5.6 District Wide Transport Mitigation Proposals

I wish to respond to some of the points outlined in the Local Plan:

3.4 Do not agree: has the Avon Bridge been assessed for increase in traffic? Solution: commission report asap. Installation of additional traffic lights not enhancing the aspect in this conservation area.
Solution: decrease in traffic required.

3.5 Do not agree: concentration of 4,500 houses in one area ie to south of Warwick and Leamington. Solution: look for alternative sites

3.5 Meeting Housing Needs: 6,000 required by 2010 so why is WDC proposing 12,000? Solution : reduce stated number

3.6 No mention of air quality ie traffic emissions. Already an ongoing problem identified. Solution commission report to assess impact of increased traffic asap. Solution 2 - reduce number of vehicles in town centre.

3.6 Sustainability: Do not agree - the plan does not meet our current needs and therefore fails this criteria

4.3.10 It was agreed at Area Committee in January 2008 to reduce the volume of traffic in Warwick. So how will this be achieved with the inevitable increase in traffic?
Solution: there is only one way into Warwick from Banbury Road and no viable alternative. Saying that car drivers will use M40/A46 to access roads to north - what evidence do you have? I was told at exhibition "it was hoped this route is used"

5.1.29 This will result in deterioration of air quality ie standing traffic at lights and slower speeds through town.

5.6.1 Have these been tested to a sufficient level of detail?

Public Transport - I do not drive therefore I know the limitations of using buses, reduced evening services, limited on Sundays and Bank Holidays, none on 25th & 26th December. It is not realistic that
residents can rely on public transport. Solution: provide and subsidise
a comprehensive bus system to suit the needs of residents
7 days a week from 6am to 11pm including Sundays and Bank Holidays.

5.6.3 The proposed implementation of blocking the right turn from Smith Street into St Nicholas Church Street will seriously impact on visitors, customers, traders and residents. How is it proposed that drivers wishing to access roads to the south ie Banbury Road or Stratford Road do so efficiently? Solution remove this idea from the proposal.

5.6.5 The introduction of possibly 2 lanes and reduced parking in St Nicholas Church Street is detrimental to this historic road and its residents. It does not seek to reduce traffic, will impact on the poor air quality identified both at St John s and St Nicholas Church Street.
In addition visitors to St Nicholas Church will not be able to access a right turn from their church onto Banbury Road. A crossing across Castle Hill for tourists and residents has been identified as a requirement for safety, how will this be accommodated?

At an exhibition of the Local Plan I was informed that the Plan was rushed through and therefore not passed through the "Plain English" route. I also feel the amount of documentation and short time scale imposed is difficult for respondents to reply to.

My greatest concern is air quality especially in light of two reports recently published in national newspapers concerning traffic emissions.
The Council has a responsibility to ensure that a reduction in pollution is carried out as a matter of urgency.

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.

General: We submit our comments on the above with heavy hearts and pessimism that no account will be taken of the points that are made by a very concerned community, who believe our chosen way of life in this lovely Warwickshire area will be destroyed.

Estimated Needs: I question the need for 12,000 new homes in the WDC area. The proposed concentration of 4,5000 homes (1/3 of the total) south of Warwick/Leamington amounts to destroying the green belt - an attractive rural area of the County. This will create an urban sprawl and almost join up Whitnash, Bishop's Tachbrook with Warwick and Leamington. A distribution of houses among all the villages/towns would be fairer and more pleasant for everyone. Is account taken in the draft plant of proposed developments of 1,400 new homes south of Leamington? More use of brownfield sites, such as Ramsay Rd derelict industrial area in Leamington, would be an ideal site for attractive development; bordering on Sydenham estate it would benefit from the existing facilities. It is currently a disgraceful tangle of empty units and overgrown environs. I understand that new homes are proposed for newcomers from cities and towns. Will the idyllic prospect of a rural life be less attractive when it is no longer rural or attractive.

Warwick and the Castle are the jewels in the crown of the area. Motoring to the Castle from M40, J 13 or 14 presents an outstanding journey past an agricultural landscape; this will be destroyed by a development of the size envisaged and detract from the Warwick experience.

Pollution: The air and noise pollution in Warwick centre itself (already at very high levels), will become a health hazard - and added to pollution from the M40 in this village area, will destroy a peaceful, attractive environment of which the District Council should be proud.

Traffic: Congestion of roads already causes severe problems, consequently we avoid going into Warwick and Leamington at peak times. To drive across the Banbury Road from this village to travel to M40 north, Warwick and Leamington, we sometimes have to journey south to join the convoy of cars from Leamington, Warwick and M40 and then find a turning area before proceeding north!

Access into Warwick and Leamington involves crossing one of the five bridges. The delays even now deter us from shopping in these towns to support local businesses, which WDC should be encouraging. Greenfield development would make residents car-dependent and would further increase the traffic flows into and out of the towns.

Provision of extra traffic-light crossroads at such junctions as Bridge End, Castle Hill, Smith Street would destroy the appearance of these unique historic areas.

Urgent attention should be given to providing a Park and Ride facility from near Greys Mallory Island/A46/M40 to Warwick and Leamington. Other towns, such as Shrewsbury, Stratford, provide successfully this useful facility to maintain the environs of their town centres.

Amenities: The impact of a substantial increase in population on the local hospital facilities and services, including car parking, is a matter of grave concern. Journey times to the hospital are erratic, dependent on traffic flows, and can lead to being late for appointments.

Schools: Some Local schools have already reached their full capacity - particularly if, like our village school, they have worked hard to produce excellent standards, Recently a new family to the village could not get their child into the local school and have to transport him by bus elsewhere, thus aggravating road congestion.

Agricultural: The destruction of good arable land into housing estates is a very worrying effect of the Plan. The country needs to encourage and develop farming to provide food for future generations.

Water Supply/Sewerage Can Severn Trent provide adequate services for such a vast development?

see attached

In general I support the policies set out in the revised strategy booklet "Local Plan Helping Shape the District".

I am pleased to set that the 2012 proposals put for extensive building in the green belt north of Warwick and Leamington have been dropped. Going ahead with it would have made a nonsense of national and local policies on green belt land.

I wish to make the following observations on particular sections of the booklet;-

Paragraphs 4.1.6 -4.1.9

This section contains a major logical flaw. Paragraph 4.1.6 argues that the District cannot achieve economic growth rates in line with national forecasts without inward migration. The following paragraphs go on to forecast how many dwellings will be required to sustain this level of economic growth. However it is impossible for every planning authority to achieve the level set out in the national forecast. Some areas will be above the average, and an approximately equal number will be below it.

The policies in paragraphs 4.1.6 to 4.1.9 appear to be based on the principle of "beggar my neighbour". Apparently Warwick District Council aims to achieve the national forecasts for economic growth by stripping other areas of their populations of working age.

Warwick District Council should be aiming to achieve for it citizens extra wealth and wellbeing per head of population. Simply importing extra people does necessarily do this. In fact it can result in the reverse through pressure that it puts on the environment and the infrastructure.

Map 6: Thickthorn

I accept that some green belt land at Kenilworth will have to be designated as a development site in order to enable the town to grow, and regard Thickthorn as the most suitable area. I also support the statements in paragraph 5.4.23 regarding the need for new employment land as part of the development.
Although there is a commitment to the provision of open space in this area, no hectares are given. Kenilworth as a whole has less publicly accessible open space per head of population than the level recommended by the WDC's SPD on Open Spaces. Provision in southern Kenilworth is particularly poor. Therefore the amount of publicly accessible open space at Thicktorn/Glasshouse lane should not only meet the needs of the new development but also address the shortfall in the south of the town. The land north of Rocky Lane would be suitable for this purpose.


Section 5.6.4

I fully support the policies regarding the Kenilworth to Leamington Spa (K2L) cycleway and the provision of a shared foot/cycleway alongside the Warwick Road between Leek Wootton and Kenilworth St Johns Gyratory.

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.

Having looked at the Local Plan and attended recent public meetings I am writing to you to indicate my many concerns and total dissatisfaction with the revised development strategy for the Local Plan.

Air Quality

In particular, the air quality issue is of great concern. I understand that air quality in Warwick and Leamington is already above the legal limit. The District Council is required to improve air quality. The scale of planned houses will make it worse. I also note that Stratford Council have their own plans for even more houses south of Warwick, has this development been taken into consideration?

Transport

I believe the strategy is car based and will push even more congestion onto the existing road network. It is obvious that building a dual carriageway to the river Avon bridge will just bring increased traffic to a halt. Also the current bridge was not built to take the potential amount of traffic. Parking in Warwick is already difficult enough, this plan will make matters far worse. As for traffic at the Morrisons roundabout on the Myton Road, I shudder to think of the implications there. The proposed removal of parking in Smith Street would adversely effect the viability of the shops in this street.

Projected Housing

The projected 12,300 homes is extremely high and I understand that less than half that number would meet local needs. Also, there are a large number of empty houses in Warwick and Leamington and these should be used to house people instead of just building more new ones.

Could we not build on brownfield and infill sites already within each towns infrastructure.

Should there not be a slower phasing in of housing based on estimated local demand releasing land as demand grows rather than an unjustified estimate so far into the future?

Historic Environment

There is no doubt that the plans will ruin the visual look of Warwick forever. The increase of traffic and people will drive visitors away. We need to conserve the beauty of Warwick, not plan to destroy it.

Parks

I understand that the new Local Plan does not have any policy to protect our parks. When this is adopted there will be no protection for our parks from developers - only National Planning Policy Framework which I believe is insufficient. This could mean that developments could go ahead on exceptional circumstances (which was the basis for the Gateway application).

Funding

With the current and projected Government cutbacks, will Warwick District Council have the funding to expand the needed infrastructure to support 12,300 homes?

National Planning Policy

From the meetings I attended it appears that a realistic forecast of need would mean that we already have the required five year supply of sites when you balance housing with employment growth forecasts vs the housing market. Why has this not been taken into consideration in the local plan?

Gypsy Sites

They seem to have all been crammed into the same area. Could they not have been spread out more fairly within the area?

Consultation Process

I was most concerned to hear at the meeting that these plans had been pushed through by councillors who do not live in the area and that politics were possibly involved in the decision making?

I would be most grateful if you would note my constructive dissatisfaction which is based on my fear that our beautiful town of Warwick will be destroyed in the future.

We wish to respond to this consultation with considerable objections to the proposed development allocations south of Warwick and Leamington.
We also wish to make it clear that, as a result of the agreement between the Garden History Society and the Association of Gardens Trusts, this should be considered as a response from the Garden History Society.
The objections relate to:
* The impact of development adjacent to the Grade I registered Warwick Castle Park (area 6 in the WDC leaflet, but area 14 in the Arup traffic document)
* The impact of traffic generated by all of the south Warwick proposed development, and of the proposed mitigation measures in the Arup traffic document as they affect both Warwick Castle Park and the historic fabric of Warwick itself.
* General observations on the justification for the proposed allocations and the economic impact. These are within our remit inasmuch as the background calculations have led to the pretty pass in which the future of the setting of Warwick's heritage now finds itself. In that respect we consider we are entitled to comment.
1. IMPACT ON WARWICK CASTLE PARK
Warwick Castle Park was initially created in 1743 to form a landscaped setting for Warwick Castle. It was developed incrementally during the time of the first Earl (Francis Greville, d1773) as the gardens were progressively extended. The park, in its form up to 1773 was much influenced by Capability Brown, brought in to advise and supervise much work from 1849 onwards.
The second Earl (1773-1816) was responsible for the extension of the park to the east, creating the present boundary, and the further extension of the gardens, closing Castle Street and creating Castle Lane adjacent to the present line of the castle wall. It might be supposed that the present line of Banbury Road was simply devised to enclose the enlarged park and particularly a greater length of the Ram/Tach Brook so that its lake could be lengthened and widened by enlarging its dam.
In fact, examination of the boundary demonstrates that it was carefully aligned to be part of the design of the park. The road rises from the viaduct which crosses Ram/Tach Brook to the ridge of Temple Hill, from which it can be seen to be aligned directly on the spire of St Nicholas's church.
The "Approach" to Warwick Castle formed part of the plans of the second Earl from as early as 1773, when he discussed them with other proponents of the "Picturesque" style, so there can be no doubt that the alignment of the road which formed the perimeter of the park was as much a part of the design of the park as the rides and walks within it.
The Castle first comes into view, in a way which was clearly planned, on the approach to Castle Bridge. The bridge had been enabled by an Act of Parliament of 1788, when the line of the road from the Asps had been completed, and was encouraged by an engineer's report to the council, that the only way to avoid the continuing maintenance problems of the old bridge was to re-locate it upstream of the castle mill. Apart from £1000 paid by the town council, whose responsibility the bridge legally was, the expense of the work was undertaken by the second Earl. It is therefore quite clear that the alignment of Banbury Road from the Asps to Castle Hill was part of the designed landscape of the park, culminating, after the bridge was completed, in the creation to the new gatehouse on Castle Hill and the present entrance drive.
The development of the eastern side of Banbury Road as a "garden suburb" would therefore be extremely detrimental to the historic landscape of the Grade I registered park.
2. IMPACT OF TRAFFIC GENERATED BY THE SOUTH WARWICK PROPOSED DEVELOPMENTS
The Arup traffic impact and mitigation study essentially demonstrates why development in this location should not take place.
This is a document of which Arup, as its authors, should be ashamed, and the County and District Councils, as its commissioners should be ashamed to have accepted. People with two degrees find it virtually impenetrable, and it is disgraceful that such an obscurely written document (and ill-proof-read, with sentences without verbs, for instance) should be offered for consultation by the public.
However, it is apparent that Arup are offering mitigation proposals for the adverse traffic impact of the proposed development, without which the impact would be even worse.
These mitigation proposals are totally barbarous and unacceptable for the environment of a county town which has main roads passing over one of the most famous viewpoints in the country, and along historic streets crammed with listed buildings.
The fact that such measures are proposed in mitigation demonstrates that the development which makes them necessary should not and cannot proceed.
The setting of not only the castle and its park, but of the whole town, is defined by the presently open areas of the proposed development and the tree-line highways of the approach roads to Warwick. In recent years this has been defiled by widening and the creation of a turning lane at Ram Brook (apparently implementing an old permission to prevent its expiry) and the new junction at Gallows Hill (apparently not needing consultation because purely highway works).
The highway works proposed by the County Council to mitigate the proposed development would have an infinitely more devastating impact on the setting of the town. The widened junctions and increased lanes would make it much more difficult to experience the famous views on foot. The view from the bridge and the entrance at the 1800 gate house would lose their impact. The open space of St Nicholas Park, protected by covenants when initially transferred to the Council, would cease to have the semi-rural character with which it was planned.
The economy of Warwick town centre depends significantly on visitors. Many businesses would fail to prosper without the addition of tourists, while others would not exist at all. It takes little effort in examining websites and twitter feeds to see that in recent years Warwick has pulled itself up by its bootstraps and made itself into a vibrant community, with a heavy reliance on "cafe culture" promoted in the previous Local Plan. But it is dependent on the ambience of the town to continue to thrive. The leisurely but quality environment on which these trends depends would be totally undermined by the level of traffic forecast in the Arup report. The so-called mitigation measures which it outlines are entirely directed at improving traffic flow, with no consideration of the impact on quality of life and the environment of the town. The beneficial results of the recent work on High Street and Jury Street in making the roads ore inviting to cross, would be lost.
It seems most probable that the proposed development would have an adverse effect on the delicately balanced economy of the town, leading to reduced maintenance of historic buildings as more of them became difficult to let.
GENERAL OBSERVATIONS
We find that the closely argued calculations of the real need for housing development in Warwick District as presented by objectors to these proposals are compelling. The District Council's calculations appear to be based on what would sell if built, rather than what is actually needed. This might appeal to the vanity of some councillors and officers, in increasing the population base of the council, but would adversely affect the attractiveness of the district and would be particularly detrimental to existing residents.
Although this might increase the Council Tax base of the District, it would undermine the viability of the town centre and old suburbs, potentially leading to neglect and loss of attraction to the town.
The proposed development is not sustainable. Firstly, there is little likelihood of people choosing to live in the new houses working locally. There is only a very small allocation of employment land, while allocations from the last and the previous local plans are still not being taken up and are being canvassed for a change in allocation from employment to housing. Other current employment land is being proposed for housing development (Such as the Eagle site) This means that the ratio of housing to employment is constantly being eroded, leading to the prospect of Warwick and Leamington becoming dormitory towns. Even if the (disputed) prospective jobs at Coventry Gateway are factored in, residents of south Warwick would have to drive around 10 miles to work there. There is a limited number of crossings of the Avon and the Leam which are already highly congested at morning and evening peaks. The existing infrastructure cannot cope without more traffic needing to make these river crossings. The situation would only be mitigated by the brutal Arup proposals, so that the ambience of the town, with higher pollution, noise and vibration would be set on a downward spiral.
We consider that the proposals for development allocations south of Warwick will be unacceptably detrimental to Castle Park and to the setting of the historic town and should be abandoned.

I wish to make comments on the proposed Local Plan, specifically the sites chosen for further housing development.

My objection is to the continued development of the areas south of the river. This area of Warwick District has already supplied much of the housing need for the District. In the last decade or so the Whitnash/South Leamington has seen substantial development; South Farm extension, Whitnash Allotments, Warwick Gates plus the industrial development and shopping provision in the area. All of these developments have put huge pressure on the existing infrastructure, and coupled with access to and from the M40, means that the area cannot take any further development. This part of the District has already taken more than its fair share of the District's new housing provision.

The development along the Tachbrook Road shows that the existing roads cannot take any increase in vehicle movement. I would say planning in Warwick District, especially in and around Leamington, is totally hampered by the constraints caused by the River Leam, the canal and the railway line. These are barriers that nobody seems to be able to address. It is difficult to get from South Leamington/Whitnash to the North of the town at peak times. It is difficult to get north/south via Warwick also. Additional development will make these moves even more difficult. Until someone can devise a way of getting over these obstacles there should be no further development south of the river.

The plans solution on dual carriageways to move traffic will not work as there will still be the bottle necks where traffic needs to cross the river, canal and railway. Whilst dualling the road out of Leamington might get traffic away more quickly, will not help ease problems for traffic coming into Leamington.

Until there is a properly integrated public transport system, that is reasonably priced, people will not use any public transport. I find it odd that you want to build on the Station Approach (I assume) car park. Where will train users park if that lane is built on? That will not encourage use of public transport. The plans for park and ride also seem totally hit or miss. There needs to be public transport, fully integrated (rail and bus), that is easily accessible for all users. Your plan does not seem to address this.

Warwick District is happy to breach the Green Belt for industrial/employment land, so why not for housing north of Leamington. It is entirely possible that the jobs created around Baginton Airport will be taken by people from the Warwick District area, or people who would want to live in the area.

I do not believe that previous decisions by the authority stand up to too much scrutiny in terms of overall planning. It is my view that the number of vehicle movements associated with the recent developments in and around Whitnash were seriously under estimated, and the impact on the local environment and community similarly under estimated. There is no room for any further development in this area.

Effect on the town of Warwick of the Revised Development Strategy

I am writing on behalf of my wife and myself to express our grave concern with regard to the Warwick District Local Plan, in response to the Consultation which closes on 29 July 2013. We have attended a number of meetings held by WDC and other interested parties over the past two years. At these meetings, virtually all present have been equally concerned by the extent to which the current Plan will have a detrimental affect on the lives of Warwick residents and will inevitably have an irreversibly damaging effect on the environment surrounding and within the historic town, causing harm to its residents, its buildings and its tourism industry. We find it inexplicable that WDC has continued to ignore the views of its residents and businesses and has persisted with what seems to be the least justifiable and most damaging of all the options available to it.

Land to the south-and south east of Warwick (Site 6)

The most serious problem with the Plan seems to be caused by the excessively high concentration of housing planned to the south-east of Warwick on what is currently agricultural land and rural 'green space'. I note that of the 12,300 homes planned in total, sites have been allocated at present for 6,630 homes, with 3,195 of these in this south-east area. Clearly this number would increase very significantly as the overall number is built up to 12,300 and the impact in Warwick of this degree of development will be compounded by that also intended by the Stratford District.

I understand that WDC has failed to identify any 'exceptional circumstances' that would enable it to build on Green Belt land to the north of Warwick and has therefore concentrated the planned development to the south-east, on this green 'Area of Restraint'. Whereas I would not advocate building on Green Belt land, the Green Belt was put in place to prevent urban sprawl from the West Midlands encroaching into the area and not because of Warwick's own potential plans. The Area of Restraint to the south is therefore equally important to the protection of Warwick's rural setting, and should be afforded the same level of protection as the Green Belt.

Projected housing need

There is no rational reason for planning so high a number of new homes as 12,300 at the present time. I understand that the actual needs of the local people over the 15-year time period have been calculated as around 5,300 homes - much less than half of that figure. There is presently no housing shortage and no demand for additional business premises, as is demonstrated by planned business developments that have not come to fruition and by, for example, the number of vacant premises on the Technology Park and other business sites in the area.

Such a quantity of extra housing would depress prices and attract incoming population, not for any reason that would have an economic advantage to the area, but simply because Warwick has the advantage of being a pleasant place to live. If all these houses are built then people will come for their own benefit, not Warwick's. It has been increasingly obvious that the town's infrastructure simply cannot support such a large increase in population and some of the issues it would raise have no clear solution, as will be noted below.

Whereas the housing demand may change in the future, a 15-year forecast, from any current projection, is unlikely to be realistic. I think we can be certain that similar forecasts made in 1998 for a period of time up to the present day would have been hopelessly wrong due to the unforeseeable degree of intervening economic and social changes. There is no reason to believe that today's estimates will be any more reliable. If a far more restrained Local Plan were put in place there is ample time, over the next decade, to make any adjustments that might prove necessary should an actual demand, from either the housing or the business sector, manifest itself.

Transport and road infrastructure

Such out-of-town developments will clearly be car-dependent, and this is where the greatest issues lie. Even if good public transport were to be provided, which seems unlikely on a commercial basis, the modern preference is always to use a car, as is evidenced by Warwick's existing problems with traffic congestion. The development to the immediate south-east of Warwick alone is likely to add 10,000 cars to Warwick's roads in due course, increased by those planned under the proposed Stratford Plan. This is an intolerable number that the local infrastructure cannot possibly accommodate.

The road enhancements planned cannot solve this problem and will only add to congestion, both in the town itself and on its outskirts. The extra lanes planned at the Myton Road/Banbury Road junction would clearly be disastrous for the town. This junction is already horrifically overcrowded, as can already be seen at any busy time. The vast majority of the traffic from Myton Road currently turns right into Warwick; likewise the vast majority of that from the Banbury Road travels straight on into Warwick. All of this traffic is immediately funnelled over the narrow, weight-restricted Avon bridge, which provides an insurmountable obstacle to traffic flow. Any additional traffic that does manage to cross the bridge will just make the present congestion in Smith Street, The Butts and Jury Street/High Street worse than ever. Creating extra lanes and introducing traffic control at that junction may shorten the length of the queues leading towards the town, but the result will be that as well as the added congestion in the town itself, traffic density on the roads immediately surrounding Warwick will certainly be far worse than at present.

Creating new business premises as a part of the new development will only make matters worse. Whereas it may be convenient to assume that incoming population in the area south-east of Warwick might also work in that area, examination of other developments, such as the Technology Park, demonstrate that this simply is not the case. The Technology Park attracts staff from all directions over at least a 30-mile radius, and many of these people travel through Warwick to get to work. Examination of the work-related travel of many people living in the Warwick area will show the reverse pattern; that many of them work outside Warwick, often on the opposite side of the town. These commuters form a significant part of the 80% of traffic that passes straight through Warwick and causes the present congestion. There is no reason to believe that people living or working in the proposed new development to the south-east would show any different patterns of travel, and Warwick will just grind to a halt. I can only imagine what effect a town that is constantly grid-locked with traffic will have on Warwick's tourism industry.

All in all, these major issues surrounding the impact of traffic in and around Warwick cause the Local Plan to fail on all three criteria for sustainability - environmental, economic and social. In these circumstances, WDC should consider a revised, and far less damaging, approach.

Air quality and pollution

I have been horrified to learn during the course of development of the Local Plan that car exhaust pollution in Warwick town centre is already higher than is legally permitted. It would seem irresponsible of WDC to contemplate developments that will make the situation worse without having any means of addressing this problem. Surely the Health and Safety of Warwick's residents and visitors should be WDC's primary concern and is a legal obligation? Bringing larger amounts of traffic closer to the town due to the road enhancements can only extend the pollution problem over a greater area. Close to Site (6), the first to suffer will be our younger generation whose schools and playing fields are immediately adjacent to the main roads.

As well as the poor air quality, pollution due to traffic noise and vibration are an increasing problem within the town. Living in Bridge End, the traffic noise has become very noticeably worse over the (almost) 25 years I have been a Warwick resident. This situation must be far worse for people actually living on the main roads or in the town centre where, as well as the noise, vibration from the traffic will be a significant factor. Not only are the people living in Warwick affected, but our historic buildings are being damaged. Any further increase in traffic would clearly make the situation intolerable and once again this will have a significantly adverse affect on tourism.

Health infrastructure

As well as the road system and traffic, such a significantly increased population will put additional strain on other infrastructure. A primary concern is whether health and hospital services will be able to cope. In particular, Warwick Hospital's (already stressed) A&E services will need to cope with a much larger population over a greater catchment area. Those needing the existing Warwick hospital from Site (6) will need to enter and cross the town by the existing congested route over the Avon bridge. As well as Warwick's own plans, the ambitious plans that I understand Stratford District Council is forming for its own large developments, just outside Warwick District, will also need to be supported by Warwick's A&E department. I have seen no evidence that this joint impact has been taken into account when considering the sustainability of WDC's plans.

As a retired person I should like to see Warwick preserved for future generations to enjoy, both for its residents and for visitors to the town. This does not necessarily mean that it should remain unchanged, but all development should be in keeping with its status as an historic county town - on a scale with, and in harmony with, its setting and environment. I fear that WDC's current Local Plan does not achieve this in any way and would urge that full consideration be given to the points raised above, with a view to producing a sustainable Plan more in keeping with the needs of the town and its residents, rather than the development aspirations of those less directly affected by the proposals as currently planned.

OBJECTION TO THE LOCAL PLAN FOR THE REVISED DEVELOPMENT STATEGY

This is not a plan or a Consultation Document it is a mish-mash of isolated ideas and unconnected thoughts without any joined up thinking. I am repeating what I said at the meeting held at Hill Close Gardens a year ago. Fundamentally my views have not changed.

My major objections are as follows:

1. There cannot be any development in this area without the building of

* A new hospital which is fit for purpose as Warwick Hospital cannot cope with potentially 20,000 - 30,000 new patients
* Two new secondary schools need to be built and I can only see a site for "possible Secondary School". This has other implications on both schools in the area and on traffic flows at peak times.
* Where are these people going to work? Is it Sir Peter Rigby's new Gateway scheme that the WDC planners are so keen on?

2. No traffic assessment can have been done because if that is the case then the overwhelming case cannot be in favour of bringing traffic over a Grade II listed bridge that is already crumbling as the 7.5 tonne weight limit is regularly ignored. You only have to stand at the end of Myton Road between 8.00am and 9.00am or between 5.00pm or 6.00pm and you can see the effect. Warwickshire County Council's record in traffic management schemes is not one to have confidence in considering the mess they made of the recent "improvements" to the High Street and Jury Street. Indeed if these plans come to fruition then many of the streets in Warwick and surrounding environs will be just be arteries and I think here of Smith Street, St Nicholas Church Street, Bridge End, Myton Road, High Street, Jury Street, Castle Hill, Europa Way etc. The list is almost endless.

It has been suggested that the junctions become traffic light signal controlled. If they are anything like the new scheme that has been put in place at Princess Drive and the Recycling Centre then they will be an accident waiting to happen. It also adds nothing to the traffic flow and is far too complicated.

If the Gateway scheme is to be the major employer then again it is naïve on the part of the traffic planners to say there will be little impact on traffic flows. Most people will therefore be making their way to the A46 Trunk Road and either Avon Bridge or Europa Way will become very congested indeed. It is already indicated that traffic at the morning peak will be moving at less than 5mph. This means maximum pollution for very little reward.

3. At a previous meeting at Hill Close it was indicated that traffic issues at peak times would be a real problem issue due, in part, to school starting and finishing times. It was suggested that schools could be spoken to stagger their start and finish times. This I felt was naïve in the extreme as many parents drop their children off on the way to their place of work and this will not change. Thus that will not improve.

4. Developers will only build houses if they can sell them. Do people want to buy them and are they affordable. However once planning permission is in place then it is very difficult to stop it. This will be like having the 'Sword of Damocles' hanging over us.

5. Surely 12,000 houses are excessive. I would have thought a maximum number of half that amount is what is actually required which would have a dramatic effect on the plan. Why is the vast majority of the development on Greenfield sites and not Brownfield ones. I understand that only 9% of Britain is developed but when cuts out most of Scotland, Wales some areas of Derbyshire, Yorkshire, Northumberland, Cumberland and others then the picture looks vastly different. We are already overcrowded as an island. Why must the residents of Warwick (mainly) and Leamington be made to suffer?

I am not a 'serial' objector but a very concerned resident of what is a jewel in the crown of Warwickshire that is likely to be desecrated by this plan.

Like a lot of people I am very concerned about the increase in traffic and the accompanying pollution and congestion, particularly in view of the limited number of crossings for the railways and rivers.

However, there are 2 issues I particularly want to raise:
* Harbury Lane - I am very concerned about this road and how it will be developed to deal with the increase in traffic. My concern is with it becoming a "motorway" that divides housing developments on either side and the dangers of not having a lower speed limit than the current 50 mph to traffic coming off the estates. Also the roundabout at the end of Earl Rivers Avenue needs to be improved by "smoothing" it out to cope with the increased levels of traffic as it is poorly designed.
* Churches - No mention or account seems to have been made about the provision of Churches for the influx of new people. At least some provision has been made this time for primary schools and maybe a secondary school plus local centre,s but consideration needs to be given to space for Church buildings even if they are satellites to the current Parish Churches.

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I object to the proposals for the housing south of Warwick and Leamington because they rely heavily on car use. The draft plan will increase traffic congestion, increase pollution causing increased respiratory disease and a reduced quality of life. The pollution will spread across the rest of the District. WDC say its investment in mitigation will improve the traffic flows but how more vehicles will cross the river to reach either Warwick or Leamington town centres or reach employment centres around Coventry is not clear. The mitigation measures will cause disruption to implement them and once Europa Way becomes dual-carriageway, it will become a barrier between the communities either side of it and the Europa Way roundabout will be a bottleneck, particularly during the peak travel hours.
If WDC believe that employment will be in Warwick or Leamington then this underlines the importance of the railways and building settlements along the rail corridors. This is very different from the concentration of dwellings to the south of Warwick and Leamington.
The number 68 bus which is the main service connecting the Local Plan's development area suffers poor reliability, most likely because of traffic congestion. This will only worsen with the added traffic that the development would bring. Furthermore the service is expensive to users which presumably together with its poor reliability causes its poor loading. Poor performance of public transport will cause more of the new residents to use cars for travel which will set up a vicious circle.
I object to the Local Plan because of the investment needed to try to mitigate the congestion. The lack of clarity about the river crossings makes it hard to believe in the viability of the infrastructure proposals.
The County proposals for a park and ride scheme by the Europa Way roundabout demands a lot of infrastructure. Furthermore, the intensity of services quoted in page 95 of the Strategic Transport Assessment looks high, surprisingly high. The financial viability of this level of service looks suspect and might well need an ongoing subsidy. In short, to satisfy the transport needs of the large scale of the proposed development needs disproportionate infrastructure spending to offset the effects of a badly sited development.
I object to the Local Plan because I believe that such a large number of dwellings should be distributed around the District. That such a high proportion of dwellings should be built in one place shows that the 'greenbelt' framework is not fit for purpose and should be reformed. WDC should look to reform the 'greenbelt' legislation if it is to take so many houses.
Placing so much development away from rail corridors is very short-sighted, especially with the planned railway electrification with its possibilities for using renewable energy. WDC should pursue a policy of one or two small eco-towns of 2,500 to 3,000 houses centred on a new railway station. Development would be around 1km across depending on housing density. As the railways run through greenbelt for the great majority of their mileage in the District, the policy would be undermined straight away. The choice is to build settlements on greenfields that will increase pollution but it is outside greenbelt or build in a sustainable transport way on greenbelt. Building settlements on rail corridors would be truly sustainable.
I object to the Local Plan because it will extend a market town and spa town in one direction, creating sprawl and being out of character with the towns.
I object to the Local Plan because it takes the number of houses, assigns some to a few token areas and leaves the majority for a single area. This is reacting not planning

I just want to register my disapproval to all of the important measures put down in the latest draft local plan. It is an absolute DISGRACE, for instance, that you are considering building all the houses South of Warwick. Why on earth did you not put housing where the new Morrisons is? Apart from which, it is absolute drivel, as the Warwick Society have proved, for you to say there is a need for all this development. I want to see Warwick, Kenilworth and Leamington thrive as someone who depends on footfall, but I certainly do not want my business to prosper at the expense of the complete destruction of the whole nature of these wonderful towns. You should be ashamed that you have not more integrity to build on what is good, and not try to introduce wholesale unnecessary change.

Similarly with these points raised by Sue Butcher...
* Do you realise that they plan to put traffic lights on Castle Hill roundabout, Myton Road roundabout and the foot of Smith Street?
* Do you realise they plan to create a no right turn from Smith Street into St Nicholas Church Street?
There is absolutely no need for these measures whatsoever.

What you should be looking at is the whole question of parking, and treating it as a means of getting people into our towns to shop, instead of treating it as a cash cow. When retail is totally run into the ground in all our towns and High Streets it will be short-sighted Councils like yours that will be to blame, and you should be ashamed of your lack of a decent strategy.

The point is WHY DON'T YOU LISTEN? The Warwick Society and the Chamber of Commerce have both spoken out as representing large considered bodies of opinion and you appear to totally disregard them. Your consultation will no doubt be shown as the usual travesty. Listen before it is too late.

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This is not a plan or a Consultation Document it is a mish-mash of isolated ideas and unconnected thoughts without any joined up thinking. I am repeating what I said at the meeting held at Hill Close Gardens a year ago. Fundamentally my views have not changed.

My major objections are as follows:

1. There cannot be any development in this area without the building of

* A new hospital which is fit for purpose as Warwick Hospital cannot cope with potentially 20,000 - 30,000 new patients
* Two new secondary schools need to be built and I can only see a site for "possible Secondary School". This has other implications on both schools in the area and on traffic flows at peak times.
* Where are these people going to work? Is it Sir Peter Rigby's new Gateway scheme that the WDC planners are so keen on?

2. No traffic assessment can have been done because if that is the case then the overwhelming case cannot be in favour of bringing traffic over a Grade II listed bridge that is already crumbling as the 7.5 tonne weight limit is regularly ignored. You only have to stand at the end of Myton Road between 8.00am and 9.00am or between 5.00pm or 6.00pm and you can see the effect. Warwickshire County Council's record in traffic management schemes is not one to have confidence in considering the mess they made of the recent "improvements" to the High Street and Jury Street. Indeed if these plans come to fruition then many of the streets in Warwick and surrounding environs will be just be arteries and I think here of Smith Street, St Nicholas Church Street, Bridge End, Myton Road, High Street, Jury Street, Castle Hill, Europa Way etc. The list is almost endless.

It has been suggested that the junctions become traffic light signal controlled. If they are anything like the new scheme that has been put in place at Princess Drive and the Recycling Centre then they will be an accident waiting to happen. It also adds nothing to the traffic flow and is far too complicated.

If the Gateway scheme is to be the major employer then again it is naïve on the part of the traffic planners to say there will be little impact on traffic flows. Most people will therefore be making their way to the A46 Trunk Road and either Avon Bridge or Europa Way will become very congested indeed. It is already indicated that traffic at the morning peak will be moving at less than 5mph. This means maximum pollution for very little reward.

3. At a previous meeting at Hill Close it was indicated that traffic issues at peak times would be a real problem issue due, in part, to school starting and finishing times. It was suggested that schools could be spoken to stagger their start and finish times. This I felt was naïve in the extreme as many parents drop their children off on the way to their place of work and this will not change. Thus that will not improve.

4. Developers will only build houses if they can sell them. Do people want to buy them and are they affordable. However once planning permission is in place then it is very difficult to stop it. This will be like having the 'Sword of Damocles' hanging over us.

5. Surely 12,000 houses are excessive. I would have thought a maximum number of half that amount is what is actually required which would have a dramatic effect on the plan. Why is the vast majority of the development on Greenfield sites and not Brownfield ones. I understand that only 9% of Britain is developed but when cuts out most of Scotland, Wales some areas of Derbyshire, Yorkshire, Northumberland, Cumberland and others then the picture looks vastly different. We are already overcrowded as an island. Why must the residents of Warwick (mainly) and Leamington be made to suffer?

I am not a 'serial' objector but a very concerned resident of what is a jewel in the crown of Warwickshire that is likely to be desecrated by this plan.

Dear Mr Barber

Warwick Local Plan - Revised Development Strategy Consultation

Thank you providing English Heritage the opportunity to comment on the Revised Development Strategy.

My response is mindful of the expectation the Warwick Local Plan enables the delivery of sustainable development in accordance with the policies in the NPPF , with one of the core dimensions being the protection and enhancement of the historic environment .

This letter responds to the proposed strategic site allocations at Thickthorn, Whitnash and south of Gallows Lane, and also considers the implication of the infrastructure provision to accommodate such growth.

Thickthorn, Kenilworth

"There is the potential for significant long term negative effect on heritage as Thickthorn Manor and Stables (Grade II Listed Buildings) are adjacent to the site and a small portion of the north east of the site contains part of a Scheduled Monument (Roman settlement at Glasshouse Wood). Stoneleigh Abbey Historic Park and Garden (Grade II) is also adjacent to the eastern boundary of the site, albeit separated by the A46".
(Paragraph 4.58 Warwick DC Local Plan Interim SA Report June 2013).

It is surprising that section 5.4 (Thickthorn) of the Revised Development Strategy makes no reference to the number of heritage assets directly and indirectly affected despite the above comments in the SA and similar references in the SHLAA. There appears an absence of evidence to demonstrate there has been a proper assessment establishing what it is about each of the affected heritage asset that is important; how the land/site proposed for development contributes to that significance, and; what in turn this means for the principle of development, and any future design response (mitigation).

You should note that this explicit point has been made to you in previous correspondence.

You will also appreciate that due to the former Roman occupation of the site there also needs to be an assessment of the likelihood that currently unidentified heritage assets (of potential national importance) will be discovered .

Without such assessments you may not be able to assert that the objectives for sustainable development have been understood and therefore cannot say whether the objectively assessed development needs of the District will be met or not in accordance with the presumption in favour of sustainable development. Consequently the Plan may be considered to be inconsistent with the provisions of the NPPF and therefore unsound.

It is expected that evidence has been taken into account when considering the impact of the proposal on heritage assets, to avoid or minimise conflict between the heritage asset's conservation and any aspect of the proposal .

You will appreciate that great weight should be given to the conservation of heritage assets and there is a legislative expectation that special weight is paid to the desirability of preserving the setting of any affected heritage asset.

The Setting of Heritage Assets (English Heritage Guidance October 2011) provides a robust assessment methodology to help determine the extent to which this and other strategic allocations would impact upon the significance of any affected heritage asset and how decision making and potential mitigation may respond. We strongly recommend you apply this guidance before the principle of development is determined.

www.english-heritage.org.uk/publications/setting-heritage-assets/

Whitnash

I note this sizeable development is proposed at the end of Church Lane, near the historic core of Whitnash and village conservation area that includes a number of listed buildings. Has the impact been considered?

South of Gallows Lane/west of Europa Way

As this particular site to the south of Warwick clearly has the most acute and evident impact on the significance of the historic environment I will focus my response accordingly. Nevertheless you should be mindful of the cumulative impact of progressive encroachment into the rural landscape from the number of proposals via this Plan and from adhoc planning applications. The Local Plan needs to determine a coherent landscape policy.

The site to the south of Gallows Lane is adjacent to Warwick Castle Park, which is included on the English Heritage Register of Historic Parks and Gardens at grade I. This encompasses Warwick Castle which is partially grade I listed and partially scheduled as an ancient monument. The setting of the park to the north-west is the historic town of Warwick. The key building of the town which dominates views from the park in that direction is the tower of St Mary's Church. The site in question lies to the east of the park and is visible in distant views from the towers of the castle and the roof of St Mary's Church tower.

The park would have spilled over into this area and is therefore a consideration for how the park as a heritage asset is experienced.

We have inspected this area, including viewing the site from the roof of St Mary's Church tower, and from within the historic park. It seems to us that there will be an impact on the setting of the park, which is a part of its significance, and that it is such that it brings the development if this site into question.

The park was bounded by a circuit drive which ran through the woodland belt on the east side of the park adjacent to the site and in places was close enough to the edge of the park to permit views out. Whilst this historic tree belt provides a degree of screening it is relatively narrow and composed mainly of deciduous trees so when leaves are shed considerably less screening is provided.

As you would expect, the park incorporates a number of viewing points including, for example, Lord Brooke's clump, with a drive running to it; and the dam over New Waters. No assessment has been made of the impact of development on these viewpoints.

It should be noted that experience has shown that even vegetative barriers or shelter belts of a depth of 50m+ may be ineffective if the objective is total screening (as opposed to baffling development), especially if predominantly deciduous species are planted (native planting likely to be requested), which will be ineffective in winter.

It should also be noted that the historic park was intended to extend beyond this boundary into this proposed development site and also that modern traffic has considerably more impact now than during the eighteenth and nineteenth centuries.

Even allowing for relatively low scale development and landscaping development is still likely to impact on the significance of the park during both day and night time. There will be increased urbanisation as the result of, amongst other matters, lighting, increased traffic and noise. Impact will be accentuated by proximity.

The implication for the sense of arrival to Warwick, the setting of the Park, the Castle and the Warwick Conservation area appears not to have been thoroughly considered; an important material consideration and therefore a serious omission. As we know, visual impact is but one contributor to the setting of a heritage asset and in focusing only on visual impact any assessment is deficient.

I repeat the point made with regard to development at Thickthorn, that you should appreciate that great weight should be given to the conservation of heritage assets and there is a legislative expectation that special weight is paid to the desirability of preserving the setting of any affected heritage asset.

The Richard Morrish Landscape study objects to the principle of development at the Asps but surprisingly not to the site south of Gallows Lane/west of Europa Way which is a similar area of land immediately to the north i.e. closer to the town. Surely the very same concerns relating to the Asps also apply to the site south of the Gallows/west of Europa Way i.e. it "...provides a historic context to the castle park. As open land it is prominent in terms of approaches to Warwick and provides a valuable setting to the town." In consequence, surely the Richard Morrish Landscape study should come to the same conclusion i.e. the development is unacceptable in principle?

Whilst the attempt to militate against harm is noted we are not confident that even if development were one field depth back, and reinforced by a narrow shelter belt it would provide a sufficient response as screening/ filtering belts of trees are seldom effective in winter, even at 100 metres depth.

The SA considers development of this site would have significant medium and long term negative effects on the landscape, the town and the historic park. This is a significant statement.

Surprisingly however it does not question the principle of development on the site due, we deduce, to the principle being established by the SHLAA. It is not clear why this should be the case as the SHLAA is a fairly crude assessment which has not fully applied the policies of the NPPF; an example being that this site conflicts with policies for the protection of heritage assets in the NPPF (impact on the setting of Grade listed Castle Park) but the SHLAA considers it to be "suitable".

The SA suggests the significant medium and long term negative effects on the landscape, the town and the historic park can be mitigated by design. However it does not clearly set out what the negative effects are (views from the Castle; approach to Warwick from the south etc.?) so one can judge whether the design response would overcome those concerns.

One would have expected that a transparent methodology such as English Heritage's Guidance on the assessment of setting published in 2011, and by English Heritage's Conservation Principles would have been undertaken and applied to explain the rationale for including this strategic allocation. As it has not there is no evident justification.

District wide transport works to facilitate future development (section 5.6)

Direct, indirect and cumulative effects of proposals on the historic environment must be appreciated. An example of an indirect effect could be the infrastructure required to accommodate additional traffic movements from major new development through historic towns such as Warwick and Kenilworth which may in turn have a profound impact on historic character and significance of affected heritage assets. Such potential harm must be considered at this stage of the Plan.

The Plan proposes a number of major highway engineering interventions with the potential to have an extreme adverse impact. English Heritage is particularly concerned regarding proposals 11, 12, 13 and 24 and the subsequent substantial harm to a number of nationally significant heritage assets.

It is surprising there is no reference to the townscape/landscape implications of these proposals in either the Revised Development Strategy, or SA - a serious omission.

An increased in traffic using the A425 (Banbury Road) adjacent to Castle Park.

The consequence of further increased use of the road in terms of noise, light pollution and visual intrusions from highway paraphernalia such as signage does not appear to have been considered; again an important material consideration and therefore a serious omission.

What are the implications for the sense of arrival to Warwick? What are the implications for the setting of the Park, the Castle and the Warwick Conservation area?

In accordance with the expectations of the NPPF, how has the Plan demonstrated that it has considered the opportunities to enhance the setting of the historic town and its nationally important assets between the Toll House (at the junction of Banbury Road and Gallows Hill) and the East Gate, a stretch of road blighted by past 'dramatic' road works particularly the Caste Hill Gyratory?

A substantial increase in traffic through the south and east of the historic town will have significant implications. Is there evidence of an appropriate assessment of the consequences for the historic environment, in particular for St Nicholas Church Street?

Castle Bridge - circa 1790 schedule monument and grade II* listed building.
This is another significant heritage asset that may be affected by the cumulative impact of development in the area. The direct impact on the bridge of considerably increased traffic movements and the inevitable 'highway works' in the vicinity will affect its setting which needs to be considered and resolved at an early stage.

Is there evidence available to reassure that this historic structure actually has the capacity to accommodate a significant increase in traffic?

The Warwickshire CC Strategic Transport Assessment Overview Report 2012 recognises at para 2.2.3 the national policy context to inform its transport planning in the District, and in particular makes reference to the need to accord with the NPPF and conserve heritage assets "in a manner appropriate to their significance" . However subsequent reports in the evidence base do not appear to address this matter at all; again a significant omission.

An objective for these schemes should be that they cause little or no damage to the historic environment. This means minimising any adverse impact on the rural context of Warwick from the south and the landscape setting of the Warwick Castle and nationally important Park. It is imperative that proposals are designed with utmost care. The NPPF expects those assets of the highest level of importance, such as these, be given the highest level of protection.

How compatible are the proposals with the ambitions of the Warwick Town Centre Action Plan regarding public realm and townscape improvements? How will these proposals enhance the experience of historic Warwick?

How can the Plan reassure English Heritage that these highway schemes will protect, and where appropriate, enhance the historic environment including the setting of individual heritage assets?

The Local Plan must be absolutely clear what it expects in terms of the design execution of these schemes. I refer you to the Manual for Streets (versions 1&2) (Department for Transport, March 2007 and September 2010).

You may wish to confirm that these traffic schemes will be sensitively designed having regard to Manual for Streets, and Streets for All to ensure they are all integrated into the landscape/townscape and take the opportunity to enhance the experience of the historic environment.

I hope this comprehensive response and further constructive involvement can help you to ensure a sound Plan and in doing so secure an effective conservation of the historic environment and the delivery of sustainable development.

If there any issues you wish to clarify please do not hesitate in contacting me.

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

New Housing


Number Of Houses & Impact To Local Infrastructure.

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

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

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

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

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

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


Location Of Proposed Development

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

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

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

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

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

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


Location Of Proposed Development Near To Bishops Tachbrook.

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

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

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

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


Use Of Green Field & Brown Field Sites.

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

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


Gypsy & Traveller Sites.

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

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

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

* Sites 6 & 9 have no pedestrian access.

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

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

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

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

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

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


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

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

I write to support the overall shape of the New Local Plan Revised Development Strategy (RDS), certainly compared to the original Plan, although with some reservations, in particular about its overall scale. I very much support the absence of development on the North Leamington Green Belt around Milverton and Blackdown.
I am pleased that the Council has recognised that the Exceptional Circumstances to develop the Green Belt to the North of Leamington do not exist and that as a consequence the risks of the Local Plan being found unsound at public enquiry are reduced. It is vital to preserve the limited green space between Leamington and Kenilworth, otherwise there is a real risk that Leamington and Warwick will merge with the West Midlands conurbation.
The Green Belt in this area meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. It would be worth referencing the Joint Green Belt Review 2009 which confirmed the high value of this stretch of Green Belt and is key evidence, more clearly in the Plan document. Development in Kenilworth, Baginton and Lillington may already take land from this essential Green Belt and further development on it would not be sustainable. It must not be permitted.
But I am also opposed to any encroachment into other Green Belt designated land in the District if it can possibly be avoided and believe a further review of some assumptions and principles could make this unnecessary. Certainly if it goes ahead the Council should seek to designate additional Green Belt land of the same size or greater than the Green Belt being developed - for example in the Asps area for the reasons highlighted in 4.3.8
My reservations and suggestions for further review are:
1. Windfalls
There is a large increase between the original and the revised Plans in the number of units being added through windfalls within existing planning boundaries, reducing the units required on new land by 1500 or almost 20% (the change was very clear in the public presentation). This huge revision suggests that the assumptions made for windfall or infill developments coming forward during the Plan period of slightly under 200 units per year (page 13 table 2) - there were 600 in the last year alone - may be significantly understated. 50 additional units a year would remove a further 750 from the newbuild total, roughly equivalent to the proposed greenbelt expansion. The assumption should be carefully reviewed.
2. Brownfield sites
The assumption here also looks modest.
Does the Plan include any assumption here or elsewhere about development of the old Potterton site and possibly greyhound track land alongside the Avon in Warwick ? Only phase 1 has been completed and filled (with difficulty - see below).
Has the recreation ground alongside the river, which is linked to the Edmonscote sports track been considered as suitable underutilised open space ?
Given shop vacancy rates and forecast trends, has sufficient allowance been made for conversions to residential in shopping areas, especially if major projects such as Chandos Street were now assumed to be available for high density accommodation ?
3. Building Densities
It is not clear if the new planning framework will specifically encourage higher density developments eg 4-8 storey townhouses/apartments within existing planning boundaries and in particular close to public transport services. It certainly appears not for newbuild proposals (5.1.3) but presumably this could also be adjusted in the new homes criteria at least in part. This would both be in line with the character of central Leamington and Warwick and take further pressure off the need to build on agricultural land. This option should be given further consideration.
4. Impact on Agriculture
It is not clear from the RDS what the impact would be on agricultural production and whether this has been considered in any judgements about possible alternatives, such as a higher density strategy outlined in point 3.
5. Building Quality and Mix
The criteria set out in 5.14 are sensible as far as they go. If there is any scope in the Plan for specifying higher standards of architecture (innovation, variety, local character etc) and of minimum living/garden space requirements I would strongly support those additions. Such criteria would help developers - and planners - avoid the costs and embarrassment of high vacancy rates on newbuild. The best recent example of this locally is probably the unattractive, rabbit-hutch sized first phase development on the old Potterton site. How the Plan might specify or aim to influence such desirable criteria should be considered.
6. Southern Green Park
It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than for development in the North. For instance putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible and if possible larger. It could be crossed by cycle-ways and would act as a green-lung to reduce air pollution.
7. Transport
The cycling plans look convincing. However the enhanced public transport outlined in the RDS seems unambitious and sketchy. Frequency of links should be at least as good as the current G1 and G2 services (every 8-9 minutes) with evening and weekend improvements throughout the District, if congestion is to be convincingly minimised. More detail is required in the Plan demonstrating how services will attract sufficent use to achieve this (coverage, frequency etc).
Two further points might be usefully touched on as part of a wider discussion of transport needs for a growing District:
- planned improvements at the slightly out-of area Gaydon interchange with the M40 will already be in place to assist flows to the south of Leamington (5.1.15)
- how will bus services (new and existing) connect to Railway stations and what is expected in the way of improved rail connections across the District (eg frequency to Coventry, a Kenilworth station) in order to reduce overall road use, pollution and congestion.
Subject to these reservations I broadly support the revised strategy and would make the following points:
8. A Joint Strategic Housing Needs Analysis is currently being performed with Coventry City Council. If this review identifies that it is necessary to increase the number of houses above those currently proposed, as I hope it wil not, I believe that there is sufficient non Green Belt land to accommodate this additional development.
9. The RDS has a fair distribution of new housing across the District. 16% of the new houses will be in the Green Belt North of Leamington, at Thickthorn and Lillington. (However see the fourth paragraph of this letter and point 1 above). 15% of the proposed development will be in Warwickshire Villages.
10. Given that the RDS will no doubt require some building on new land, even after possible adjustments arising from points 1-3 and 8, the proposal that most of the new development is located close to where employment opportunities already exist (e.g. industrial parks to the South of Leamington & Warwick) is logical. It provides an opportunity for people to live close to their place of work, reducing or eliminating commuting for many people, reducing pollution & improving quality of life. Furthermore there is ample space to build to the south of Leamington as the next nearest town is Banbury.
11. Focusing development in the South, in one broad area, ensures adequate public services can be provided and developed to meet the needs of the new population. These services can be designed to meet the exact needs of that new population and planned within easy walking and cycling distance, minimising traffic congestion. If development were to be more spread across the district public services would have to be developed in an inferior and unacceptable "make-do-and-mend" fashion which would provide poorer levels of service to both existing and new residents in those areas.
12. The RDS provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district as it would have forced people to travel south to employment land, shopping (e.g. supermarkets) and the M40. Loss of vital Green Belt recreation land would also have resulted in more people travelling by car for recreation.
Less overall development outside the present limits - and particularly within the Green Belt - should be the main objective.