5 Strategic Development Sites and Infrastructure

I object to the continued 'urban creep' and the loss os distinct boundaries between towns and villages. Warwick, Leamington and Whitnash have already merged into one, and moves to the South of Leamington and Warwick shall impact on Bishops Tachbrook and other local hamlets.

Primary services are all based north of the river including police, fire, ambulance, let alone telephone exchange, postal depots etc. Bottlenecks of bridges will further ad to issues with service delivery and response times. Local infrasture such as schools and healthcare and not set up to accomodate the massive influx of people, let alone road infrasture for the additional traffic.

I feel that placing all development into the area south of Leamington and Warwick has a massive impact on the local residents in this area and will remove the 'urban fringe' and countryside appeal of living in these areas.

A plan to spead development around the district more would be preferred, or alternatively a green field site away from existing housing locations to form a new town or village would not create much more in the way of cost or infrastructure requirements.

The changes proposed in the Strategic Development Sites south of Warwick will generate an extra 4,000 to 5,000 extra vehicles using the southern approach roads in Warwick that are already subject to severe traffic congestion. Adding traffic lights does not address the fact that there is only one bridge available across the Avon which was built in the 18th century, has a 7.5 ton weight restriction, and only allows single lane traffic in each direction. These developments will only bring more traffic, greater congestion, air pollution and traffic noise onto this already overloaded bridge. As a pedestrian, it is already very difficult to cross the Banbury Road at peak times due to the continuous stream of cars. This also already causes a problem for the school children trying to gain access to the schools on Myton Road, and their parents trying to collect them on overcrowded roads.

The planned housing mix does not provide for the building of bungalows for elderly and people with restricted mobility. The only provision mentioned for the elderly is Extra Care Homes.

Sport England would refer to previous comments regarding building on land used for sports. But we also add the need to ensure that there is sufficient playing fields to meet the additional demand created by the new housing and employment.
Sport England is aware that Warwick DC is also a sport facility strategy this important to ensure that there is adequate swimming, indoor bowling and sports hall provision. Until this work is completed Sport England would advise that our Sports Facility Calculator is used working out contributions from the housing which is to be created: http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/sports-facility-calculator/

Greenfield land is as important as green belt land in that it is often agricultural land. Use of agricultural land for development would lead to a reduction in food production when the population is increasing. Greenfield land also provides an area of separation between major towns and smaller rural settlements preventing coalescence of settlements.

Please increase the Country Park to meet up with Warwick Castle Park and prevent future spread southwards and also protect the approach to the castle - as per English Heritage.

Section 5.1.4. continues the policy of providing 40% affordable housing. While this is excellent as a global figure it can result in providing an excess of affordable housing in rural areas where it is not appropriate. This then causes extra unnecessary demands on public transport requirements for employment and recreation. In Rural areas, affordable housing levels should be determined by Local housing assessment surveys.

Stagecoach Midlands has concerns that the strategic development proposals set out in the Strategy are coming forward through the development control system in an uncoordinated manner, in advance of the strategic Policy framework to guide this development being in place. These proposals now account for the majority of the strategic quantum. Having reviewed all of them, we find that in most cases, little consideration has been given to providing a sustainable high quality bus service within convenient walking distances of homes. We will make our separate representations on individual proposals in due course.
In general, Stagecoach Midlands believes that the density proposals do not support high-quality public transport provision. Within an average density of 30-35 dwg/Ha Master Plans should make provision for higher density along proposed bus corridors, even if this is offset by lower densities in the more remote areas.

The proposed country park should extend north to Warwick along the Banbury Road adjacent to Warwick Castle Park excluding that area from development and should extend so that any proposed development is not in sight from the park including roof tops.

This revised plan does not answer my question from the previous version. How does the council plan to maintain its levels of affordability long term are these requirements to be taken up by housing associations or the council? This is the only way I can see the affordability requirements being maintained long term, otherwise they will be purchased by private individuals and market forces will prevail and they will no longer be affordable

In general I would support the revised development strategy and welcome the inclusion of specific provision for a country park to the south of Leamington.

However, the remaining comments on green infrastructure (GI) are vague and weak and need considerable strengthening. GI is broader than the concept of open space within the Council's Open Spaces Supplementary Planning Document and that document should not be relied upon to define standards of GI expected in growth areas. GI should be integral to any design, not a bolt on. The Local Plan should seek to spell out expectations for GI and it's design.

Areas that particularly need stressing that are largely absent from the present document include

* the ways in which different elements of GI relate to each other, creating networks and corridors of green space, allowing people to move by sustainable, health promoting means within a semi-natural environment and allowing movement of wildlife. The relationship between elements of GI and the networks created are far more important than simplistic quantity standards, but it is very difficult to create these networks later. When making new green field allocations the requirement of well planned, interconnected GI should be explicit.

* the importance of urban tree planting as a vital structural element of GI. Urban trees have significant benefits in terms of mitigating climate change (cooling the urban heat island by both shading and
evapo-traspiration) [1,2], rainfall interception [3], cleaner air [4,5], residents' sense of social wellbeing [6], economic activity [7], crime levels [8] and more [9]. They are increasingly difficult to 'retrofit'
and should be designed in to new development. The Local Plan should be explicit in expecting integration of grey infrastructure with green. In particular there should be a clear requirement that major thoroughfares and a significant proportion of smaller roads be tree lined, and that all new surface car parks be planted so as to eventually provide a closed canopy (car parks being an area that allows large spreading trees). Integration of grey and green infrastructure will require that grey infrastructure is constructed so as to provide a suitable environment for trees and other GI elements to flourish. As the benefits associated with trees are greater with large spreading species, these should be favoured.

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Local Plan-Gypsies and Travellers June 2013
Norton Lindsey Parish Council
Pitches required forecast---25in 5 years and 6-8transit over plan period
GT14- this site has been the subject of numerous planning applications for a poultry sheds and has been successively rejected by the Planning Inspectorate after a campaign by the Parish Council, local villagers and the Local Planning Authority because of the dangerous access to the site amongst many other reasons.
The Parish Council do not support the inclusion of this site since it, in addition, fails to meet several of the policy criteria.
1. There is no GP surgery or public transport and the local school is already oversubscribed.
2. This area has been known to have excess surface water at times of heavy rainfall.
3. There is a dangerous access for larger vehicles to the site and it is not large enough for turning and servicing on site.
4. The site is in the Green Belt.
5. The Village is one of the few remaining hill top villages in Warwickshire and this visual entry to the village is one which has not been spoilt by development.
The Parish Council therefore reject this site as being a candidate.

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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 object to latest local plan for published by WDC for the following reasons...
We need a plan which accurately reflects the population growth and demand within the district taking into account the latest data from the `Office of National Statistics`. I believe that the current plan massively overstates the demand.
The situation has been made worse in South Leamington and Whitnash by the `immigration` of students from Warwick University.......which is 10-15 miles away, dependent on route - and in Coventry! Many `low-cost` properties suitable for `first time buyers` have been taken up by students (including new build).
Whitnash also currently takes a higher level of Immigration compared to other areas.
The healthcare and education provision is already virtually to capacity.
Transport - at times the roads in this area are exceedingly busy and hazardous around schools especially. If the schools are extended any further then the roads will be impassable at certain times of the day especially Golf Lane, Coppice Road and Morris Drive around Briar Hill and St. Margaret`s schools. The potential developer of the Fieldgate Lane area admitted that their traffic survey failed to measure the traffic at the peak time of day i.e when parents are all arriving to collect their children at the same time - around 3pm.
The plan shows an focus on the area south of the river. The `green belt` argument used to limit development to the north of Leamington is artificial. `Green belt` status is man-made, created some years ago to meet the needs of the time and should be varied when circumstances change. A more even and fair distribution across the district is needed.
There is still much `brown field land` in the wider area e.g Baginton, Ryton and do we need another fuel filling station at the new Morrisons store.
I object specifically to the proposed development of the Fieldgate Lane / Golf Lane field for the following reasons:-
Drainage / potential flooding
We have evidence of the flood risk status of Fieldgate Lane which shows that we are within 250m of an area prone to flooding (zone 3).
The drainage channel in Fieldgate Lane connects directly to the Whitnash brook in the flood zone.
The normal flow in the Fieldgate Lane drainage channel is negligible but several times a year at times of heavy rainfall the water level reaches within a few centimetres of overflowing the channel. On several occasions water has come over the top, flowed along Fieldgate Lane, down driveways and has reached as far as garage doors.
The slope of the field and loss of the water soakaway due to development must result in additional water in the drainage channel at peak times.
I have already had house insurance declined by one company on the grounds of flood risk.
We also have the situation several times during a normal winter when the ground is waterlogged to the point where we can have several centimetres of water standing across our gardens and this can take a considerable time to drain away. Fieldgate Lane also often floods with running rain water to part way up the kerbs for short periods during heavy rain. These are actual events seen by local residents.
Currently the field regularly floods in the north-west corner and along its north edge several times a year during heavy rain. Development of roads and hard standing on this sloping site will inevitably result in more runoff towards the Fieldgate Lane drainage channel and will make the current situation much worse.
Traffic hazards
The entrance to Golf Lane from Heathcote Road has long been considered a hazard and, I believe, has formerly been the prime reason for not allowing further development. The main issues are :-
... this part of Golf Lane is on a steep slope and is relatively narrow.
....visibility to the right is restricted when exiting Golf Lane.
....the junction with Home Farm Crescent is at the bottom of the slope, on a bend and visibility is again restricted when turning right into Home Farm Crescent.
The junctions at Morris Drive/Golf Lane, Golf Club entrance/Golf Lane, Golf Lane/ Fieldgate Lane corner and Mullard Drive / Fieldgate Lane are all areas which residents consider hazardous. At all of these junctions the issues are the same in that many drivers come through them not expecting to meet other traffic. It is not just strangers who don`t know the roads, but local drivers who only expect traffic from a particular direction. I am aware of the hazards and usually drive through these junctions at around 15mph but regularly have near misses. Many local drivers ignore the road signs and markings and residents can quote daily incidents.
At school times the traffic situation in Coppice Road, Golf Lane and Morris Drive is hazardous and Police are regularly in attendance. Children already have significant difficulty in crossing the roads through parked and moving traffic. We are aware of at least 2 serious incidents outside the schools.
Traffic lights at Heathcote Road / Tachbrook road are already at capacity at certain times of the day with traffic often queuing back several hundred metres.
Traffic flows have recently been measured as part of a development application for the Fieldgate Lane field but this failed to measure the traffic at school closing time as it was not considered to be a busy time of day. In fact this is the most hazardous time of day and additional traffic from this proposed site will make it worse.
Schools
It is common knowledge locally that the local schools have been at capacity since the advent of Warwick Gates. There are regularly comments in the local newspapers about the issues. Additional housing locally will make the situation worse.
Ecology and wildlife
Bats - there are numerous bats of several species which feed around the local houses and over the Fieldgate Lane field every night during the summer months and sometimes at other times of the year. The roost sites are not known but are certainly local.
Birds - many species of birds use the hedgerows and field throughout the year. I have records of 47 species using the hedgerows and fields in Fieldgate Lane alone including Tawny Owls, Herons, Lapwing, Snipe, Buzzards, Sparrow Hawks, Woodpeckers, Bullfinches,
Mammals - the field is used by deer, fox, hedgehogs (a declining species) and several species of small rodents.
Ridge and Furrow system - the field is a rare and disappearing example of the medieval ridge and furrow system of historic importance and should be preserved.
General
Formerly, the Fieldgate Lane site has been considered unsuitable because of the slope and its contribution to potential flooding. The slope of the field will also mean that the view from Fieldgate Lane will be of a succession of house ends and roofs increasing in height up the hill, particularly in winter.
The site is an `Area of Restraint` in the current local plan - for many of the reasons quoted.
A current planning application shows the access road immediately opposite our property in Fieldgate Lane This would result in major disruption to access to our property, parking and our way of life for several years. The slope of the land will mean that, at night, headlights will shine directly at our living room and bedroom windows.

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