'. This is simply a statement in the RDS and will carry no significance in the future
This area should be included in the 'Country Park' specified to the East and would then be given status similar to Green belt in the North of the District

1. You state that your aim is to, "distribute growth across the District". You then propose that nearly 70% goes in the south of the town. The statements do not match
2. You also state that you wish to, "avoid development in locations which could potentially lead to the coalescence of settlements". You then proceed to do exactly that by proposing large numbers of houses between Warwick Gates and Bishops Tachbrook. The fig leaf of a country park boundary is a joke!
3. You state your desire to use Brownfield sites but then propose only 5.7% of the new houses will be on brownfield.
4. Currently Bishops Tachbrook and the south of Leamington are just visible to one another. The visual impact of the housing built south of Harbury Lane and extending down the side of the Tachbrook valley will be severe.
5. Large areas of the landscape south of Leamington and Warwick are concidered to be uniquely beautiful. A rolling landscape with far reaching views. Given the overiding concerns about the excessive numbers of new houses proposed it is not right that this landscape should be lost.
The Planning Inspector who reviewed the current local plan in 2006 stated that Woodside Farm should not be built on now or in the future.
6. WDC's landscape consultant Richard Morrish in the Landscape Area Statement in 2009 referred to the land south of Gallows Hill and concluded "this study area should not be considered for urban extension and that the rural character should be safeguarded from development". So why has the district gone against that recommendation?
7. Infrastructure and transport issues are ill thought through:
* The Local Plan RDS does not contain any evidance to show that the proposed infrastructure improvements can be delivered from the Developer contributions through Section 106 and Community Infrastructure Levy.
* With some much unnecessary housing concentrated to the south of the town centres and surrounding roads will end up severly congested.
This will be even more severe at pinch points, crossings of canal river and railways where there is no realistically deliverable solution to the problem.
* Appendix E of the Warwick Strategic Transport Phase 3 Assessment show traffic speeds of only 0 to 10 miles per hour in large parts of Warwick
* Oakley Wood Road through Bishops Tachbrook village is already used by many as a route to the M40 south and Gaydon. The speeds many drive are unsafe - the net impact on safety in the village is likely to be detrimental

Controlled housing in the villages is very important to ensure the survival of existing services and communities.

Stagecoach Midlands wishes to object to the proposed preferred option for the broad location of development, because of the difficulty in serving the sites on a sustainable commercially viable basis.
We strongly agree that a strategy of urban concentration makes best use of existing public transport infrastructure, and allows existing bus services to perform significantly better in terms of load factor. Such an approach also gives scope for a virtuous cycle of service enhancements to be delivered based on an overall larger quantum of demand from which to draw, by developing the network.
This supports travel mode shift not just from within the new developments, but across the improved network as a whole. It is likely, for example, that new or augmented routes serving development to the south of Warwick would continue, as today, across the town centres providing new direct links as well as enhanced frequency. This would improve the overall attractiveness of the service offer, subject to operating conditions being at least as supportive as today.
There is currently virtually no bus priority within the Warwick and Leamington urban area. Were measures to achieve bus priority to be introduced, then the positive effects outlined above would be greatly magnified.
We also concur with WDC and WCC that there is scope through a concentration of development south of the towns, to kick-start a radically improved level of service in an area in which historically it has proved very hard to offer frequent, direct bus services, not least because of car-dependent urban design, and a lack of critical mass of demand. In addition, the major local highway corridors, in particular Tachbrook Road and Europa Way, are already affected by peak-time congestion, even before any new development is constructed.
This opportunity to improve the public transport offer will only be realised, however, by positively planning for the bus to play a much enhanced role. While some of this is implicit in the intent of measures set out in the Revised Development Strategy, we are concerned that overall there is no clear agenda, nor specified measures, to ensure that the opportunities provided by the Strategy to deliver a much higher quality of public transport offer have been taken up, in the form of sufficiently well-developed actions required by Policy. We will address the opportunities we identify in more depth later in our responses.
As such we submit that the Strategy is not in conformity with NPPF.
Stagecoach Midlands OBJECTS to the location and distribution of the quantum around the south of Leamington and Whitnash.
In general, we consider that insufficient consideration has been given to achieving higher density development across the sites, or parts of them, sufficient to make best use of existing and credible future quality public transport provision. While we recognise the attractiveness and desirability of the Garden Suburb vision, the provision of effective high quality bus services is undermined by the relatively low housing densities involved, and the consequent likely impact on the dwelling stock mix.
The current Strategy, in proposing a relatively large development footprint also effectively gives rise to a much greater expanse of development south of Harbury Lane, than is easy to serve by a single high frequency bus route. Diverting existing service 68 through these areas will pull it away from existing development at Warwick Gates OR risk creating a circuitous service design that will be very unattractive to existing bus passengers, while being even less attractive to car owners.
Large parts of the development footprint in Myton Garden Suburb in particular, are much closer to existing local employment and amenities, and are also most closely related to the existing urban area. This development proposal is expected be within easy reach of the proposed high frequency bus corridor incorporating the "virtual Park and Ride". Depending on the master planning approach, higher densities might be justified in Myton Garden Suburb adjoining this bus corridor, either on the eastern flank if the service uses Europa Way, or, if a bus priority corridor were delivered within the scheme, within 250-300m of that. Higher densities, of up to 45 dwellings/Ha, would support much better patronage levels for the proposed bus service.
If it were possible to accommodate a larger development quantum at Myton Garden Suburb overall, which is the location best able to take advantage of sustainable transport measures, it might be possible to avoid the need for land releases elsewhere, which are currently very much less easy to access by sustainable transport modes.
In particular Stagecoach Midlands considers that several small-scale proposed land allocations east of Whitnash/South of Sydenham look to be difficult to serve on a sustainable basis, by attractive public transport services, without significant infrastructure measures being put in place, that are not anticipated by the Revised Development Strategy.
As stated above, the Strategy proposes that the development footprint extends much more than 300m south of Harbury Lane. The development quantum on land allocated beyond this threshold would be equally hard to serve with a bus service sufficiently frequent and direct to be attractive. In addition the wider public concerns expressed about incipient coalescence with Bishops Tachbrook could also be mitigated by a revised approach that reduced the development quantum that needs to be accommodated here by achieving a higher-density more compact urban form on development sites better related to existing and future sustainable transport opportunities.
We particularly object to the smaller scale releases of land south of Sydenham/east of Whitnash. These areas are well beyond 400m of existing bus services. Extending services into this area will require an additional vehicle resource, even at a modest half-hourly frequency. We do not consider that the potential patronage that would be generated by the proposals would sustain a credible commercial service in the long term. In fact, the need to split access to land south of Sydenham with a second access across the current Campion School site, makes this problem much worse, with only an additional 300 dwellings available to support the operating additional operating costs involved, which are likely to be between £130-140,000 per year at current prices.
However, were direct bus-only vehicular access provided across the railway between Whitnash and the land South of Sydenham, we see much greater potential to incorporate these areas into a high-quality commercial bus network, subject to appropriate pump-priming funding being available during the build out period to deliver this service appropriately early. This would require a bus gate incorporating a pedestrian and cycle link; and a high-quality bus circulation facilitated through the site, also picking up the proposals at Fieldgate Lane west of the railway.
Such an approach would lead to Sydenham potentially being directly connected to employment both existing and proposed south of Leamington. We consider that this would significantly enhance its connectivity to these opportunities and greatly improving the socio-economic sustainability of the Strategy. A dedicated transport crossing would also give public transport and other sustainable modes a major advantage over private car use from all the development east of the railway, and as a result these additional measures would offer a much more sustainable location compared with further development south of Harbury Lane.
We support the proposals at Redhouse Farm Lillington where the whole proposal falls within easy reach of an existing commercial high frequency service. It is the one proposed allocation that best makes use of existing public transport services and infrastructure in a location that is already sustainable.
We note the current proposed approach at Kenilworth. We recognise the need to meet the housing requirements of the town, and can see the landscape and other factors that favour Thickthorn. However we object to the current proposals because:
* We see that with the main access being proposed on to the A46 interchange, it will prove to be an exceptionally attractive location for car-based commuting, causing additional peak time congestion and undermining the effectiveness of the Strategic Highway Network, and potentially delaying our existing services, not least those offering fast links to Coventry and Warwick University via A46.
* When evaluating how we might serve the development, it is unclear that the quantum of development proposed there, and that existing adjacent, is sufficient to support a dedicated high-quality bus service longer term. Were we to divert existing routes it would in effect lead to other large parts of Kenilworth which currently enjoy frequent services, being either unserved or much more poorly served.
We also strongly support the additional development envisaged outside the main towns, particularly in larger villages. Bus services to these villages already typically offer hourly services, or better, but the longer-term sustainability of the current level of service does depend in most cases on higher levels of demand. We submit that, at a time when Warwickshire County Council is faced with ever increasing pressure on its budget for socially necessary but uneconomic bus services in rural areas, the approach taken by the Revised Development Strategy outside the main urban areas, is a prudent one to maintain and indeed possible allow some enhancement of bus services to outlying settlements. Walking and cycling do not present as credible a sustainable travel choice in these locations.
We would suggest there is likely to be scope for the kick-start of improved service patterns in certain rural corridors, facilitated by limited developer funding sought across multiple developments served by a rural bus route corridor. This may not only involve added frequency, but also more direct services, making elapsed journey times much more competitive with other modes such as car or scooter.

I would suggest the redevelopment of existing commercial to provide more employment would be prefered rather than being used for residential expansion to minimise any environment/contamination issues

I would like to see this proposal include infomation regarding the level of current commercial premises providing employment within the area, their distribution within the area, an indication of current empty properties, an indication of those requiring redevelopment and what type of property is required going forward - does it reflect modern trends regarding technology?

What work has been carried out to work out what proportion of the local population works within the immediate area and what their mode of transport is? And what proportion works outside of the area and again what is their mode of transport? This information would provide a good guide to move the local plan forward to ensure that the employment generation figures are realisitic

These proposals are preposterous and mark another ill-judged step on the road to our beloved area becoming swamped by ugly cramped suburban sprawl. The same misguided economic justification will be used on an even greater scale in 2030 and mid-Warwickshire will end up like Sutton Coldfield. No supposed benefits are worth the ruination which this scale of urbanisation will cause.

Please note my total opposition to this massive development

Attached

I wholeheartedly agree with the ambition of making WD "a great place to live, work and visit" but I am not convinced that this Local Plan addresses the issues in such a way as to achieve that vision.
I therefore wish to raise my concerns regarding the new local plan. I am extremely conscious of the position WDC finds itself in but am very worried that this solution is driven by an urgent need for a strategy in the face of developer pressure against the backdrop of the NPPF.

1. Assumptions

I am not convinced by the ONS's forecasts for population. There should be a forecast for 2030 and another for 2050. Most economists agree that UK population will start to fall away mid-century.
There are only 4 options presented and each is exclusive of the other; there are no options presented which are simple or complex hybrids. This is narrowing the choice unnecessarily when a hybrid plan may present the best compromise / optimum mix for all.
The options do not fully consider the needs across district or borough boundaries. The RSS Core strategy in 2007-10 looked at the wider picture and sought to find regional, more balanced solutions. By looking at numbers individually by District or Borough, our choice of options is dramatically reduced and does not consider the impacts on surrounding areas. These artificial political and authority boundaries are not considered by business or residents. As a parallel, in the past Fire Services looked only at the provision of service within a County boundary...clearly this is inappropriate when best planning a reactive service, particularly in rural areas, to avoid duplication eg N Warks / Sth Leics.

I see that there is now a Joint SHMA following the intervention of the Planning Inspectorate. Surely a Local Plan cannot be fully considered through consultation until this has met and made broader, more fully fledged proposals that meet the needs of the wider area and so avoiding duplication and ensuring more joined-up thinking? And what is the "new information" that has come to light?

Finally, when the Plan refers to 'Sustainable Communities', what is is meant by this? Very seriously, a definition is required to know what is being spoken of. Does it mean a community feeding itself, travelling within its own confines, providing its own energy and water needs? Please provide.

2 Housing

The primary determinant for the preferred option seems to be to avoid building on the Green Belt even though elsewhere WDC and Coventry CC will allow industrial development on the Green Belt. This is surely not a principle. Whatever guides the decision-making should be consistent and coherent. If one is permissible, then so should the other.

The notion of the primary employment site being planned at Baginton / Coventry Airport whilst 70% of new housing is proposed south of Warwick and Leamington doesn't seem to make sense

And "The apportionment of housing was guided by the principle of....avoidance of coalescence of settlements". The option proposed for suburban peripheral development to Warwick and Leamington would guarantee that the two in fact would become symbiotic twins with no green buffer separating them.

I would like to have seen a 'HYBRID 5' option being proposed that included elements of options 2, 3 and 4.
I believe in particular that the development of a new town, in the mould of the Eco-Town once proposed near Ettington a few years ago, in South-central Warwickshire would be the best solution to our collective needs. Sites such as the former Royal Engineers depot at Long Marston would have been perfect. I also believe that further expansion of Southam would make sense regionally.
Other villages such as Leek Wootton and Hatton should be expanded more than proposed given a) their size, b) their available land c) their current lack of village services and d) their proximity to the A46 corridor and Warwick and Warwick Parkway train stations. Hatton currently has next to no services and amenities: how was it allowed to be so?

Despite the huge impact on the area, the matter of HMOs and students seems to get little coverage or perhaps I have missed something in the documents. Given the sale of the issue, the Local Plan should address how in future it expects to balance the town between long-term residents and students etc. I would advocate more block development and place a moratorium on the conversion of existing housing stock: there has been a great surge in the number of terraced houses converting to student occupancy which has reduced the availability for young home-makers and families. Surely this is placing an additional burden on the housing shortage being faced in Warwick District. I would urge that WDC considers the conversion of Riverside House and the Fire Station to student blocks with the Council retaining 51% ownership of the sites for future revenue generation.

3. Economic considerations and Employment

I cannot see where in the document it speaks of the additional employment lands other than at the Gateway site.

In fact, worse still, the mention of a Reduction in employment land on industrial estates in Sydenham, Cape Road, Montague and Common Lane would be to the detriment of low skilled work forces throughout the area. Currently such workers are able to walk / cycle to work. this will not be the case in the future as these sites are sold off for housing. By insisting on maintaining the land as industrial, the land value will fall and then become viable for future industrial use; if the land value rises then this will be impossible in future.

The document speaks of " a need to provide new employment land in and around the District's main towns to meet local needs and encourage the creation of new jobs". Completely agree with this but have serious reservations about the viability and robustness of the Gateway project to deliver the number and quality of employment it is promising. In fact, the notion of a business park by the airport would suggest that this is really a giant logistics park by stealth when the former Ryton car plant site is a ready made brownfield location for such business. If I recall, such an application was made some years ago but turned down by Rugby BC. Using Green Field and Greenbelt land to provide such business seems wrong on all counts therefore.

I do not see how the expansion of the Warwick Technology Park is going to help low-skilled workers find jobs. It does not make sense.

Further, the document details the need to "support the rural economy"; this is really important but only touched on. The entire viability of villages is threatened in future with the withdrawal of services from them (the closure of post offices / pubs, small village stores, even primary schools etc..)

4. Infrastructure

The document speaks of an emphasis on infrastructure - "the development of sustainable communities with strong local centres / and or community hubs". As above, the rural economy is very fragile and villages need greater support if they are to remain viable. Rural bus services will become more and more threatened unless the villages served have sufficient mass.

I don't understand how having the major employment site to the north of the district and the housing tithe south will not lead to massive congestion in the town centres of Warwick and Leamington. This does not make sense.

5. Sustainable

See point 1) above. To re-iterate, what is really meant by sustainable communities. It is important to be clear on this point to avoid accusations of 'Greenwash', but it is similarly important to ensure the best, most durable and sustainable communities are created, it just for 2029 but for 50-100 years from now.

The coalescence of Warwick and Leamington does not seem to support a better environment.
The document states that "..ensuring new development is based on principles of sustainable Garden Towns, suburbs and villages" is key however it is not fully explained how this may be achieved. Urban centres have an optimum mass but this is not explored. Likewise, their interdependence is not explained; creating an hierarchy of primary and secondary villages is welcome but this needs to be examined in depth as to implications for the main settlements.

Section 3.4 para 17 talks of contributing to conserving the environment by "....reducing pollution" yet this is not supported with any evidence or data. The development of south Warwick and Leamington would surely have quite the opposite effect.

The document speaks of "caring for our built, cultural and national heritage" which is laudable and right. But the strain on Warwick and Leamington town centres by the addict all 'peripheral residential development would be at odds with this aim.

There is no reference to Building Regulations or the greatest ambition of all, namely, to build 'Passivhaus' dwellings for all new developments between now and 2029. It is possible and should be our goal.
Cycle routes are mentioned only on passing. They should be a key factor in new transport planning to / from town centres and stations / transport hubs.

In summary I have major reservations about this Plan. It appears fundamentally flawed in its assumptions, its siting of housing and its assumptions for employment in the north of the District and not in the south. Foremost, I have grave concerns about the lack of infrastructure, in particular for roads and transport in general to support such number sof homes around the periphery of Warwick and Leamington.
These two towns are very unusual in that they have three barrier to the passage of people and traffic. From north to south and vice versa: a railway, a river and a canal. As such, in Leamington, there are just three narrow single carriageway routes joining the two halves. They will not be able to support any increase in traffic. And in Warwick their is the medieval town and castle to navigate around. What is already a nightmare for pollution will only become worse.

This is not a plan to deliver "Sustainable Communities and Development".

I urge you to reconsider urgently before these towns are forever destroyed by the short-termism forced on WD by developers and the NPPF and the Localism Bill.