Whole area

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.

Although not resident in the centre of Warwick which I understand has pollution from vehicle exhausts already worse than legally permitted levels I live in an area close to the existing roundabout with Myton Road. I understand that it is planned to install traffic lights with additional lanes in place of the roundabout due to the anticipated increase in traffic if the Council's proposals as to development are implemented. As I understand it the air pollution not only in Warwick itself but at the proposed new traffic lights and along the nearby roads will be worsened.

Furthermore I walk into Warwick on a regular basis as do a number of other residents in Bridge End and am concerned at the anticipated
increase in air pollution for pedestrians and householders generally. What steps are to be taken by the Council, advised by yourself, as to safety measures in relation to air pollution in Warwick itself and on the roads leading into the town and in other residential areas?

I object to the Council's proposals as to possible and substantial development to the south of Warwick and Leamington Spa in any event for well documented reasons put forward by many others but particularly on the grounds of health as indicated above. I await your reply to the second paragraph of this letter.

House Numbers :
Whilst I appreciate the efforts WDC has made to protect Greenbelt land in the north of the district , I have significant concern at objection to the numbers of homes being built on Warwick South which now totals 3500+. The project housing need of 12,000 homes is far too high. Less than half that number would meet local needs. It is wrong to forecast as far into the future as 2029, and to allocate greenfield land now. It is akin to having no plan at all, allowing uncontrolled growth, just leaving developers to decide what to build when. There are better alternatives for meeting local needs, especially affordable housing, instead of encouraging in migration and gradually releasing land for development as demand groups. Giving priority to using brownfields sites instead of greenfield site and co-operating with other local authorities with the planned 1900 houses at Lighthorne Heath and plans for Stratford District building on the opposite side of the M40, junction 15.


Infrastructure/Traffic
By building 3500+ houses on Warwick South you will have roughly 7000 more cars on the road which will increase traffic on the already congested Myton Road and Europa Way with even longer tail backs. Widening roads and junctions cluttered with traffic lights and signs at beautiful places will only serve to push more traffic through bottlenecks at Warwick at Bridge End, over the Castle Bridge, and on the approach to Leamington via Europa Way. Whilst WCC are hoping? a big IF! traffic congestion wont be any worse it will mean more cars going slower through Warwick town centre and the surrounding areas leading to extended traffic jams and delays!. . which leads me onto my next point.

Air Quality
With the increased number of cars on the roads due to the size of this development carbon emissions would increase leading to reduced air quality. I attach a copy of the 2008 Air Quality Action plan for Warwick which clearly shows a shocking picture of the poor air quality, with the very worst area being Warwick town centre which is over legal limits. The District Council is required to improve air quality, but the plan and its transport strategy would worsen it. Noise and vibration would be constant, businesses and tourism would be damaged. Worse, the long-term health of residents of these streets would be even more threatened.

Of particular interest is the comment on page 17:

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape, geology, cultural heritage and material assets must be thoroughly assessed, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. All assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

I would therefore request before any development is considered that proper surveys of air quality are carried out and if levels are indicated as being "high" as in this report enclosed which would of only increased in recent years that any housing development would be stopped on the grounds of public safety. I have written to Dr John Linnane, County Medical Officer of Health ,WCC with my grave concerns in relation public health safety.

Environment
The land between Warwick and Bishop's Tachbrook is rural and agricultural and present policies indicate this is an area of environmental sensitivity which gives Warwick town and Castle some of its finest views. Building on it would merge our built-up areas, making them a single suburban sprawl, something for which WDC said they would never do, the merging of Warwick & Leamington. The green field land is as important as the Green Belt to the north of Leamington and Warwick, and should be safeguarded just as strongly. People visiting Warwick come for its natural beauty and historic charm, yet maybe faced with a view of overdeveloped building sites!. I would be interested to know why this area has not been preserved?

Fairness
We would also like to question in the politest terms the transparency and independence of the approval process for the local plan. It seems strange to us the makeup of the executive committee who approves the local plan has no representation from Warwick South with executive members living in Kenilworth, Radford Semele, Cubbington , Lapworth and Warwick North with minimal housing development in these areas.


In conclusion I would like to see a fairer local plan with housing numbers re evaluated and more evenly distributed across Warwick district. Utilising and giving absolute priority to using brownfield and infill sites near schools, shops and railway stations; building homes close to jobs; and co-operating with other local authorities, instead of competing with them for development.

Please do not destroy and over develop our beautiful historic town!.

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.

Flooding and impact of climate change
Given the projected increased severity and frequency of storms and flash flooding due to climate change in the area the following are potentially inappropriate development site.
a. the area marked up S. of Sydenham to the East of the railway which is a further breach of the boundary between Whitnash and Radford Semele. The impact of such a development on drainage from the site itself and from the proposed development at Fieldgate Lane will probably lead to increased frequency and depth of flooding in both areas.
b. Similarly, the recent and extended winter flooding of the areas bordering the A452 south of Harbury Lane and the restricted drainage in that area would raise the question of whether it is wise to propose building in such areas.
Lack of planning for modal shift in travel behaviour

In 2012 the Council has adopted a Low Carbon Action Plan, but this is not reflected in the local plan document.

Throughout the plan there is a clear bias towards supporting and increasing travel by private motor transport. Park and Ride is a great idea for out of town visitors but will do nothing to reduce car traffic and use within the urban area from an increased residential population. Moreover, the lack of integrated provision for enhanced cycling, walking and bus travel is a major deficit in the whole plan.

There is now good evidence from other areas that have adopted a sustainable travel strategy that a modal shift in travel behaviour can be achieved.
The local plan should ensure that housing, employment and community facilities are planned in such a way to be in line with the Low Carbon Action Plan Appendix V point 4.1 - Walkable communities, which the District has adopted:

"The council through its responsibility for planning, including the local development plan for the area...has a very major influence on development in the district. The way in which new neighbours are set our and existing ones are developed has a critical impact on transport sustainability. The extent of the relationship between planning and sustainable transport has in the past been overlooked, with the motor car being viewed in the twentieth century and the universal solution. More recently the negative impacts of the motor car have come to the fore, including noise, pollution, accidents, congestion, deterioration of the natural and build environments and not lease carbon emissions..there is now the realisation that there needs to be a new paradigm not just for transport but addressing the causes for the need for transport. This type of neighbourhood [walkable community] enjoys...improved health, reduced crime, improved social contract and being an inclusive community."

The local plan does not recognise need for walkable communities outlined in its own adopted document and demonstrates a total lack of ambition in looking to influence travel patterns.

In particular the location of primary schools, the siting of which appears unrelated to proposed housing density and distribution.Similarly, there is no mention of where the required GP practices would be sited. The positions and nature of the proposed 'community centres' where such practices might be sited again do not appear to relate to the density and distribution of the housing. Employment locations are being planned as far away as the gateway and relying on people travelling to work by the motorway network.

Housing Efficiency
Housing on green field sites should be at level 5 of the code for sustainable homes to reduce carbon emissions.


Affordable Housing

The Council has an overall target for affordable housing of 40%, but green field developments, should have a higher percentage of affordable homes - 50% than brownfield sites, to encourage brownfield development. This would strengthen the hand of the Council in negotiation with construction companies.

The council's own Strategic Housing Market Assessment (SHMA) suggests that
if all affordable housing needs are to be met, about 77% of new homes
should be affordable. Therefore, the council's lack of ambition regarding
affordable housing is disappointing and suggests greater concern for
developers than local residents who are in desperate need of suitable
housing. The Council risks building housing simply to increase inward migration without solving the housing problems in the district. The Council accepts the Affordable Housing Viability Assessment
(AHVA) assessment that it is possible to have up to 50% affordable housing,
yet it is not willing to take a flexible approach and categorise sites by
level of viability i.e. insist many sites have more than 40% affordable
housing. This is despite good work of the AHVA in setting out 3 categories
of site. The Council should work harder to maximise affordable build and
therefore should:
* Categorise each site by viability to maximise the number of affordable
houses which it recognises are so badly needed
* Increase density of housing which will reduce the cost per home and
therefore enable more affordable properties to be built
* Follow the advice in the AHVA, 7.49 and reduce the threshold for
affordable properties to 7 properties in urban areas
* Seek independent opinion regarding the 20% of Gross Development Value
(GDV) return figure in the AHVA upon which viability figures are based.
This figure is not justified in the document and expected GDV returns are
falling in the property industry e.g. see
http://www.thepropertyspeculator.co.uk/tag/gross-development-value/ which
suggests 15% is more realistic. LDZ who wrote the AHVA also work for
developers and so potentially they have an interest in inflating this
figure to the benefit of developers at the expense of local residents


SUMMARY

The SHMA suggests 77% of new homes should be affordable. The AHVA says up
to 50% affordable housing is possible, so the council must insist many
sites have more than 40% affordable housing. The Council should:
* Categorise each site by viability to maximise affordable housing
* Increase density of housing so more affordable properties are built
* Reduce the urban threshold for affordable properties to 7
* Seek independent opinion regarding the 20% of GDV return figure as 15% is
more realistic

Housing density and release of land

The District is justly proud of the excellent rural areas surrounding for
our small towns. Therefore it is scandalous that this local plan seeks to
build recklessly, and largely, on green field sites. This is
entirely unnecessary for the following reasons:
* There is not a clear link between economic growth and housing
* Housing should be focussed on brownfield sites within urban areas
* More effort should be made to use currently vacant homes and retail/
office spaces, especially homes above shops
* Excellent residential schemes of up to 200 homes per hectare are quite
common, so there is absolutely no reason to advocate 30 homes per hectare
(note section 4.23 of the Strategic Housing Land Availability Assessment,
SLHAA). As household size is tending to reduce, the need for small homes
continues to grow, enabling much higher housing densities than proposed in
this plan


Even if the council does not accept the full force of the above arguments,
it should still be acknowledged that there is uncertainty in their
prediction that so much housing is required. Therefore, it is imperative
that there is gradual release of land for housing over the timescale of
this plan, with the most suitable land released first e.g. only brownfield
sites usable for the first few years, then selective low-grade agricultural
land. Only when all other sites have been built upon, should the rest of
the allocated land be released for development.

SUMMARY

Building mainly on green fields is largely unnecessary because:
* Economic growth and housing aren't linked
* New housing should be on brownfield sites
* Vacant homes/ offices should be used
* 200 homes per hectare are common, so advocating only 30 homes per hectare
is wrong. Small homes are needed due to smaller households, enabling much
higher housing densities.

Uncertainty in predictions means land should be released gradually; most
suitable first e.g. only brownfield sites, then low-grade agricultural.

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.

I have been following the development of the latest attempt at a local plan and find the whole thing a bureaucratic nonesense. A lot of very talented council employees have spent an enormous amount of their valuable time trying to create a cohesive and coordinated plan to cover the housing needs for Warick and Leamington Spa for the next generation, with appropriate infrastructure to support a very large number of houses.

However, already over 2,500 (or is it 3,500??) dwellings have had planning applications already placed with the council. These refer to potential schools, provision for health care etc but do not seem to offer the definitive infrastructure that is required. These should not be accepted until the local plan is accepted after correct public consultation. WDC should stand up to national government during the appeal process if necessary.

Why not scrap the whole thing and let a free-for-all sort it out BECAUSE THAT IS WHAT IS HAPPENING - NOW.

However I do have some specific points:
Housing.
Why are the numbers so high? Using projections based on natural growth of the population and an allowance for migration only 5400 homes are required. WDC consultants gave a forecast study in Dec 2012, in their own opinion at only 4405 new homes required. If growing for new jobs is the reason this is not required as Warwick district has low unemployment at only 1.7 percent. The 2012 strategic housing market assessment said that overall Warwick district had a very good jobs home balance.
A major issue is also why nearly 70 percent are being planned to be being built within the same area around Warwick gates and bishops tachbrook.
This will mean that their will be a huge urban sprawl of whitnash, Warwick and bishops tachbrook.
The planning inspector who reviewed the current local plan in 2006 stated that woodside farm should not be built on now or in the future. This still stands and therefore should definitely not be agreed to.
WDCs landscape consultant Richard Morrish in the landscape area statement in 2009 referred to this area at Gallows hill that this study area should not be considered for urban extension, so why is this being ignored. The beautiful rolling countryside will be destroyed.

The local infrastructure cannot possibly cope with this amount of housing. The roads will grind to a halt, already the Warwick roads cannot cope at peak times. The Warwick strategic transport phase 3 assessment show traffic speeds of only 0-10 miles per hour at large parts of Warwick.

Warwick hospital is already at capacity and cannot possibly take more people using its facilities.

The school system in the local area is already bursting at the seems, priority areas are over subscribed. Particularly a problem is Warwick gates where I am a resident. WDC failed to provide a school for over a thousand homes and this has constantly caused problems within the school system, having a knock on effect to all local schools and families. My son has currently the worrying task of finding a school place for his daughter and we know of many people disappointed this year who have not managed to get there child into any of their 6 choices even with being a mile or so down the road from the school. If all these houses are going to be built as well as the gypsy sites, will the schools be in place before the houses are built, or are the current residents going to be forgotten and pushed out of priority areas with new people moving into the area. The schools MUST MUST MUST be built before the houses are occupied to stop any further issues. You cannot allow another mistake like Warwick gates to happen.

I cannot more strongly object to this local plan and the applications that are trying to sneak in the back door. WDC must take more time to consider the plan and reduce the amount of housing and distribute it evenly over the district and not just penalise our area.
The back door applications must be refused until this process is considered together.

The Warwick DC Local Plan

I write to raise my strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.

This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.

Scale and proportion

* massive long term coalescence of settlements,
* loss of significant open space,
* loss of local countryside,
* loss of agricultural land,
* lead to significant urban sprawl.
* 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/13/0858 - 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

I write to raise my strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.

This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.

Scale and proportion

* massive long term coalescence of settlements,
* loss of significant open space,
* loss of local countryside,
* loss of agricultural land,
* lead to significant urban sprawl.
* 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/13/0858 - 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

I would like to register my support for the Revised Development Strategy for the local plan.It is heartening to see that this Revised Development Strategy now recognises that there are no exceptional circumstances that warrant major development of the North Leamington Greenbelt and that it is necessary to preserve the limited greenbelt between Leamington and Kenilworth.
WDC is to be commended for this revision as whilst it keeps the housing requirement it manages to satisfy this through the better use of brownfield sites and a limited number of houses on greenbelt land south of Leamington, where there is a greater amount of greenbelt before any other town is reached.This revision also is more equitable in the way that the new houses are allocated including 17% in greenbelt to the North of Leamington and 15% in villages.
Development to the South of Leamington also places people close to employment opportunities and should reduce the journey time/mileage for commuting to work for these new households, which should be beneficial for the environment as well as the people concerned.
I note that the Revised Development Strategy provides for improvements to the road network to the south of Leamington and for the provision of the necessary schools and other infrastructure to support this Development - I would hope that these improvements are built in a timely and co-ordinated fashion.
Overall I would commend WDC for revising the Development Strategy .

Warwick Local Plan
Objections to Development of South Sites (areas south of Warwick)
Since there is a proposal for 'a major sub-regional employment site in the North East of the district' it appears very odd to site 3,195 houses South of Warwick, which almost inevitably will create huge volumes of traffic - the plan for which appears to be to direct it along the Banbury Road over the Avon Bridge through the town and out along the Coventry Road, presumably heading to the 'sub-regional employment site in the North East'.
It appears that the proposals regarding roads are to the benefit of traffic - easing as much through the town centre as possible...the document refers to 'a more attractive route to vehicles'.
An audit of current pavement usage? What about the current users of the pavements? Has the Local Plan taken into consideration the current numbers of pedestrians, cyclists, dog walkers, joggers, parents with prams and toddlers in tow, tourists photographing the castle, school children walking in groups to and from all three Warwick Foundation Schools and Myton School at key points during the day.
St Nick's park is really well used. Rowers and various boat users on the river Avon, walkers, joggers and children. Sea Scouts is based in the park. One of Warwick's most beautiful spots is the iconic view from Avon Bridge across to the castle. It's simply stunning. Lots of tourists congregate on the bridge to take photos; it is not a road that could/should take large volumes of traffic.
The Banbury Road needs to keep the pedestrian crossings. Numerous children cross there daily to get to school. There also seems to be a trend for office workers from Heathcote Industrial Estate to take a healthy walk around Bridge End at lunchtimes. People currently enjoy living and working in Warwick.
Traffic Noise/Pollution Warwick Prep School Playground for the youngest pupils is next to the Banbury Road (pollution levels? Noise in classrooms?) The Avon Bridge, St Nick's Park (which is extremely well used and visited), the Myton Road with its 3 schools, are not areas to try to increase the volume/speed of traffic. A Left filter turn into Myton Rd seems particularly worrying- a school girl broke her leg being hit by a car there around Easter time. To have a filter lane - which encourages continual movement - by a very large school seems absurd. A left lane filter would remove an area that is currently pavement and landscape and a buffer between school children and the numerous coaches and cars that turn there during school hours.
Green Belt Vs Historic Buildings? It appears that some previous plans did not progress due to concern for the Green Belt north of Leamington. The traffic will be increased in parts of historic Warwick, especially over the grade II listed Avon Bridge. Bridge End is a conservation area, the route along the Banbury Road is landscaped which is meant to reflect the tradition of Warwick Castle Park. The impact of additional signage and traffic lights on the historic vistas through the town centre would be detrimental.
If there is to be some increased housing in Warwick, such as that of the Myton Road, surely the priority is to ensure that children living in those houses can cycle to Myton/Warwick school and allow their parents to walk or cycle to work in Warwick/Leamington town centres. Therefore increased cycle lanes would be paramount to any green plan for the area.
There's nothing in the plan to benefit those people with shops and businesses in Warwick. The town centre needs a better parking plan. There is nothing to encourage the volumes of traffic to be directed through the town to stop and enjoy the things that Warwick has to offer.
Misguided traffic proposals. The idea to block one entrance of Bridge End is unworkable. Cars are invariably parked on both sides of the length of Bridge End and there are already occasional problems with deliveries. This conservation area needs to keep access for emergency vehicles, refuse collection and deliveries.
All traffic should be directed out of the centre of Warwick - not through the middle of it! It is imperative that any new houses based south of Warwick should have major road access to the by-pass/motorway or other links to major employment areas. The roads and buildings in Warwick are such that there will always be a maximum capacity however much tinkering goes on to 'improve traffic flow'. The town environment and historic nature of the area deserves much better than to make its roads the main priority.

Objections to Development of South Sites (areas south of Warwick)
Since there is a proposal for 'a major sub-regional employment site in the North East of the district' it appears very odd to site 3,195 houses South of Warwick, which almost inevitably will create huge volumes of traffic - the plan for which appears to be to direct it along the Banbury Road over the Avon Bridge through the town and out along the Coventry Road, presumably heading to the 'sub-regional employment site in the North East'.
It appears that the proposals regarding roads are to the benefit of traffic - easing as much through the town centre as possible...the document refers to 'a more attractive route to vehicles'.
An audit of current pavement usage? What about the current users of the pavements? Has the Local Plan taken into consideration the current numbers of pedestrians, cyclists, dog walkers, joggers, parents with prams and toddlers in tow, tourists photographing the castle, school children walking in groups to and from all three Warwick Foundation Schools and Myton School at key points during the day.
St Nick's park is really well used. Rowers and various boat users on the river Avon, walkers, joggers and children. Sea Scouts is based in the park. One of Warwick's most beautiful spots is the iconic view from Avon Bridge across to the castle. It's simply stunning. Lots of tourists congregate on the bridge to take photos; it is not a road that could/should take large volumes of traffic.
The Banbury Road needs to keep the pedestrian crossings. Numerous children cross there daily to get to school. There also seems to be a trend for office workers from Heathcote Industrial Estate to take a healthy walk around Bridge End at lunchtimes. People currently enjoy living and working in Warwick.
Traffic Noise/Pollution Warwick Prep School Playground for the youngest pupils is next to the Banbury Road (pollution levels? Noise in classrooms?) The Avon Bridge, St Nick's Park (which is extremely well used and visited), the Myton Road with its 3 schools, are not areas to try to increase the volume/speed of traffic. A Left filter turn into Myton Rd seems particularly worrying- a school girl broke her leg being hit by a car there around Easter time. To have a filter lane - which encourages continual movement - by a very large school seems absurd. A left lane filter would remove an area that is currently pavement and landscape and a buffer between school children and the numerous coaches and cars that turn there during school hours.
Green Belt Vs Historic Buildings? It appears that some previous plans did not progress due to concern for the Green Belt north of Leamington. The traffic will be increased in parts of historic Warwick, especially over the grade II listed Avon Bridge. Bridge End is a conservation area, the route along the Banbury Road is landscaped which is meant to reflect the tradition of Warwick Castle Park. The impact of additional signage and traffic lights on the historic vistas through the town centre would be detrimental.
If there is to be some increased housing in Warwick, such as that of the Myton Road, surely the priority is to ensure that children living in those houses can cycle to Myton/Warwick school and allow their parents to walk or cycle to work in Warwick/Leamington town centres. Therefore increased cycle lanes would be paramount to any green plan for the area.
There's nothing in the plan to benefit those people with shops and businesses in Warwick. The town centre needs a better parking plan. There is nothing to encourage the volumes of traffic to be directed through the town to stop and enjoy the things that Warwick has to offer.
Misguided traffic proposals. The idea to block one entrance of Bridge End is unworkable. Cars are invariably parked on both sides of the length of Bridge End and there are already occasional problems with deliveries. This conservation area needs to keep access for emergency vehicles, refuse collection and deliveries.
All traffic should be directed out of the centre of Warwick - not through the middle of it! It is imperative that any new houses based south of Warwick should have major road access to the by-pass/motorway or other links to major employment areas. The roads and buildings in Warwick are such that there will always be a maximum capacity however much tinkering goes on to 'improve traffic flow'. The town environment and historic nature of the area deserves much better than to make its roads the main priority.

4.3 Broad Location of Development Housing
1. The Council's revised assessment of housing need is welcome, specifically the reductions in the need for large developments on green-field sites by an improved focus on the capacities of urban SLHAA sites and likely windfall sites.
2. The Council's proposals to maintain important green areas, such as the Green Belt north of Leamington and the Asps adjacent to the Castle Park, the creation of a 'country park' along the Tach Brook and proposals for other as yet undefined green infrastructure corridors are also welcome. Further work should be done, however, to ensure the establishment of significant areas of connected green space within all major proposed housing developments in order to minimise the unrelieved uniformity that characterises so many modern large-scale housing developments and facilitate healthier alternative forms of transport. In this regard, my comments on paragraph 5.1 of this plan suggest a possible significant enhancement to the current proposal for the Country Park adjacent to the major development area south of Warwick and Whitnash
3. In particular, however, the location of the bulk of the housing to the south of Leamington, Warwick and Whitnash is strongly supported, not primarily because it minimises use of Green Belt land, although that is important, but because it does not necessitate the construction of an environmentally destructive new road across the Avon corridor north of Leamington. Significant development to the north of Leamington also makes no sense in terms of transport planning when most of the large retail outlets requiring car access are south of the railway and would increase cross-town car traffic - already at its limit because of the barriers of river and railway.
4. Spurious arguments of 'fairness' should be countered with robust defence of planning logic by officers and councillors - in particular in the area of transport planning. The areas now proposed already have good access to the M40, Leamington station and an existing, relatively easily upgradable transport infrastructure. The key transport problems within Leamington are railway crossings. North of the railway, development is currently fairly stable, while almost all of the new road infrastructure and major-volume retail development (Sainsbury, Lidl, Morrisons and Aldi) has been to the South, with further additions recently announced. Placing the bulk of housing development on land to the South of the railway line, with easy access to the motorway and rail network and to most major retail outlets, will minimise the traffic pressures at rail crossings and across the historic centre of the town.
5. There are, however, legitimate concerns for residents in areas adjacent to areas of large housing developments, particularly with respect to transport issues and to the look and feel of their neighbourhood. It is essential that the Council explores all possible options to ensure that these developments do not assume the character of the Warwick Gates development - a ghettoised housing desert of nearly identical builds relieved by few amenities, little communally useful green space, and almost no integration except by car with other areas of the town. It is essential in the major developments now envisaged, that the total outcome is a high-quality integrated urban development, which significantly enhances the overall attractiveness of the southern areas of Leamington, many areas of which seem to have been accorded 'second-class' status in the past.
4.4 Housing allocations
1. One topic completely missing from the current plan is the allocation of land for self-build properties. This has been raised in one of the consultation meetings and in my opinion should be included into the current consultation and review process and into any future reviews of the plan. The lack of land available for self-build in the district is well-known, so addressing this by identifying areas for self-build properties could provide a significant, practical and popular addition to the plan. Self-builds typically deliver higher quality and more varied housing and could provide an important quality-enhancement both to the housing stock as well as enhancing the amenity and character of the area. This could be ensured by requiring all such builds to meet the highest standards in terms of ecology and sustainability and design. It would also help local employment, because such developments are much more likely to use the services of local professionals and tradesmen.
2. In particular, as demonstrated in my submission to the original plan, there is significant scope for beneficial, larger scale development in both Primary and Secondary Service Villages and - in a more limited way - across the totality of the numerous smaller villages and settlements. This should be explored both as part of this plan and any future revisions of it because it is a way of managing development across the district while also minimising loss of/damage to Green Belt areas. Village residents are right in not wanting to have their environments degraded by significant developments, but this applies just as much in already established areas so real issues of 'fairness' lie here rather than in intra-town disputes fuelled by nimbyism. It cannot be right that inhabitants of major local villages parasitise services in neighbouring towns when many such services (schools, shops, health facilities) could with some extra growth in major villages sustainably be provided locally for themselves and adjacent smaller settlements. Apart from the added convenience for villagers, it would also reduce traffic problems across the district. Making self-build land a significant element in village developments (though not only there) could also do much to encourage developments of an unthreatening kind.
3. A further general comment relates to the uncertainty of some future aspects of housing allocation relating to negotiations with adjoining areas. In particular, with respect to the proposed major employment site around Coventry airport and the outcomes of the Joint Strategic Housing Market Assessment undertaken with other councils within Coventry's Housing Market Area, should further Green Belt land be required to provide additional housing in the Warwick District Council area, sites should be identified on the fringes of Coventry adjacent either to the airport development or in the proximity of Warwick University (a major employer located on the border between Coventry and WDC land). In the re-evaluation of the SHLAA presented with comments on the previous plan, a number of suitable sites with potentially significant capacity were identified. As with Kenilworth, there is no alternative to the use of Green Belt land, but all of these were sites where impact could be minimised, especially in conjunction with the development of green corridors similar to those proposed below for the proposed developments south of Warwick and Whitnash.
5.1 Southern Sites: Sites South of Warwick and Whitnash
1. While supporting in general the idea of a Country Park to prevent coalescence with Bishop's Tachbrook, the current proposal privileges only Bishop's Tachbrook residents and those in new developments immediately adjacent to it. It does not form part of any green infrastructure useful to the establishment of non-road transport alternatives or create an amenity benefit across the whole of the new development area. This proposal should be amended and extended to the potential benefit of all residents in the proposed new developments and adjacent areas by, for example:
a) Creating a significant green strip all along the north-eastern side of the proposed South Warwick development area (west of Europa Way, south of Harbury Lane and west of Oakley Wood Road) and south of Gallows Hill, which would both improve the green space and amenity areas to many more southern residents, and facilitate an appropriate base for the establishment of linked amenity areas as well as for a healthy, safe non-road transport infrastructure - for walking, cycling, mobility scooters and other sustainable personal transport devices.
b) Compensate for the loss of building land involved by moving the proposed Country Park to the area of 'possible expansion' shown for it south of the Tach Brook. This could extend right up to the current northern boundary of Bishop's Tachbrook, so facilitating the expansion of non-road transport links with it and ensuring a barrier against future coalescence or development north of Bishop's Tachbrook. If the ideas outlined in my response to 4.4 were adopted, there may be no need for further allocation of building land in this area, but if there were, some suitable space exists south of the current development west of Europa Way, which, but if kept close to Europa Way, would not significantly affect the designated protected area of the Asps.
c) This linked amenities/alternative transport infrastructure could form the basis for further enhancements to an alternative transport infrastructure linking the north-eastern corner of these development sites with the town centre and local retail sites to the potential benefit of many more local residents, especially if complemented by the addition of a new alternative transport crossing of the railway line and canal so better linking the north and south of the town and benefitting all town residents, including car users,. In the longer term this could, with the addition of bike hire as in London, also facilitate in the longer term the establishment of a "park and bike" scheme to complement any virtual park and ride facility south of the town.
5.6 District-wide Transport Mitigation Proposals
Note: In the comments made below, reference is often made in terms of cycling, but it is everywhere intended that these are taken to include walking and use of other low-speed personal transportation such as mobility scooters.
1. In the absence of the time or information to rank these proposals in priority order, it is noted that all seem in principle justifiable. This is, however, far from the key issue, which is the continuing lack of attention to sustainable alternative transport in the Warwickshire area and the continued imbalance towards expenditure on car transportation (specifically cars, because no such expensive works would be required even with a significant increase in public transport). A continuing progressive rebalancing is urgently needed.
2. As outlined, the proposed improvements to the cycle network are piecemeal and will result in little more than one significant cycle route - from Leamington to Kenilworth and on past Warwick University to the outskirts of Coventry - a sort of HS2 for cyclists with few linkages to any wider, safe alternative transport environment. All the rest of the cycle transport network consists and will continue to consist of (slightly upgraded) a hotchpotch of routes, sometimes partial, sometimes on roads, sometimes on pavements, usually ending just before a point where real investment is needed to provide safe facilities for cyclists, frequently ignored by drivers, who drive on them or park on them apparently with impunity because infringements are rarely if ever policed. They are also designed with little consideration of the desire (and need) of cyclists to travel efficiently - crossings and road junctions seem designed primarily for car users and to favour smooth flows for cars rather than for cyclists or pedestrians. Against this background of historical lack of delivery, all of the protestations about maximising sustainable travel, reducing the impact of car-based travel in the region appear to be just more hot air, unlikely to be realised.
3. The Warwick District Council plan requires a long-term strategic plan to establish a basic infrastructure (with targets for initial delivery and targets for extensions and improvements) if the health and amenity benefits of walking and cycling are ever to be properly realised and the mobility interests of disabled people to be addressed. The suggestion of enhanced green-corridors outlined in the comments on 5.1 above could be one element, which could be matched in all of the other major development sites. The strategy should then be to establish a network of major routes for personal non-car/motorbike travel within and between the local population areas, which could inter alia include:
a) a continuous tarred riverside pedestrian/cycle route from Warwick to Leamington with a pedestrian/cycle bridge to cross the Avon and the Leam/Avon junction (this route has been facilitated by the proposals to develop the old Guide Dogs for the Blind property and the 8 metre buffer zone from the watercourse to the development boundary) and would be relatively easy to achieve from St Nicholas Park to the Campion Hills, providing a safe alternative transport spine between the two towns. Appropriate long-term targets would be to enhance this so as to provide, in the longer term, an uninterrupted route with no interactions with conventional road traffic.
b) a continuous tarred canal-side route from Sydenham to Warwick Parkway Station created by cutting back growth and works to maximise the width where possible. Appropriate long-term targets would be to explore options for creating more space underneath existing bridges (perhaps as bridges are maintained/redeveloped), a link to Warwick hospital and railway station and towards the town centre, a link to the new southern development and riverside route, a link to Leamington station and on to Whitnash.
c) a south-north route within the town, from the station across the Leam and Pump Room Gardens and to Clarendon Road up Binswood street and Tavistock Street, which should both be made pedestrian/cycle and deliveries only. An extension up Beauchamp Road to Binswood Avenue would create a very efficient safe path for non-car users, especially children cycling to school, through the town with minimal impacts and possible improved footfall for shops, the loss of relatively few parking spaces and mostly positive impact for car drivers (the main town centre parking sites are along this route - all reachable from Augusta Place, Windsor street and Russell Street).
d) the effective extension of the cycle path past Guy's Cliffe to Coventry by identifying the B4115 as a road primarily for non-car use. This would not require the banning of traffic but through/inessential traffic could be minimised by enforcing a low speed limit and making some sections one-way only, so facilitating car and cycle separation. Long-term targets for this route, which could become the major inter-urban link for the area could include a link from Old Milverton to Hill Wootton with a pedestrian/cycle bridge across the Avon, links to Leek Wootton and Kenilworth across existing pedestrian/farm bridges, an extension from Old Milverton to Trinity School/North Leamington School along the backs of the allotments. An extension into Coventry could also be negotiated.
e) Alternative personal transport users, like car drivers, need secure places to leave their cycles, mobility vehicles, and other equipment. At all important destinations (stations, shopping malls and town centre locations, parks, etc.), provision of spaces where such vehicles can be securely parked should also be factored into a strategy with longer-term improvement targets - preferably with a good proportion protected from the weather and -if feasible - some provision for lock-up storage.
These proposals are not intended to favour the existing cycling community, though they would clearly benefit them. They are aimed at the increasing number of people who would like to cycle, who would like their children to cycle, but fear to do so because of the evident dangers of cycling in an environment which is so skewed in favour of cars that cyclists are ignored and resented in equal measure. Equally importantly, they are also aimed at benefitting pedestrians and the less mobile, who would welcome more, safer infrastructure to facilitate their travel. Safer cycling would increase uptake, reduce school-run impacts and other traffic problems, improve air quality, improve health, reduce healthcare costs - and be much cheaper than conventional roads to establish and maintain. The demographics of Leamington undoubtedly favour a progressive policy of this kind and could help to sustain the attractiveness of this area for young, highly-educated entrepreneurs.

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Please accept this objection in addition to any others as it contains other information that has come to my notice.
1. There is no supporting Local Plan to allow this application.
2. The existing 2007 Local Plan is still in force and is still relevant to this application.
3. This application has been made by the developer knowing that the current Local Plan would not support it.
4. The application by the developer/land owner has been made with prior knowledge that a new Local Plan was under consultation but not approved.
5. The application is for 220 dwellings but makes no reference to the phasing over the next 17 years. As this is common to all applications that have been made and most likely will be made then it should fail on this point and be rejected.
6. WDC should have made this clear in any discussions with developers but failed to do so.
7. The NPPF came into force in 2012 and should not be assumed or considered to be out of date.
8. WDC have identified and recommended this site as being acceptable for development without any consideration of the harmful effects on the surrounding neighbourhood.
9. This application must not be taken in isolation. It is part of a large number of present and future applications to satisfy WDC's poorly researched information on housing numbers. This may be due to numbers they have accepted from the Minister of the Environment or their own numbers from GL Hearn.
10. The 12,300 is the latest number that is now being quoted by WDC. This has been challenged as being pure guesswork without any positive proof. It has been suggested that 5,400 is closer to the truth following work by a local councillor.
11. It is not being truthful or fair of WDC to invite individuals to object only to the application sites adjacent to their homes, as indeed that is the case of this development. They should be objecting to the total applications under the umbrella of the Local Plan. If that is seen as unsustainable then all applications should be rejected.
12. WDC have put themselves in the position of having to consider many applications to build a large number of houses. It is now a rat race by developers as to who can get in first. This should not be run on a 'first come first served basis'. Applications should be in abeyance until after the Local Plan has been properly consulted.
13. Consultation meetings I have attended all have the same theme. That is to give the public details of what has been decided and ask for questions. There is indication that the massive objection that is taking place will stop the intention of the Local Plan.
14. The Local Plan as seen by the public for the first time was in its final and intended form with no facility to consider alternatives. Therefore it is not a consultation document seeking approval. Rather it is a statement of intent. This must be referred to a Public Enquiry.
15. There are alternatives to creating urban sprawl. A - Proportional distribution throughout the district over 90 to 100 small sites in or adjacent to villages, with no increases for Leamington Warwick and Whitnash that have received the bulk of development over many years. B - Two or Three medium isolated sites to the North, East and West of the District with zero housing South of Leamington and Warwick. C - A new town in Green Belt that is completely independent of neighbouring towns and villages. This would be a challenging but exciting alternative that would give established towns and villages a chance to stabilise.
16. It has never been made clear by WDC that they have supported or facilitated the applications by various developers even though they deny this.
17. WDC are aware that the Local Plan now under consultation has not changed from the previous 2007 Local Plan and are now attempting to convince the public it is a viable and acceptable plan.
18. WDC are in full knowledge that this application is just a part of a massive urban sprawl they have recommended as being suitable for the 12,300 houses they have stated are needed to 2029, without any proof of the needs of those houses.
19. WDC have failed to recognise the severe impact on the present incumbents of a very large area South of Leamington and Warwick that the combined applications would have. So this application like all of the others must not be permitted.
20. By encouraging the various developers (including Gallagher Estates) to submit applications in order to show that the 12,300 houses are deliverable they have effectively isolated each development application from the residents who are not directly joined to every site.
21. By not carrying out a fair and just consultation on this application and con-joining it as part of the overall intent of the New Local Plan, WDC are minimising the effects on the unwitting public of all the applications when combined under the 'Master Plan' .
22. The consultation period for the Local Plan has been extended after public protest. There is still not enough time to complete an effective consultation because of the large area covered by the Local Plan.
23. This application must only be judged in combination with all other present and known future applications. Each application must be placed in a Local Plan Group and considered as such.
24. If the 12,300 number is successfully challenged and kept within a suggested 5,400 this total can be shown to have satisfied the 5 year and beyond requirement.
25. This application being part of the New Local Plan that is to provide housing needs up to 2029 is for 280 dwellings. That should only permit an application for 17 houses each year. Any application in excess of that should be rejected.
26. The laws of supply and demand should be accepted as being the meter for providing houses for those who not only need them but can afford them. The 12,300 number being quoted by WDC is a mythical number with no proof. Therefore the New Local Plan should have recognised this fact and factored the numbers accordingly.
27. Owning a house is the biggest single commitment anyone takes. It is undeniable that of all those who want a house, there will be many who will never afford to do so. Their only recourse is to rent. The houses in this application (and all others) are not aimed at the low cost rental market.
28. The number of people living in the vicinity of 75% of the 12,300 houses who need or will need a house do not represent the need for this number of houses. The truth is that developers are speculating on selling these homes to anyone outside of the area who can afford them. WDC should have recognised this and should only allow developments that are for the local people
29. A result of the above, is that anyone who lives in the area concerned who will be looking to buy will not be able to do so as they are out of their price range.
30. This application will destroy the protecting green area that protects the ancient town of Whitnash. There is considerable wildlife in the neighbouring woodland and the farmland that will be gone forever. This is important and needs protection.
31. The actual site of this application will further disruption to an already extremely busy road.
32. A further proof of supply and demand is that the estate agents are overflowing with houses for sale, but only a few that are affordable.
33. Another fact is that present house owners wishing to move or upsize cannot afford to due to the squeeze from government spending cuts. Their only answer is to extend and even that is very restricted due to the high costs involved and petty restrictions imposed by District Councils.
34. Warwick District Council should not cave in to government demands but should use the ability of elected councillors and the public to protest to the Minister of the Environment.

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We oppose the decision taken by Warwick District Council on providing land around the village of Bishops Tachbrook for the purpose of permitting travellers/gypsies to set up temporary home. These people have a total disregard for anyone but themselves and many fund their existence by crime, namely burglary other aspects of theft and damage to property. This I know in dealing with the travellers who set up camp over the years in and around Tachbrook Park. In my capacity as a security provider to businesses on this estate I dealt with the problems as detailed above which were regular when they were present. Recently we had travellers encamped on the edge of our village near your proposed site and they were moved on last Thursday. They have left us with rubbish and human waste which is right beside the main Banbury road and the entrance to Hill Top Farm. We also came across a bird which had been shot with a crossbow bolt. So WDC expect us to tolerate this behaviour on a daily basis? During the discussions with yourselves we identified some sites on the A46 away from decent home owners and people who pay very high council tax and whom you expect to vote for you.

Now to focus the new homes subject. The proposal for the village to take on a very high proportion of new houses is absolutely diabolical. Why does South Warwickshire have to be the place for this horrendous amount of new housing? Some of these houses will be for people who will be working near Baginton so why is North Leamington or Coventry not being looked at for new housing? The old Peugeot factory site still has undeveloped land and there is also sufficient land for you to compulsory buy in and around that area. If you can build a railway (HS2) through greenbelt you could build a few houses on it too.

I would like for you to add my email to the many that you have received already and to please take note at what people are saying.

1.1 In its Local Plan Revised Development Strategy, May 2012, the Council [in para 2.2] invites comments on the proposals. Here are the comments of The Warwick Society.
While the Society's main concern is that a better Plan must and can be proposed, these comments are necessarily framed as objections, to make it clear that the present proposals are unacceptable to many residents of Warwick and its neighbourhood as well as to the Society.
Just as the Revised Development Strategy [its para 1.4] focusses on the main changes since the Preferred Options proposals, so this response is to be read alongside the Society's letter of 27 July 2012 commenting on the Preferred Options, of which a copy is annexed, pages 6-10.
1.2 The Warwick Society, the town's civic society, was founded in 1951. It has as its first aim
to conserve, for the benefit of the public, or to encourage the conservation of,
the natural, artistic and cultural amenities of Warwick and its neighbourhood.
It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people. The history and the architectural character of Warwick, which make it one of the most distinctive towns of its size in Britain, were summarised in the Society's letter of 27 July 2012 .
1.3 The Plan and its Development Strategy give an opportunity to make the town and the district around it a finer place, and a better place to live in, to be educated in, to work in, and to visit. It is well-placed at the south-eastern corner of the West Midlands for sustainable development, prosperity and continuing attractiveness. The requirements for a Plan pursuing these ends were summarised in the Society's letter of 27 July 2012 . That letter continued :
The Preferred Options fail by a long way to achieve this. The Issues identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.4 We greatly regret that, in the face not just of the Society's objections but also of strong criticism from the overwhelming majority of respondents to that consultation, the Council proposes an RDS which would do even greater damage to Warwick and its neighbourhood.
97.5% of respondents objected to development of the land south of Warwick. The Council's retort has been to increase substantially the number of houses proposed for that area, postulating that public opinion carries little weight in such decisions.
The arrogant disregard of the Council for the views of residents and other interested parties is itself cause for objection to the RDS.
1.5 The RDS has many accompanying documents. It is a further sign of the attitude of the Council to public involvement that all have been issued simultaneously, giving residents and other interested parties only six weeks during the summer holiday period to understand, discuss and respond to material which has taken well over a year for many council staff and consultants to produce.
As well as much more material in the 'evidence base', these accompanying documents include:
Sites for Gypsies and Travellers, raising concerns for residents adversely affected by the RDS by proposing a majority of the twenty potential locations for the three sites needed throughout the District in the same concentrated area close to Warwick;
The Community Infrastructure Levy Preliminary Draft Charging Schedule, which is not referred to on the Council's webpage notifying us of the consultation on the RDS and G&T sites but only on a later, subsidiary page;
The Final Interim SA Report, which disguises its purpose - Sustainability Appraisal - behind its acronymous title, is neither notified on the webpage outlining the two 'main' consultations, nor referred to at any point in the RDS which it purportedly supports; and
The Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3, which proposes the reversal of existing policies to reduce the impact of traffic in Warwick Town Centre but is not itself the subject of 'consultation'. The County Council unilaterally abolished the Town Centre Forum late in 2012 and has done nothing in the intervening eight months to implement the new but less effective process of discussion with which it proposed to replace it.
1.6 We explain hereafter as briefly as we can our main objections to the Revised Development Strategy. We do not comment on the Final Interim SA Report nor the Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3 or the other accompanying documents, but have many observations on their assumptions, analysis and conclusions which we will make separately.

2 Housing Need
2.1 The criticism of the methodology and the outcome of the housing need projections made in our objection to the Preferred Options , stands. The proposed figure of 12,300 new homes to be built is much too high. We note that it is a provisional figure, pending completion of the joint assessment being carried out with councils in Coventry, Rugby and Nuneaton & Bedworth. It must also be dependent on co-operation with Stratford District Council over its proposal for a new settlement at Gaydon, which might be superior to much of the proposed development south of Warwick in meeting housing needs for employment there.
2.2 You have yourself stated, at the Community Forum meeting held at Warwick Gates on 13 June, that half of those new houses would meet local needs and half would be for incomers . In our view, even less than half of 12,300, under 6,000, will be sufficient to meet local needs, and we refer to the analysis carried out and discussed with you by Ray Bullen for Bishop's Tachbrook Parish Council which supports our conclusion.
2.3 Forecasting as far into the future as 2029 is clearly very uncertain. By fixing now a single end figure, based on assumptions and trends and 'compound interest' - incurred by repeating small percentage differences over many years - the RDS projections can only have one certainty - that they will be wrong. Worse, by taking this single long-distant future figure and giving it short-term weight, in allocating greenfield land for development now, the damage of error will be immediate. This approach is akin to having no plan at all, allowing uncontrolled growth, leaving developers to decide what to build when, with our towns, villages and countryside blighted by the effects of false certainty and a National Planning Policy Framework which seeks development at all costs.
2.4 While the NPPF requires 'sustainable development' which meets an 'established housing need' to be approved , planning applications already made or imminent for much of the land south of Warwick meet neither of these criteria. A realistic forecast of housing need is that the District already has the required five-year +5% supply of sites. Using the exaggerated and uncertain RDS projections in support of short-term, expedient planning applications - which could over-ride the Plan process before it reaches Examination in Public - would open the Council to legal challenge.

3 Prudent use of Land and Natural Resources and
Protection of the Natural Environment and Landscape
3.1 The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint', designated at the time of the construction of the Warwick Technology Park, and intended to give permanent protection to this vital green gap. The Society has repeatedly suggested that it should be designated as Green Belt, but the Council has refused to implement this.
3.2 Building on it would merge the built-up areas, turning them into a single suburban sprawl. This would conflict directly with one of the principles of the Local Plan Strategy, 'avoiding coalescence' .The green space between the built-up areas to the south is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded as strongly.
3.3 Once developed, this green land could not be reclaimed. Its development would conflict with the basic principle of sustainability, 'meeting the needs of the present without compromising the ability of future generations to meet their own needs'

We use the term incomers as being less ugly than the technical term in-migrants, regretting that there seems to be no expression which is not pejoratively confused with the word immigrants; we refer to people moving into Warwick District from other areas, noting that encouraging the movement of better-off people from the West Midlands conurbation and Coventry may be one of the objectives of developers in Warwick District, and perhaps of the Plan.
Your word not ours; Revised Development Strategy, page 8, third point from bottom
Report of the World Commission on Environment and Development to the General Assembly of the United Nations, 11 December 1987
4 Sustainable Transport and Reducing the Need to Travel
4.1 Sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network. While the Local Transport Plan gives priority to sustainable means of transport in the hierarchy - walking, cycling, public transport - the Transport Strategy assumes that these developments would have the same ratio of peak hour car use to housing numbers as every other development of recent decades.
4.2 Development at relatively low density cannot effectively be served by public transport. The low concentration of the population does not provide sufficient volume for a bus service to run viably at a frequency which makes it an attractive competitor with car use. The limited influence which the County Council has over operators of unsubsidised commercial routes make it unlikely that a bus service would survive after the first few years of developer subsidy, as has been seen at other sites including the Hatton hospital redevelopment.
4.3 Whatever the fine words about walking and cycling routes within the suburban developments, these sustainable modes will not make a significant contribution to meeting transport needs. Distances will be too long for walking, for example from the areas south of Warwick to the town centres or railway stations; and cycling will be very unattractive as soon as cyclists reach the road network on which the use of cars has been intensified. The putative designs of new junctions in the Transport Strategy make it clear that the design priority would be to maximise the flow of vehicles, with people on foot and cyclists diverted to circuitous routes, with secondary priority at traffic light controlled crossings.
4.4 The Transport Strategy concludes that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. The infrastructure plan proposes spending almost all of the potential developers' funding contributions on intensifying the use of the existing road network. The schemes that it labels 'junction improvements' and 'mitigation' would be improvements only in maximising the flow of vehicles; and mitigation only in reducing the increase in congestion, while increasing not reducing the impact of traffic on town centre streets. They would both make sustainable modes less usable and damage the historic and natural environment with the intrusive impedimenta of the highway engineer.

5 Air Quality and Climate Change
5.1 The already illegally dangerous pollution in streets in centres of Warwick and Leamington would be made worse by the increase in traffic. Noise and vibration would be constant and business and residential amenity would be damaged.
5.2 No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, and in particular to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings, all require air quality to be given absolute priority.
5.3 It has been suggested by the Council's Chief Executive that the air quality requirement could be met after development has been approved by then considering ways in which traffic through Warwick town centre could be reduced. This approach would invalidate the Transport Strategy, as the only way to reduce the volume of traffic would be transfer to other modes or other routes, neither of which has been assessed in the Strategy. A transport plan which meets all the objectives, including protecting the historic environment and assuring air quality, must be agreed before development is allocated.


6 The Historic Environment and the existing built environment
6.1 Warwick's historic environment is vital both to the social goals of the plan, to give people a sense of place and belonging, and to the economic goals as the basis of its visitor economy. It would be directly damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's.
6.2 Development on the land between Europa Way and the Banbury Road would extend sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would directly damage the Castle Park, Grade 1 registered landscape; and the 'junction improvements' on the Banbury Road would damage its rôle as part of the Castle Park planned landscape.
6.2 The historic environment would also be indirectly damaged by the effect on the economy of the town centre streets being primarily a conduit for through traffic, constantly full of fumes and noise, and with their commercial premises split from each other by queues of vehicles. The damage to the commercial success of the town would lead to a longer term indirect effect of reducing the demand for such premises, residential and commercial, and a fall in their maintenance funding. There is a real risk of the town centre hollowing out, in a miniature echo of the great American cities, becoming a poor quality zone in a car-based suburban sprawl.

7 Other Infrastructure
7.1 While in theory development would be conditional on it funding schools, and healthcare facilities, strong concerns remain that the funding and provision would be inadequate, and that there would be risks to water supply, sewage and drainage.

8 Alternatives to this Plan and Development Strategy
8.1 Lower housing numbers which meet local needs, especially for affordable housing, instead of encouraging in-migration; the gradual release of land for development as demand grows; giving absolute priority to using brownfield and infill sites; building homes close to jobs and not mainly within 20% of Warwick District ... many options exist but have not been given proper consideration in the preparation of the RDS.
8.2 Absolute priority should be given to brownfield sites, with greenfield sites only being allocated when there is a proven immediate need. This will ensure that more brownfield sites become available, their value increased by the non-availability of easy, profitable alternatives for the mass housebuilders.
8.3 While a year ago the IBM/Opus 40 site on the north-west edge of Warwick was to be used for office development, it is now likely to be proposed for housing. It provides a good example of the way in which long-term plans are by their nature crude, and that housing sites can be found on brownfield sites well-connected to the transport network.

9 Conclusion
9.1 In objecting on these strong and numerous grounds to the Revised Development Strategy, the Society offers its assistance to the Council in the necessary task of devising a better alternative, with the full involvement of a wide range of residents and business interests.
1.1 In its document Local Plan Preferred Options, May 2012, at para 3.3, the Council invites the views of all interested parties to help shape a draft Local Plan.
1.2 Here are the views of The Warwick Society. They refer to the Full Version of the Preferred Options and in some cases to some of the supporting documents made available on the Council's website. The Response Form, which we have not found effective for structuring our comments, uses the words 'support or object' rather than the Preferred Options' 'the Council is keen to hear the views'. While we have phrased our comments as views, it will be clear that many would be objections to firmer proposals, and will become formal objections if the next stage of the plan-making process does not respond satisfactorily to them.
1.3 The Warwick Society, the town's civic society, was founded in 1951, and has as its first aim to conserve, for the benefit of the public, or to encourage the conservation of, the natural, artistic and cultural amenities of Warwick and its neighbourhood. It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people.
1.4 Warwick is no stranger to development. The mediæval town was largely destroyed by fire in 1694, though many timber-framed buildings at its fringes survived. Rebuilding followed a plan to widen the streets and to improve fire-resistance with stone and brick walls. It took place at the start of the Georgian era. So the High Street, the Cross, Church Street, St Mary's Church and Northgate Street form an elegant and coherent architectural ensemble. It is the juxtaposition of the mediæval with the Georgian which makes Warwick distinctive. More recently, C19 industrial development based on the canal and then the railway has been followed by more extensive C20 sprawl based on the car and the road network. In the decade 2001-2011, the population of Warwick grew from 23,000 to 30,000, a rate of increase of 30%, among the very fastest rates of any town in the UK. Assimilating this growth and building new communities takes a generation.
1.5 The new Local Plan gives a new opportunity to make the town, and the district around it, a finer place, and a better place to live, be educated, and to work in. Its population may grow, because it is attractive, and well-located at the south-eastern corner of the West Midlands. Its future residents, and those who work here or visit, need a vision which ensures that it continues to be attractive, and to function well.
1.6 This means:
1 Developing the local economy sustainably, both facilitating growth in jobs and income and reducing the impact of climate change;
2 A pattern of development which reduces dependence on the car, congestion and pollution;
3 Transport and social infrastructure which enables people to live sustainably and economically;
4 Walking routes, cycle routes, schools, health centres and shops which allow people of all ages and capabilities easy and healthy access to them;
5 A mix of housing which meets local needs, especially affordable housing for families;
6 A rate of development which allows the towns and their communities to absorb change and make each a socially and personally contenting place to be; and
7 Protecting the natural and historic environment, especially the green hinterland of towns, green spaces within them, and the historic buildings which make them special places.
1.7 The Preferred Options fail by a long way to achieve this. The Issues [para 4.8] identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.8 In the following sections, we consider the three main ways in which the preferred options fail to meet the expectation of those who live in the District, and suggest changes which, if introduced to the draft Local Plan, could make it a very much better direction for the District to follow.

2 Population Growth and the Demand for Housing
2.1 The Preferred Options' emphasis on growth in jobs and housing, each matching the other [para 4.10], is founded on a circular argument and on mere assumptions.
2.2 The Strategic Housing Market Assessment [para 5.13] 'projects' (not forecasts) future growth in the District's population. It explains [SHMA figs 2.13 and A2.4] that 'in-migration' has been much the most important cause of population growth in the fifteen years 1996-2010. Of a total population increase of 18.9k (from 119.8k to 138.7k), 16.5k has been net in-migration, and only 2.4k the natural change. The report notes [para 2.33] that 'past migration trends will have been influenced in part by past levels of housing delivery.'
2.3 The SHMA assumes the average rate of in-migration of the last five of those fifteen years, 2006-2010, and projects it for the next twenty. There is no quantified analysis of the causes of the in-migration, nor any quantified forecast of its future level. It is simply an assumption.
2.4 The SHMA goes on to assume an age profile for the in-migrants, again basing its projection on neither evidence nor analysis, but on assumptions, in this case those of the ONS [SHMA para 2.17]. The projection of net in-migration is the difference between two much larger numbers, gross in-migration and gross out-migration, and the in-migration figure is produced only by adding that assumed net projection to the ONS assumption of out-migration. The projection is not a forecast, just an arithmetical exercise, and its predicted growth in population is no more solid than the assumptions and extrapolations on which it is based.
2.5 The extrapolations have as their base the after-effect of rapid housebuilding in the years before the market collapsed in 2008. All that they show - as described at the end of para 2.2 above - is that if houses are built, people will move into them; in a second circularity, if the mass housebuilders do not believe that their output will be sold, they build little. A third circular argument then enters the Plan as it stands: if the population rises, employment will rise, as those who buy and occupy the new houses are very likely to have jobs - without which they do not have the means to buy the houses.
2.6 We conclude that the preferred level of 'growth' is simply a bid for growth, rather than a forecast for which there is either evidence or action plan, other than almost free-for-all development with all of the negative impacts on existing residents and the environment that that will bring. The alternatives of more modest levels of growth, in both housing and employment, with much lower damaging impacts, would be equally valid for the Council to choose. We urge that it should reconsider its preference in the light of the absence of evidence in support of it, and take a broader view of both growth and all its consequences.

3 Infrastructure
3.1 The infrastructure proposals do not provide for sustainable development. The modelling of the existing network against possible locations for development consists only of modelling vehicle flows. It does not reflect the national polices and Local Transport Plan which require priority to be given to reducing the demand for transport, and to walking cycling, and public transport.
3.2 Except for the possibility of Kenilworth station (which would have a negligible impact on demand for road use in the peaks) all of the significant infrastructure proposals are for increases in the road network. They have been selected to deal with some of the local congestion created by increase in demand of the various housing site options. They do not provide a coherent transport network for Leamington, Warwick and Kenilworth, rather a continuation of the existing mismatch between traffic and the capacity available to accommodate it.
3.3 Good railway services are already provided at Leamington and Warwick Parkway stations. The level of service at Warwick station is significantly inferior to that of Warwick Parkway, even though it serves a much more substantial population within walking distance. Conversely, almost all access journeys to Warwick Parkway are by car. For journeys to and from work, Birmingham and London are significant destinations and there is some commuting in to Warwick and Leamington which is badly served by Warwick Parkway. The basis of a sustainable infrastructure plan should be to improve train services at all three of these stations, and especially at Warwick station, and to concentrate development close to them, minimising car use. This possibility does not appear to have been considered.
3.4 The conclusion of the modelling is that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, in particular to meet the Air Quality Management Area requirement to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings all require that the legal requirement to restore air quality should be given absolute priority.
3.5 Instead, the infrastructure plan proposes spending almost all of the potential developers' funding contributions on major expansion and 'improvement' of the road network. The lesson was learned decades ago that changes of this kind, increasing capacity on some congested sections, simply increases congestion on adjacent parts of the network, through the traffic that the improvements generate.
3.6 We are disappointed and concerned that the preferred options do almost nothing to allow transport demand to be met more sustainably, rather simply try to accommodate it at the expense of the environment and of existing residents and road users. We consider that the whole emphasis of the plan should be above all on sustainability of transport, not just for its environmental impact but also because the prosperity of residents of the district depends on accessibility to services without having to meet the increasing costs of car use.

4 Locations for Development
4.1 Much of the criticism of the Preferred Options has been directed towards the allocation of particular areas of greenfield land at the fringes of the urban area on which large-scale house building is proposed. These sites represent a major misdirection of development. We consider that, rather than the strategy of the Preferred Options, the pattern of development in the district should be dramatically different.
4.2 The total level of development should be substantially lower, of the order of 250 dwellings per annum, Option 1, which is sufficient to meet local needs and not to encourage in-migration.
4.3 Unbuilt existing permissions themselves provide nearly five years' supply to meet this level of requirement.
4.4 Beyond these absolute priority should be given to brownfield sites, as provided for by the NPPF. The Preferred Options propose only that brownfield sites should be used at the end of the plan period, the effect of which would be to consume greenfield sites rather than to bring forward brownfield sites by increasing their value. Some brownfield sites may provide for small numbers of dwellings, but these should not be dismissed: there are potentially many of them.
4.5 Brownfield development should include the intensification of existing development within the urban areas. We do not rule out 'garden development', which can often be in locations close to existing facilities and employment and easily served sustainably. There are extensive areas of development carried out mainly in the second half of the twentieth century where more intensive use of existing housing and employment land would be entirely feasible - were the market signals to encourage it. The proposals for much more intensive office use of the IBM/Opus 40 site on the north-west edge of Warwick go too far in this direction, but demonstrate that intensifying development on a site well connected to the transport network can be attractive to developers.
4.6 Only as a last resort should greenfield land be allocated. The suggestion that it can produce high-quality environments by applying the principles of the garden cities is spurious. The garden cities were planned around local employment and services (in the era before the car, competing supermarkets, choice of school admissions, and two-income households became the societal norm): that is not how we live now. All of the greenfield sites at the urban fringe would be largely car-dependent. As well as their damaging impact on infrastructure and on existing settlements, they would not produce stable, happy communities of their own. The rapid growth in population of Warwick in the last decade requires a period of much gentler growth while the new communities gel.
4.7 The allocation of land south-east of Warwick between the Banbury Road and Europa Way does exactly what the Preferred Options say that they wish to avoid, merging the built-up areas to their east and west. The northern part, north of Gallows Hill, would make Warwick, Leamington and Whitnash into a continuous, sprawling urban area. The southern part, between Europa Way and the Banbury Road would extend this sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would have a directly damaging effect on Castle Park, Grade 1 registered landscape.
4.8 The Green Belt was established to end the outward sprawl of the major conurbations. Circumstances change and there may be exceptional reasons for declassifying Green Belt land: the expansion of Warwick University may be a virtuous case of this. But it is essential that its edges should not be eaten into by extending urban sprawl, for example at Loes Farm and north of Leamington, in the opposite direction from that which it was originally intended to prevent. Similarly, when the Green Belt was designated land south of Warwick and Leamington was not seen as threatened by sprawl from the conurbation simply because the towns stood in the way. Now, that land requires the same level of protection as the post-war Green Belt gave to the edge of the Birmingham and Coventry built-up areas.
4.9 Instead, the Green Belt has become the guarantor of favourable surroundings for the few residents in and outside villages scattered across it. Given the severe damage to the existing urban areas that would follow from their outward extension, an entirely different approach is required to find acceptable greenfield sites. The possible 'Gateway' development around Coventry Airport is an example of this approach: it must concentrate employment and housing close to good transport links without creating undue pressure on the existing urban areas. Planned new or enlarged settlements outside Warwick, Leamington and Kenilworth, and in some cases outside the district - delivered through cooperation with neighbouring authorities - should also be preferred. The substantial employment at Gaydon is not matched by housing provision in the locality, rather met by car-borne commuting to it. Warwick Parkway station and the nearby A46 provide an opportunity not for an urban extension but for a new settlement outside the existing urban boundary, which would not damage what lies within it. Hatton and Lapworth, with existing railway stations, could also be the focus of much more extensive development than is proposed.

5 Conclusion
5.1 We have concentrated on the three main ways in which the preferred options would both worsen the quality of life of the district's residents and damage the historic environment.
5.2 In the copious supporting documentation, there are many more details of the proposed policies which we cannot support.
5.3 But we have limited our comments to these three main issues to try to persuade the Council that the eventual draft Local Plan must be very different from the Preferred Options now proposed.
5.4 We urge the Council to reconsider its preferences and to recognise its long-term responsibility to both the environment and the quality of life of Warwick district.

see attached

The proposed site allocations for the new Local Plan result in an overall imperative to ensure that policing infrastructure expands proportionally with the delivery of new development growth, in order to ensure the continued delivery of policing services to a significantly growing population. Warwickshire Police expresses no preference amongst the growth options presented, but there are a number of observations to make about the new Local Plan that will be vital to helping us work in partnership with the Council and applicants to deliver required policing services into the future.

Observations
Strategic Vision: This currently makes no reference at all to the need to ensure safe, secure and low crime communities and places are created and maintained in Warwick District. This is at odds with paragraphs 58 and 69 of the National Planning Policy Framework (NPPF) and the Council's forthcoming Sustainable Community Strategy, described at paragraph 3.6 of the Local Plan. Unless this is addressed, support for the infrastructure and design measures necessary to create and sustain such places and communities is critically undermined.

Section 3 makes a number of references to the importance of sustainability. Low crime & disorder is vital aspect of sustainability, as stated above, which must be included in any definition or statement regarding this term.

Revised Development Strategy: Please see the enclosed representations, prepared by consultants Boughton Butler LLP, regarding this topic.

Strategic Development Sites and Infrastructure: All of the strategic development sites detailed in the Local Plan will require the proportional growth of police infrastructures to maintain equivalent levels of service in the areas concerned. However, the police service does not receive funding to cater for the infrastructure needs and associated costs that come with the delivery of development and associated population growth. This is because with population growth there is a corresponding increase in crime and the number of incidents requiring a police response. This places demands not just on the 'front line', but on the whole spectrum of support and specialist police services, e.g. forensics, roads policing or armed response team to name but a small number, that will be called upon during the lifetime of a development.

Further, policing is a countywide, regional and national service and it is not practical or sustainable to develop an infrastructure on a piecemeal basis. The recognition (such as in paragraph 5.1.14) that cumulative impacts must be planned for at the strategic level is vital to achieving the most effective infrastructure, both for individual agencies and for joint agency partnership working and shared services is consequently a very welcome inclusion and represents a big step forward in the provision of cohesive public service infrastructure, including policing.

We therefore request that the Local Plan includes specific policy recognition of the need for additional police infrastructures in relation to strategic and other development sites. We intend to provide details on the precise infrastructure required as work on the Council's Infrastructure Delivery Plan progresses over the course of this year.

Secured by Design - Strategic Development Sites and Infrastructures - Housing Mix: The Lifetime Homes standards include safety in terms of both traffic and crime. It should therefore be a requirement that all homes should be designed and built to the Association of Chief Police Officers (ACPO) Secured By Design accredited standard. Also, achieving the best possible traffic safety of any new roads development should involve consultation with the Warwickshire Police Road Safety Unit.

5.1.27: Highlights the potential for 12,300 new homes in Warwick District. This represents an increase of approximately 23% increase in the District and approximately 5.4% increase in Warwickshire as a whole. It is logical to conclude that this will lead to a proportional increase in demand to policing services. This is in addition to significant housing growth elsewhere in the Warwickshire policing area. Accordingly, the Warwickshire Police infrastructure will require expansion in response to the planned housing and other development growth in Warwick District.

Whilst this will not, in most cases, lead to the visible structures of new police stations, there remains a fundamental requirement to provision expanded infrastructure capability in policing through mobility (police vehicles), communications (radio systems and IT infrastructure), support functions (crime recording, strategic planning, judicial services, HR, Finance, Fleet Management, Estates and others). Wherever possible these will be developed in partnership with other agencies, and should be a core component of CIL planning.

Map 4: Whitnash and south of Sydenham: There is a potential need for a neighbourhood policing base within the housing developments proposed for the South of Warwickshire & Witnash. Ideally this will be a shared facility operated in partnership with other public service agencies.

Conclusion
The Warwick District Local Plan Revised Development Strategy presents police infrastructure and Secured by Design considerations that need to be addressed. The significant growth in housing, employment and population also requires continued engagement between the Council and Warwickshire Police in infrastructure planning and CIL scheduling to ensure proportional provision of flexible police infrastructure into the future.

I am writing to express my horror at the new draft Local Plan and the threat it poses to the local area. This plan flys in the face of concerns expressed during the 2012 Local Preferred Options consultation and goes against the professed "Vision" and aims of Warwick District Council. If the Council goes ahead with this it is ignoring its own promises to local residents and the opinions of the local people whose taxes are funding the Council.

The new plan involves an excessive number of new houses concentrated in a small rural area, replacing agricultural land with an urban sprawl. Calling the development a "Garden suburb" will not change the fact that we are talking about thousands of houses on greenfield land. This many houses are NOT needed and certainly not in one place. The local need is for fewer than 6000 new houses by around 2030. This proposal is for more than double that, with 4500 of them south of Warwick. This is larger than the village I live in, which has grown gradually over hundreds of years. Building such a volume of housing all at once, in one area is reckless and unnecessary.

The Council states in its plan that it wishes to "Avoid development in locations which could potentially lead to the coalescence of settlements". Leaving a small section of land around the Tach Brook as the only space between a new sprawl of housing connecting to Warwick Gates, to Whitnash, to Leamington and Warwick is an insulting token gesture and does not address the concerns raised by residents of the area in the Preferred Options consultation of last year. Describing this land as a "Naturalistic open space/ buffer" says it all. We do not want a tiny strip of "Naturalistic" land, we want the natural landscape and agricultural land that is there now. To insinuate that this buffer will mitigate all the problems is at worst blatantly dishonest and at best woefully ignorant and naïve.

This volume of housing will cause an unbelievable increase in traffic and congestion through the area. We have already seen the effects of the Warwick Gates estate on traffic through the village and en route to Leamington and Warwick. This would increase pollution, road traffic accidents and make journey-times much longer. If new schools are added to the mix, traffic problems would be exacerbated further - it is already that case that traffic is about 10 times worse during term time than during school holidays.

The Council also states that it wishes to "Develop sustainable communities". How about protecting exisiting communities? As was shown in the recent consultation on parish boundaries, Bishop's Tachbrook is a strong and thriving independent community with a great history - again, this is being threatened by the plan to build thousands of new houses and practically link us up with the urban area that is Warwick Gates/ Whitnash / Leamington.

What the council is talking about is replacing agricultural and natural landscapes with a vast amount of housing, then as an afterthought, adding in so called "Community spaces" and "Country parks" - some kind of 'fake natural landscape' to ease developers consciences. This does not undo the damage wreaked on the landscape and wildlife. If the Council really cares about preserving the local area and making "Warwick District a Great Place to Live, Work and Visit", it should protect and celebrate its beautiful local landscape, not turn it over to the highest bidder to bulldoze. In building such a large number of houses in one area, you would also effectively be getting rid of any incentive on the part of potential new residents to live here. No one wants to live in a massive estate where roads are congested and overcrowded and local towns full of pollution. People come here BECAUSE of the countryside and relative quiet. Warwickshire is known for its agriculture and landscape and has been throughout history. The Council is also overlooking the impact on Warwick's historic town centre, which is already becoming highly polluted and congested. Don't forget that tourism is a key part of the local industry, being close to Shakespeare Country (I work for the Shakespeare Birthplace Trust) and having the ever-popular Warwick Castle in its midst. We should be aiming to preserve the countryside and local villages as these are part of Warwickshire's 'image/ brand". Tourists do not come here to see thousands of modern houses and villages that have been swallowed up by the growth of the urban landscape. Think how popular the Cotswolds is, with its country lanes, open fields and well-defined villages. If this plan goes ahead, I suspect many visitors will just bypass Warwick and Leamington and make do with visiting other places to avoid the traffic - after all, there won't be much left to see with all of the open fields gone and Warwick town centre reduced to a traffic island.

It is really quite illogical to build such a large number of properties in an area which is never going to be able to provide enough jobs for this many people. Anyone living on such a new development would be compelled to commute by car, when it would make more sense to build new housing on brownfield sites near existing industry. In an era when there is an increasing desire for ecological homes, minimising car journeys, cutting energy use and protecting the environment, this seems like a retrograde step.

I would therefore urge Warwick District Council to reconsider and:
1. Reduce the planned housebuilding for the District to a more reasonable level and not build for the sake of it.
2. Spread the development widely within the district - a few hundred houses at most here and there.
3. Use brownfield land rather than agricultural land and land which is a haven for wildlife.
4. Consider more suitable sites for housing e.g. near workplaces/ cities.
5. Work to reduce traffic, congestion and pollution within the area, rather than increase it.
6. Celebrate and protect our historic and beautiful landscape and make it more appealing to visitors, residents and potential new residents.
7. Stay true to its professed vision and mission and listen to the opinions of EXISTING taxpayers (I for one would not like to stay here if this plan goes ahead).

Everyone can see that this proposed development is completely out of proportion with what is sensible and what is required. This is too many houses, in the wrong places, without thought for the consequences. It is not too late for the Council to do something about this and save our local area and stand up for local people.

see attached

see attached

I feel it necessary to write to you in the strongest possible way concerning the proposals for the development to the south of Warwick especially the area bounded by Myton Road and Europa Way. This land owned by the Oken Trust and King Henry VIII Trust was an area of restraint. Why has this now changed and for that matter who had the right to change it? The proposed desecration of the land is unforgiveable for many reasons which I would like to outline.

The first point to highlight is the vastly extravagant estimate of new homes needed. The projected number far exceeds the reality. Also the fact that the numbers have been quoted up to the year 2029. How can you forecast that far ahead with any accuracy. If we are talking government figures I think we all know what past mistakes have been made through cavalier ministers' ideas and the fiascos which resulted.

Secondly the air quality, which even now is at danger level, would be made even worse by the number of extra cars resulting from all the new inhabitants into the area. This brings me to the third point which is the road network which is barely adequate at present. From my experience Myton Road is virtually at a standstill during the morning and evening rush hours. Even if extra capacity on incoming routes was to be provided, the traffic would still need to cross Castle bridge, Portobello bridge and other roads which is unfeasible. The phrase 'A quart fitting into a pint pot' comes to mind.

The ratio of homes to employment at present, whilst not perfect, is nevertheless manageable. The proposals suggest creating employment to match the need for extra housing. How?

All infrastructure would be affected. Schools, health, water and drainage which all at the present time are stretched would be pushed to breaking point. The land alongside the cycleway off Myton Road is already prone to flooding. Building on this land would exacerbate the problem.

Warwick is a beautiful market town. It is not a city and its residents do not want it to become one huge urban sprawl. This is the reason we choose to live here and for many of us this has been for a long period of time. The suggested area south of Myton Road and bounded by Europa Way is a necessary buffer to keep Warwick as a separate entity. It is good farmland with copious wildlife. Do not destroy it for some Political and Developers Charter.

This is an ill-conceived plan and it has disastrous consequences for everyone. It cannot happen. We as residents deserve our say and we deserve better.

I object to numerous elements of the WDC Local Plan. I am not a planner and therefore it has taken considerable time and effort for me to draw together a reasoned response - time that many families simply do not have.

In the public meetings I have attended throughout the Consultation I have been astounded at the insistence of Council officers that the Local Plan in its current form is going ahead irrespective of the public response. What kind of Consultation is that?

I have also yet to hear a solid reason why the greenbelt land north of the river, earmarked in the first draft, is no longer being considered. Limited release of this land would create a more balanced and sustainable urban area.

I understand that fairness is not a planning concern. But the concentration of such a high proportion of the proposed new housing south of the river is completely unacceptable. Aside from the coalescence of settlements this will cause, the strain on local infrastructure, the nightmare traffic and corresponding reduction in quality of life for existing residents, it will impact upon Leamington Town Centre, which will cease to be just that, a centre. If the proposed new levels of housing are built south of the river, this will skew the demographic across the District, the Town Centre will become increasingly irrelevant as new residents access retail outlets and supermarkets located south of the river. At a time when Town Centre retailers across the country are struggling, I am shocked at the District Council's blatant disregard for the local economy and their willingness to plan the decline of Leamington Town Centre.

I would like to object specifically to the following areas of the Local Plan:

Level Of Growth
I am not convinced that WDC's required number of houses is based on sound analysis. Recent projections by respected local planners suggest that the District Council has over estimated the need. I am concerned this has been done for expediency, to ensure the Local Plan is passed upon eventual government Examination. Also, I am not convinced that WDC has effectively exercised its Duty to Co-operate with Coventry in cross-boundary housing provision.

Location of Growth
The Local Plan should make more Green belt releases to the north of Leamington. As mentioned above, a spatial rebalancing of the urban form is required away from the southern edge of Whitnash/Warwick/Leamington. This surely would be sound planning practice, creating a more rounded urban area, enabling greater accessibility for the Town Centres (Leamington and Warwick) with them forming two central hubs. If the proposed developments to the south take place, Leamington Town centre will no longer be 'central' to the District's urban area.

Myton Garden Suburb
The proposed development here will result in a coalescence of Warwick, Whitnash and Leamington. Additional traffic on Europa Way and north under the railway would pose serious concerns.

South of Gallows Hill
This area of land is highly visible and covering it with houses would impact on the backdrop of Warwick castle, damaging the local tourism industry upon which numerous businesses in the local area rely. In planning terms it is not a logical extension of an existing urban form, but instead would create a peninsula of development to the south.

Whitnash East
In the immediate vicinity of this site there are areas of historical and conservational interest which must be preserved. I am doubtful that the cost of relocating Campion School in order to gain access to this site can be justified by the number of new houses proposed.

Warwick Gates Employment Land
I am concerned at proposals that this land be reallocated for housing when there is no other land in the urban area that offers this amount of high quality land area for employment in such an accessible location. Why is the proposed housing density in this area so low?

Woodside Farm
Access to the development is a major concern. A single access point would isolate the development from the existing community and create such a volume of traffic that it would be simply unsustainable. How can the significant cost of highway improvements to provide two access points be justified even if physically possible? The proximity of Ashford Road and Harbury Lane junctions surely precludes access via Tachbrook Road and access via Landor Road is precluded by the current road alignment and lack of vehicle capacity. Our local road infrastructure simply could not cope with the numbers of new cars this development would bring. Increased air pollution and traffic noise are real concerns, alongside the danger posed to pedestrians (particularly children) of residents from the new development using Othello Avenue as a cut through to access local shops. The National Planning Policy Framework clearly states that development will not be permitted where it generates significant road traffic movements unless mitigation measures are used to avoid adverse impacts. I do not see any convincing evidence that mitigation measures will be adequate enough in this instance.

The visual impact of this dense development, 83m above sea level compared with 65-68m for established housing in the area, would be unacceptable, making it highly prominent in the local landscape. Furthermore the fact that some houses will be up to three storeys high raises significant concerns of privacy for existing dwellings. Attempts to mitigate this issue using trees for shielding will likely bring problems with shading and access to natural light.

The area proposed for development has steep inclines, as steep as a rise of 5m in 40 (1 in 8). Flooding from the fields is already a concern for those houses that back on to the Woodside Farm area. Given the density of the proposed housing, I am very concerned about the effect of considerable new water run off from hard surfaces in a new development, and the potential flood risk this would pose to existing housing backing on to it.

Woodside Farm is Grade 2 agricultural land. With growing population rates and domestic food production demand rising, it is fundamentally unacceptable to build on land of this quality when brown field sites are available.

Fieldgate Lane/Golf Lane
How is this site going to be accessed? The junctions at Coppice Road/Morris Drive and Whitnash Road/Golf Lane do not have the capacity to cope with the additional traffic these developments would bring, particularly at peak periods.

We have been advised to write to you regarding objections to the Revised Development Strategy Local Plan. Having studied documentation and attended meetings I wish to object to the overall plan to build the number of new homes suggested in Warwick district and in particular the 3420 planned in the south of Warwick (zone 6).

The whole basis for the homes is population growth nationally. The amount of employment land within the plan would not fulfil the amount of local unemployment and create enough for the amount of housing proposed. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people.

Warwick District has already seen much development over recent years, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

I have lived in Warwick most of my life and still live at home with my parents. I would like to continue to be able to live in the area with my own family in the future and for my children to have green fields around them and affordable homes, not to be surrounded by and urban sprawl of commuters.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands.

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion being at Warwick Gates which is in South Warwick where the majority of further development is now proposed.

By only building the amount of houses currently required for Warwick district this will discourage migration from other areas as has happened with past developments.

As it stands, I wish to object specifically about the development zone 6 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an


untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry, including up to 14,000 new jobs speculated at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick.

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times.

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road. The alterations made to the roundabout with the addition of Morrisons has made some current improvement but will not be able to handle the extra traffic created by the number of dwellings proposed for zone 6.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 2-3000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way, the area of restraint, is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc.

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

I ask, is developing the ASR a sustainable development? "Much rubbish is talked about sustainability, usually by developers. It does not mean that estates are built near to a bus stop or a primary school or a doctor's surgery; this is just moderately intelligent planning. To get to the correct definition it is necessary to go back to the source of the concept of sustainability which was the United Nations commission chaired by the Norwegian Prime Minister Gro Harlem Brundtland in the 1980s. This said that sustainable development is that which meets the needs of the present without compromising the

ability of future generations to meet their own needs; in more simple terms it means that we should not destroy something which future generations would find valuable." (www.stortfordcf.org.uk)

Surely if all this land is built on to the south there will be nowhere that the future generations can use in Warwick for recreation other than St Nicholas Park. If the land was made into recreational use, as it was designated to be, that would serve not only our generation but those of the future too.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road.

The most disturbing consequence of the proposed development of zone 6 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remained in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf and particularly page 17:

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape, geology, cultural heritage and material assets must be thoroughly assessed, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. All assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

It was pointed out at a public meeting in 2009 that part of this area may not be needed for development in the future but we learnt at the recent Warwick Forum that 2,000 homes planned for Milverton had been transferred to zone 6, the worst area for infrastructural needs and more importantly the area of restraint.

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the proposed site at zone 6.

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses, many having been 3 form entry 30 years ago now down to 1 form


entry, whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton into whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

Warwick hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run.

Stratford District have now put this area forward as part of their Local Plan. Can District Councils not communicate with each other? To have this large area developed as well as the south of Warwick District will create even more stress on the road structure towards Warwick.

There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Local Plan?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. I know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and reclaim the hundreds of dwellings (including Station House, Union Court, Chapel Cross and The George) in the South Town of Leamington to private affordable starter flats, homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.

Warwick District Council's original Strategy to 2026 stated that 90% of the population live in the urban areas and 10% in rural areas. The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.



According to http://warwickdc.jdi-consult.net/ldf/readdoc.php?docid=15&chapter=4 the Preferred Vision for Warwick District to 2026 will be

"Warwick District in 2026 will be renowned for being:
1. 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, contributed towards creating high quality safe environments with

low levels of waste and pollution, and made a meaningful contribution to addressing the causes and potential impacts of climate change;"

If this building work is allowed to go ahead as it stands, it will be far from that.

The Core Strategy also pointed out that the development should be directed towards the south of the urban area and this has been carried forward into the Local Plan apparently to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry. What this is in fact doing is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

If Green Belt land was taken to the north of Leamington and south of Kenilworth, to the east and west, to build the bulk of the houses required for Warwick District and included a supermarket for the residents of north Leamington, Lillington and Cubbington this would alleviate the need for them to travel to the south of Leamington or Warwick to shop and would not cause incursion into the West Midlands and Coventry or encroach on the current residents of those areas.

This Green Belt land could then be reclaimed to the south of Warwick and Whitnash and residents of the new dwellings would be a more central position for employment in Warwick, Leamington, Kenilworth and Coventry.

I urge Warwick District Council to revise the whole plan taking into consideration the views of the residents of Warwick, not allowing any further planning applications to be passed on land within the Local Plan until it is fully agreed and finally to consider the overwhelming number of objections received from Warwick residents at previous consultations.

We have been advised to write to you regarding objections to the Revised Development Strategy Local Plan. Having studied documentation and attended meetings I wish to object to the overall plan to build the number of new homes suggested in Warwick district and in particular the 3420 planned in the south of Warwick (zone 6).

The whole basis for the homes is population growth nationally. The amount of employment land within the plan would not fulfil the amount of local unemployment and create enough for the amount of housing proposed. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people.

Warwick District has already seen much development over recent years, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

I have lived in Warwick most of my life and still live at home with my parents. I would like to continue to be able to live in the area with my own family in the future and for my children to have green fields around them and affordable homes, not to be surrounded by and urban sprawl of commuters.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands.

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion being at Warwick Gates which is in South Warwick where the majority of further development is now proposed.

By only building the amount of houses currently required for Warwick district this will discourage migration from other areas as has happened with past developments.

As it stands, I wish to object specifically about the development zone 6 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an


untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry, including up to 14,000 new jobs speculated at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick.

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times.

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road. The alterations made to the roundabout with the addition of Morrisons has made some current improvement but will not be able to handle the extra traffic created by the number of dwellings proposed for zone 6.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 2-3000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way, the area of restraint, is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc.

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

I ask, is developing the ASR a sustainable development? "Much rubbish is talked about sustainability, usually by developers. It does not mean that estates are built near to a bus stop or a primary school or a doctor's surgery; this is just moderately intelligent planning. To get to the correct definition it is necessary to go back to the source of the concept of sustainability which was the United Nations commission chaired by the Norwegian Prime Minister Gro Harlem Brundtland in the 1980s. This said that sustainable development is that which meets the needs of the present without compromising the

ability of future generations to meet their own needs; in more simple terms it means that we should not destroy something which future generations would find valuable." (www.stortfordcf.org.uk)

Surely if all this land is built on to the south there will be nowhere that the future generations can use in Warwick for recreation other than St Nicholas Park. If the land was made into recreational use, as it was designated to be, that would serve not only our generation but those of the future too.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road.

The most disturbing consequence of the proposed development of zone 6 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remained in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf and particularly page 17:

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape, geology, cultural heritage and material assets must be thoroughly assessed, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. All assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

It was pointed out at a public meeting in 2009 that part of this area may not be needed for development in the future but we learnt at the recent Warwick Forum that 2,000 homes planned for Milverton had been transferred to zone 6, the worst area for infrastructural needs and more importantly the area of restraint.

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the proposed site at zone 6.

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses, many having been 3 form entry 30 years ago now down to 1 form


entry, whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton into whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

Warwick hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run.

Stratford District have now put this area forward as part of their Local Plan. Can District Councils not communicate with each other? To have this large area developed as well as the south of Warwick District will create even more stress on the road structure towards Warwick.

There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Local Plan?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. I know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and reclaim the hundreds of dwellings (including Station House, Union Court, Chapel Cross and The George) in the South Town of Leamington to private affordable starter flats, homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.

Warwick District Council's original Strategy to 2026 stated that 90% of the population live in the urban areas and 10% in rural areas. The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.



According to http://warwickdc.jdi-consult.net/ldf/readdoc.php?docid=15&chapter=4 the Preferred Vision for Warwick District to 2026 will be

"Warwick District in 2026 will be renowned for being:
1. 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, contributed towards creating high quality safe environments with

low levels of waste and pollution, and made a meaningful contribution to addressing the causes and potential impacts of climate change;"

If this building work is allowed to go ahead as it stands, it will be far from that.

The Core Strategy also pointed out that the development should be directed towards the south of the urban area and this has been carried forward into the Local Plan apparently to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry. What this is in fact doing is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

If Green Belt land was taken to the north of Leamington and south of Kenilworth, to the east and west, to build the bulk of the houses required for Warwick District and included a supermarket for the residents of north Leamington, Lillington and Cubbington this would alleviate the need for them to travel to the south of Leamington or Warwick to shop and would not cause incursion into the West Midlands and Coventry or encroach on the current residents of those areas.

This Green Belt land could then be reclaimed to the south of Warwick and Whitnash and residents of the new dwellings would be a more central position for employment in Warwick, Leamington, Kenilworth and Coventry.

I urge Warwick District Council to revise the whole plan taking into consideration the views of the residents of Warwick, not allowing any further planning applications to be passed on land within the Local Plan until it is fully agreed and finally to consider the overwhelming number of objections received from Warwick residents at previous consultations.