RDS6: The Council is proposing to make provision for 22.5 hectares of new employment land

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.

see attached

see attached

Dear WDC,

I have studied the new local plan and would like to object strongly to certain aspects which impact adversely on Baginton and the greenbelt.

1. Gateway;
This proposed development must be removed from the plan. There is absolutely no justification for building this ill thought out, unsustainable white elephant on Green Belt. There are no special circumstances and we all know that it was only approved by WDC planning committee through cynical manipulation of the committee membership and the conflict of interest represented by the developer and the LEP. I am sure if this development ever looks like going ahead the media will take a great interest in how this travesty became a reality. If it does go ahead the Green Belt will be ruined forever and there will be no significant job creation.

If the private sector thought it could develop businesses and create jobs in this area then Ansty and Ryton would be full by now and yet there is no sign of this happening in the foreseeable future.

Therefore Gateway must be removed from the plan.

2. Gypsy & Traveler site.
Again there is no justification in using Green Belt for this project. Baginton has no local facilities - medical, educational etc. and there is no safe pedestrian access to the proposed site. In addition it is perverse to talk about creating jobs and then put forward a plan which will adversely impact on successful rural businesses. Looking at the other options it is clear that this requirement could be met elsewhere in Warwick district without building on Green Belt while providing travelers with access to the key public services.

Therefore the Gypsy and Traveler facility should not be built on the proposed Baginton site.

CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.
Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.
We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:
Paragraph 3.4
We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.
Paragraph 3.5
We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.
Paragraph 4.3
We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.
Paragraph 4.3.2
We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.
Paragraph 4.3.9
We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.
Paragraph 4.5.3
We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.
Paragraph 5.61 - 5.6.4
We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).
Summary and Conclusions
The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.
However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.
We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.
In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.
Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).
I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.

I am a resident of Bishops Tachbrook, where I live with my husband and 2 children (aged 4 & 6). We have lived in the village for 8 years and chose the location because we wanted to raise our family in a village setting, away from the town centre.

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

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

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

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

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


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

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

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

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

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

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

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

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

New Homes and Projected Numbers

I struggle to understand the long term plan to increase the volume by 12000 and in the south of the District by over 4000 in the next phase. This will completely transform the dynamics of the community to the south of Leamington and severely damage the appeal of the area. I would want to see clear evidence that the local economy and new employment will demand such growth. This said, in planning terms the recommended solution seems to be an easy planning option. A huge swathe of housing adjacent to Myton is not clearly thought through.

We already have a large vacant property stock and many brown field sites which with imagination and thought could be brought back in to play to regenerate the town and restore its character.

Why cannot we see smaller developments around the outskirts, both north and south of Leamington rather than one' big bang '.
The constraint of green belt seems to have been overcome and modifications made by other District Councils . Is there joined up thinking across the whole of the County both in terms of policy and capacity?

I am also concerned at the impact the Plan has on the land close to and surrounding Warwick Castle - a major economic attraction to the District.

Office Buildings

Why are there proposals for more office accommodation?
There remain significant office buildings vacant in Leamington - indeed many offices have been unoccupied for some years. Proper planning should bring these buildings back into the equation. They also provide options for redesignation / modification as housing.
In this way the gradual decay of our town centre could be addressed. It remains too easy simply to build outwards!

Transport

The proposed modifications / widening of roads to meet expected volume changes does not acknowledge the fact that as roads draw closer to the centre of Leamington there are unavoidable bottlenecks with simply no where for traffic to go! Peak travel would become impossible if we extrapolate the average number of cars per proposed new dwellings in terms of vehicle growth.

Health Services, Schools and infrastructure

While any developments would need to balanced by additional health centre and GP services it is difficult to see how Warwick Hospital and both its general and maternity services could cope with increased patient numbers which in the long term could rise by up to 50,000 The hospital itself is landlocked with no scope for expansion.

The quality of education in existing schools could well be undermined if capacity is not accurately calculated. I am uneasy about class numbers rising above accepted norms.

Has the current work regarding drainage in the town taken account of the impact of such a large increase in dwellings?


In conclusion I remain very unhappy about the Plan. It does not appear to have been thought through with any in depth knowledge of the District but and with somewhat dubious population statistics and economic forecasts.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail 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 proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 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.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 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". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

see attached

see attached

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see attached

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

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

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

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

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


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

Scale and proportion

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

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

Effect on local road traffic/infrastructure

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

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

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

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

Effect of local services/amenities

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

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

Flood Risk

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

Alternatives to the Local Plan

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

Alternatives that should be considered include:

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

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

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

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

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

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

a) The projected number of new homes - the forecast date for this is unrealistic and there is no evidence of how this figure realistically reflects other development and infrastructure that will be required locally to serve this increase in the population of this housing.
b) Review the land earmarked for development and identify alternative areas
c) Review the implications such major developments will have on the current transport network and the feasibility of how this will cope and the scope of developing alternative network
d) Compatibility of the proposals against legal requirements for air quality
e) Commitment to maintaining local heritage and historic environments - the proposals are at odds with these commitments
f) Developing employment provision in connection with housing needs is unrealistic - has any data been collected for the current populations to establish the percentage of population who live and work in the same area?

I would urge the Council to reconsider the proposals and set up further in depth consultations to ensure that the Council's approach to localism accords with what is actually required locally and is in the very best interests for all concerned

see attached

After carefully reading your proposals for the local plan I wish to comment as follows.
Gateway.
The Gateway is totally inappropriate development on green belt with NO special circumstances. The green belt was set up to prevent city sprawl into the countryside. I request that you take all reference to Gateway out of the local plan.
Housing.
It is encouraging that WDC have at long last agreed that small housing developments in local communities should be allowed. Small growth sustains local amenities like shops and post offices. In order to protect the character of our village it is important to have a balance between market and affordable houses and it is good to see this incorporated in the proposal. However to suggest 70 - 90 houses over such a short time frame an this is totally unacceptable. The minimum should be deleted and left with just a maximum number and the final number should be in line with local needs and wishes.
Gypsy Sites.
Eric Pickles has announced that no gypsy sites will be built on green belt land so why is WDC proposing one on land opposite Coventry Airport which is in our green belt? We currently have 3 gypsy sites within 1 mile of Baginton and the guidelines require that such sites should be distributed across the district. The guidelines also require sites to be near a school, a doctor's surgery, a hospital and good local bus services; Baginton does not meet any of this criteria!. One of the proposed Baginton sites is on land owned by Smith's nursery; this is causing a very negative reaction locally which could harm the business potential of this local employer. WDC have identified other potential sites within Warwickshire that are not on green belt land which are more appropriate.

Please take my views into consideration when creating the next stage of the drafting process.

See Attached

I would like to raise concerns about proposals in WDC consultation document which will adversely affect the rural village community of Baginton.

Gateway.

This is an inappropriate and unsustainable development. There are no special circumstances for the use of Green Belt land for this proposed development. Hence the local plan should not include references to the Gateway.


Traveller sites

There are already three traveller sites near to those proposed in Baginton and hence the proposal of sites in Baginton does not fulfil the strategy of distributing developments across the district.

The proposed traveller sites in Baginton represent inappropriate development of Green Belt Land.

The proposed sites are not in easy reach of facilities such as schools, doctors, hospitals etc and public transport links are poor. Access to the village from the proposed sites has no suitable footpath.

The proposed Stoneleigh Road site is that of a local rural business. This business would be adversely affected by forced loss of land and this is unacceptable when there are other more suitable sites available.

Alternative proposed sites South of Warwick have better access to facilities, would lead to a more even distribution of sites across the district, would not lead to the loss of green belt land and would not have an adverse impact on a local rural business. Therefore these sites would be more appropriate that those proposed in Baginton.


Housing

The proposal of building 70-80 new houses in Baginton is a disproportionate increase for the size of the village. The local plan must not dictate the type of housing development to villages but should take into account village desires under the Localism Act. Outcomes of our Parish Plan and Housing needs Survey identify a maximum of 20 houses and this figure should be used in
preference to the proposals in the consultation document.

I urge you to reconsider these proposals.

Dear District Council
We wish to object to the proposed local plan on the following grounds:
* There is excessive new housing. The housing allocations in the plan should cater for "indigenous" growth, perhaps with a small growth for economic growth purposes. But not this huge amount of new housing.
* The land proposed for employment is also excessive, especially given the amount of vacant employment sites, some of which have been vacant for many years.
* The plan does not take into account the proposed growth outside of the district in the Lighthorne/Gaydon/Kineton area.
* The plan concentrates housing to the south of Warwick and Leamington. No consideration has been given to minor modifications to the green belt to provide a more equitable distribution of growth to the north and south of these two town centres.
* The impact on transport north-south through Warwick and Leamington will be severe, especially given the limited number of river crossings.
* Warwick and Leamington town centres will suffer from congestion and poor quality air. This will make them less attractive to visitors and shoppers.
* The proposed gypsy/traveller sites are,again, concentrated to the south of Warwick and Leamington rather than being distributed more evenly through the district.

I am writing to strongly object to the Development Strategy planned for Baginton Village.

1. Gateway

The Gateway is an unsustainable and inappropriate development of the Green Belt land with no very special circumstances. It will have a very great affect on the quality of life within the village and cause an unnecessary increase in traffic through the village particularly Mill Hill. The bridge in Mill Hill will certainly not be able to cope with the increase number of buses proposed to service the commercial businesses planned. There is plenty of commercial land around this area that could be used for commercial development without impacting on our rural community.

2. Housing

Although, I welcome the development of new housing within the village particularly affordable housing, I totally disagree with the proposal put forward of 70-90 houses, a more realistic number would be 20. The Local Pan must not dictate the type of housing development to villages, but should take into account individual village desires under the Localism Act. Outcomes of Baginton Parish Plan and Housing Needs Survey should be used in preference to the proposals in the consultation document.

3. Gypsy & Traveller site Options

The proposed Gypsy and traveller sites in Baginton (ref G101 & G107) are an inappropriate Development of the Green Belt. The consultation documents identify major negative effects as to the sites being located on Green Belt land and being adjacent to Coventry airport, the industrial park and in the vicinity of several sewage treatment works, with the associated noise, light and air quality effects.

The proposed sites are not within easy reach of local facilities such as doctors, schools, hospitals etc and there is poor public transport provision. Access from the sites to the village along the grass verges are unsuitable for pushchairs, wheelchairs etc.

There are already three sites within a few miles of Baginton at Siskin Drive, Brandon Lane and Oxford Road. Therefore, the proposed sites do not satisfy the Local Plan Strategy of "distributing development across the District".

The proposed site in Stoneleigh Road is on private land, which includes part of the local nursery. It is unacceptable to adversely impact on a rural business by forcing them to give up part of their land for such a development, when there are more suitable sites.

The alternative sites proposed to the south of Warwick district are preferable options to the two proposed in the Baginton parish as they are outside the Green Belt, they also have better access to facilities, would not have an adverse impact on a rural businesses and would not lead to an over-concentration of sites in one area.

I moved to Baginton with my family nearly 3years ago at considerable financial costs so that I and my family could enjoy the benefits of living within a rural community. Since moving here the village of Baginton has continually had to fight Warwick District Council over a number of proposed developments. Can you please take into account that this is a village and not an overspill from Coventry and I would very much like to enjoy the rural setting we now enjoy!!!

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

New Housing


Number Of Houses & Impact To Local Infrastructure.

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

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

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

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

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

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


Location Of Proposed Development

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

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

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

"a mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands, that have developed and grown in a way which has protected their individual characteristics and identities."

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

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


Location Of Proposed Development Near To Bishops Tachbrook.

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

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

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

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


Use Of Green Field & Brown Field Sites.

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

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


Gypsy & Traveller Sites.

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

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

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

* Sites 6 & 9 have no pedestrian access.

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

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

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

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

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

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


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

see attached

I am writing to object to the current proposals in the Warwick District Council Local Plan Revised Development Strategy and to support an alternative strategy. This is not based on purely emotional reaction or "nimbyism" but on acknowledged planning considerations, a concern for the future of Warwick and its suburbs, and some relevant legal implications. In particular I have grave concerns about the ability of the future transport infrastructure to cope with the District Council's proposals and the disastrous effect that those proposals will have on the quality of life in the town and its suburbs.
Although the thought of any major new housing development affecting Warwick is profoundly worrying, I accept the District Council's view that the economic arguments justify a reasonable level of development in the area covered by the Local Plan. However, the proposal to allow 12,300 houses by 2029 is far too extensive and must call into question whether district councillors, especially those representing constituencies outside Warwick, are genuinely concerned about the future of the County Town. I understand that in response to the consultation, evidence will be put forward by acknowledged local experts in planning, legal and conservation matters. I believe that these representations will justify a substantially reduced proposal for housing development in the area.
Transport infrastructure
It must be patently obvious to anyone who lives or travels through the area that Castle Bridge, Myton Road and Prince's Drive are struggling to cope with the existing level of traffic, especially at peak hours. The modifications to the road system following the opening of the Morrisons and Aldi supermarkets are not solving these difficulties. The tiny modifications in the above three areas proposed in the Local Plan documents will only tinker with the problem. The impact of 3,195 new houses with access to the existing traffic bottlenecks of Myton Road and the Shires and the old Ford Foundry roundabouts will lead to more extensive gridlock and pollution in the whole area between Castle Bridge, the Ford Foundry roundabout and Warwick New Road. Even if one accepts that the Local Plan is not intended to improve the existing traffic and environmental pollution, it should not be allowed to exacerbate gravely an already barely acceptable situation.
Environmental Pollution
I understand that the level of pollution in Warwick town centre is already above legal limits and that the District Council will be receiving submissions about this during the consultation. I urge the Council to give full consideration to this evidence.
Level of Housing Development
At a recent meeting the audience was given to understand on planning grounds that to meet the existing needs of the area only 5,400 (not 12,300) houses are required. This could be achieved without using the vast swathe of greenfield land south of Warwick, Leamington and Whitnash, by relying on the much less invasive and intrusive 5,678 homes already completed or allocated in the Local Plan. Any significant increase above the 5,678 would appear to give grounds to those who suspect that the Council is more concerned to attract people from outside the District than to support its existing population, and to attract lucrative planning proposals from developers. There appears to be no current evidence of a demand for employment development schemes. The lack of interest in office development on the area allocated on the Morrisons site speaks volumes in this regard. This feeds the frequently made suggestion that the Local Plan is really aimed at attracting new home owners to the Warwick area who will not work there. This may be more lucrative for the Council, but commuter traffic would therefore increase, further exacerbating the problems of transport infrastructure and environmental pollution outlined above.
On a further important point, it is very worrying that Stratford-on-Avon District Council is consulting about the possible provision of some 4,500 houses in Gaydon and Lighthorne Heath, not many miles from the main development area proposed by Warwick District Council. It is very likely that many such home owners would look to Warwick for employment and services, again further exacerbating the problems outlined above.
Conclusion
If Warwick District Council is genuinely concerned to implement a Local Plan that is "strongly based on evidence and takes account of representations made by interested individuals and organisations", then I believe that it should modify its proposals and allow only the 5,700 or so houses on sites already completed or allocated.
This would be in keeping with the Council's strategic vision of making Warwick "a great place to live, work and visit". Please do not betray that vision by subjugating what has until now always been a great place to live to the voracious demands of excessive housing development that would ruin the nature of Warwick and its suburbs forever.

I am writing in response to WDCs consultation exercise for the New local Plan.

WDC completely ignored the opposition to the recent Gateway planning application and I have absolutely no doubt that if it can ignore 800+ letters of opposition to that development in the green belt and the unanimous opposition of the local parish councils there is no chance of the council listening to any opposing views to their proposed local plan.

I am appalled by the completely arbitrary estimates for future employment land requirements and the non scientific approach to the amount of land required for reserves/margin/flexibility. No reference is made to how these figures are arrived at. Is there a nationally approved way of calculating this or are they in fact just "pulled out of a hat"?

The result of all this will be an over-provision of employment land and unnecessary removal of large amounts of land from the green belt.

I am also appalled at the way previous employment land has been re-designated as housing land thus creating an artificial shortage of employment land. This is another example of "sleight of hand" by WDC and has been done without consultation or support of the local community.

The employment land proposals within the New Local Plan (RDS6, RDS7 & RDS8) should be removed, as they are not logical, necessary, sustainable or based on robust estimates of future demand.

see attached

As a resident in the District, I would like to register my fundamental concerns to the proposed Revised Local Plan. There are a number of features that will prove to be serious retrograde steps to the area:

1. The density and volume of new houses - the number of houses appears to be significantly overstated and concentrated to the south of Warwick along Gallows Hill area rather than being spread ore evenly (even if the number of houses required is a correct projection). Projections are estimates and surely it is better to make smaller incremental changes rather than sweeping over-reaching change, which may not be needed or desirable. The Ray Bullen paper in 2012 stated that ONLY 5400 would be required (not all at once) , which is more than 50% less than the now increased number that WDC are suggesting of 12300.
2. Why are brownfield sites not being utilised before new greenfield developments - is it "easier" for developers to go for greenfield sites?
3. It is not a given that all new residents will work in the same area as they live, therefore congestion is inevitable because of the concentration of new houses to the south Warwick
4. Likewise the proposed new employment area close to Gallows Hill is likely not needed, there are numerous empty office blocks available for new businesses already existing on various technology parks or other areas around the district. Many that have not been fully occupied since they were built.
5. The density of development means that the very features that attract people to live in Warwickshire will be lost and the developments will just become co-joined and akin to Milton Keynes or similar, with no distinction between the different sub areas and villages. The attraction of Warwickshire is farmland between and surrounding the town and villages adjacent to Warwick and Leamington, providing space and definition to the residential areas. People who live in Warwick District do not want to live in a housing/pseudo town sprawl. Towns and villages evolve they are not dropped into some Greenfields, The "country park" that is proposed on the edge of the new Gallows Hill development is a poor substitute for open fields and becomes a semi urban "park" given its location not open countryside. Prior studies that WDC commissioned (Planning Inspector 2006) )stated that the Woodside Farm area should not be built on.
6. The farmland that is now being earmarked for development is medium to high grade and should be retained for its ability to produce multiple crops and be part of the UK agricultural economy rather than requiring yet more food to be ultimately imported

In addition, Bishops Tachbrook, seems to have been "chosen" as a Primary Village for expansion, presumably because of the volume of housing due to be created as a result of the Local Plan. This is based on a poor premise (see 1 - 3 above) and seeks to alter the dynamic of a successful village. A village has a distinct identity and the boundaries shouldn't be needlessly expanded. The views from the village are of rolling countryside, which would be slowly eroded and the distinct spacing that allows the village to function as a village (rather than as an add on to a new development or Warwick Gates or Whitnash) will be lost. There is real history to the village which would be lost forever. Likewise extra housing and increased attendance at the school will cause more congestion and be dangerous to pedestrians and drivers. The size of the existing roads fits with the size of the village and to expand or widen the road network would again destroy the soul and history of the village, which should be retained for future appreciation by others. Adding on an extra 100-150 houses is also unnecessary, and again a very high volume where the need is not supported or proven.

Gypsy Sites

There are significant concerns regarding the location and number of pitches proposed. Firstly, it should be noted that it is not a given that gypsies would use such sites, in other areas (Shipston) there are sites which were set up but not used. Land that is used by the gypsies tends not to be managed well and so becomes an eyesore to other surrounding residents. The write ups suggest that they will pay council tax but given that many of the gypsies will probably be unemployed there is no motivation to take pride in the surroundings. If the council does not manage these, then there is limited re-course by those potentially affected in the direct vicinity.

The proposed sites, such as those at No's 3, 4, 5,9, 10 and are all located adjacent to busy roads, which would be dangerous to all parties including the gypsies. They are not close to secondary schools.
There is no information on the maximum number of people that would be allowed to stay on the site. The public information states 20-30 number of caravans but that does not give any idea of possible density of inhabitants, which will put a strain on local services.

I sincerely hope you will listen to the feedback the WDC receives and revise the location and volume of development to a less intrusive and a more sensitive number.

I am writing to object to several aspects of the current version of the Local Plan. The points set out below are not necessarily interdependent, but in the context of the south of Warwick and the impact on Warwick itself are additive.

The number of homes put forward is far too great. 12,300 is a drastic increase from the number in the previous draft / version of the plan. There is evidence in the paper from Ray Bullen Dipl Arch RIBA that 5,400 homes would satisfy the likely demand.

The location of the vast bulk of the homes south of Warwick is drastically unbalanced and inappropriate, and would have damaging effects on Warwick and also Leamington, for quality of life, traffic, pollution and tourism.

In respect of balance, the previous plan used land north of Leamington, albeit in the Green Belt. This should be reinstated; the location of the Green Belt many years ago is no longer appropriate, especially given the ridiculous situation that 80% of this district is designated as Green Belt. It is inappropriate both to expect the District to take a full District's worth of new housing and to attempt to cram the new housing into the remaining 20% of the District.

The location of the housing is also inappropriate. The new developments by Coventry Airport, as well as the economic centre of gravity north and northwest of Warwick will attract travel north from Warwick and Leamington, so putting homes south of those towns would generate traffic trying to go through them both, making both towns busier.

The concept that economic development near Gallows Hill and the increasingly inappropriately named "Science Park" will be attractive to businesses and provide employment for people in the new developments is not credible, and has already been disproved by District Planning officials and the Committee at the meeting on 23rd July. The justification for granting permission to Application W13/0607 to build houses on the land north of Harbury Lane was that there was not sufficient demand for the economic use which had been promised when Warwick Gates was built. People from that development already have to travel into and through Warwick (and Leamington) for work and other purposes, adding to the volume of traffic.

One gets the impression that the plan has put housing where developers want to build to maximise profit, not where it is best for the district.

The District Council's report by RMA consultants states re land south of Gallows Hill & The Asps that "The largest part of the study area is prominent in approaches to Warwick, is valuable in the setting of the town and provides the historic context for Castle Park. The recommendation remains that this area should be protected from development."

The concentration of houses south of Warwick would not only increase pressure on sewerage but also increase the risk of flooding. In the last two or three years since further development in the area a new occasional pond / lake has appeared in the field at bottom of Gallows Hill. The effect of replacing more earth with concrete and tarmac and of concentrating rainwater run-off could only to be exacerbate this situation and put the area at the bottom of the hill heading north into Warwick at greater risk of flooding.

The impact of increased travel in the plan, particularly motor but also other forms (albeit not adequately provided for), has been significantly understated. The modelling shown is just not credible. The current experience is much worse than shown in the misleading Ove Arup diagram, which covers future flows "AM" and shows an average of 40mph from the Asps. In the rush hours nowadays the traffic jam starts at The Asps and continue right down to the Warwick Bridge, along Europa way and the road to it from junction 14 of the M40.

The word "Mitigation" is an almost Orwellian misnomer. It does not do what it says - it just tempts traffic into Warwick and spoils the quality of life for those living near the new busy routes. Evidence for this is in the paper from Dennis Crips.

Not should also be taken of the probable increase in vehicle pollution in Warwick, which is already at illegal levels.

The increased volume of traffic and the traffic measures proposed to speed more traffic through Warwick would make the quality of life much worse for people living on or near the roads affected, and would lessen the attractiveness of Warwick as a destination for tourism, shopping and dining, damaging the economy of the town.

There are already massive traffic bottlenecks between Warwick and Leamington and the south - the bridges over the Avon; Warwick Bridge, Prince's Drive, and Leamington Town Bridge. They are already struggling with the volume of traffic from housing south of the towns, total overload if development happens. The Warwick Bridge is historically important, narrow, and increasingly busy. There are already frequent illegally heavy loads using the bridge; these would increase, and are already going to cause a serious problem when the bridge is damaged and will be out of action for a significant time.

The whole road system of Warwick and also Leamington becomes gridlocked now if there is any problem on either A46 or M40. The situation would be even worse with more traffic needing to use it.

Relief via Longbridge roundabout is unlikely. It is already jammed at busy times - rush hour and schools.

The plans show a lack of provision for pedestrians and other forms of transport - especially cycles. Removing pedestrian crossings on the Banbury road may speed traffic, but would increase accidents to pedestrians and schoolchildren.

see attached

Dear Sir/ Madam

REPRESENTATIONS TO THE WARWICK DISTRICT REVISED DEVELOPMENT STRATEGY - JUNE 2013

CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.

Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.

We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:


Paragraph 3.4

We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.

Paragraph 3.5

We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.





Paragraph 4.3

We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.

Paragraph 4.3.2

We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.

Paragraph 4.3.9

We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.


Paragraph 4.5.3

We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.

Paragraph 5.61 - 5.6.4

We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).

Summary and Conclusions

The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.

However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.

We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.

In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.

Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).

I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.