Lower Heathcote Farm

The green land south of Harbury Lane provides a buffer between the Warwick Gates development and Bishops Tachbrook. Development on Lower Heathcote will leave only a small buffer around the Tach Brook. However as this is in a dip it will be difficult to see giving the impression from Bishops Tachbrook that the village is linked to Warwick Gates and therefore to Leamington Spa. This will destroy the separate character and identity of the village of Bishops Tachbrook.

Yet another scheme to ruin a pleasant open aspect. This should not be called a New Local Plan - it should be called "Let's ruin the area of Whitnash and Warwick". Why the dense concentration of housing development in this area? I suggest smaller developments spread over several areas in the District. That way, no harm will be done to existing communities, traffic will not be overbearing, schools will not be over subscribed and expensive road networks will not be necessary. And, WDC will still be able to produce figures that placate Mr Pickles and his henchmen.

The land to the south of Harbury Lane should not be developed as is high grade agricultural land which should not be lost. Although the proposed country park may provide a minimum separation of the urban expansion from the village of Bishop's Tachbrook the large number of houses proposed will destroy the visual aspect of the Warwickshire countryside for the residents of the village.There is no evidence or guarantee that the infrastructure improvements needed for such a large development can be provided by the Developer contributions through Section 106 and the Community Infrastructure Levy.

I object to the proposal the redevelop this area for the following reasons:
a) Road capacity in the immediate area is insufficient to meet current traffic requirements.
b) Local amenities would not cope with the increased housing proposed.
c) Parking and road access into Leamington Spa can get extremely congested, particularly when a relatively small events such as the recent Peace Festival taske place. This access would not cope with the additional population increase proposed.
d) Traffic in and around the roundabout near the Shires Retail Park/Morrisions would, as per point C, not cope with the additional increase in traffic.

Housing requirement estimated, use of Green field site based on an over estimate of the local housing needs.

We note a formal planning application was made for the northern portion of this site. Stagecoach Midlands notes that the promoter has made no provision for a bus service to penetrate the site directly or indirectly in those proposals. These have now been withdrawn. We found this omission most concerning. We submit that any future proposals for this land should assume the retention and enhancement of the existing service along the existing route/s, with attractive pedestrian links to quality bus stops provided on Harbury Lane. This approach justifies higher densities on the northern edge of future proposals that come forward. As a corollary it may be appropriate to reduce densities at the southern edge especially if these plots end up being outside a reasonable 400m walking distance of stops on Harbury Lane.
This would also support wider urban design and planning objectives.
We object to the development footprint extending further south onto land beyond the initial application site, as this land is well over 400m away from Harbury Lane and will not be within reasonable walking distance of a good bus service.

see attached

Thank you for the opportunity of commenting on the Warwick Local Plan Revised Development Strategy.
Midland Red (South) Ltd trading as Stagecoach Midlands, is the leading commercial bus operator in Warwickshire. The company operates the vast majority of bus services in Warwick District, including Leamington Spa and Whitnash, where we operate a comprehensive network designed to offer both convenient local trips, but at least as important, services offering residents effective choices for longer journeys. The great majority of these routes are commercial, fully funded by our passengers
We also operate services supported by Warwickshire County Council, won following tenders for best value. We always strive through disciplined reliable operation, quality customer service and on-board experience, and effective marketing, to build revenue on such services as far as possible with a view to taking them on without public funding at a future date, where possible. These services to a great extent follow timetables and routes specified by WCC, as socially necessary services, where patronage today could not support a commercial operation by us or another bus company.
Stagecoach in particular has a national, independently assessed reputation for delivering among the highest levels of customer satisfaction. As well as offering reliable convenient services we are constantly investing both in existing services and our operational bus fleet, and developing new products and services aimed explicitly at providing greener smarter travel choices to the public, and especially those who do not yet regularly travel by bus.
Stagecoach proactively seeks to identify and pursue business development opportunities, and the company recognises the role it plays in delivering sustainable development. We welcome the opportunity to comment on, and help shape development proposals to the advantage of the community and the wider travelling public.
High-quality bus services are one of the most credible means of preventing car dependency, mitigating local highways impacts as far as possible, and achieving sustainable development. This includes not only environmental but also socio-economic goals.
We submit that there is a clear alignment of interests between stakeholders in the planning system, and ourselves and other commercial bus operators.
Strategic Vision
Stagecoach Midlands therefore wishes to generally support Warwick District Council's Strategic Vision, which is essential in setting the basis on which sustainable development can be realised, but has strong reservations about certain of the measures proposed, which we do not believe will deliver the vision. As this Vision is taken forward through robust policy-led prioritisation of actions, Stagecoach Midlands will be much better able to support the LPAs objectives while achieving our strategic goal to provide further high-quality greener smarter travel choices to the District's residents and visitors.
The National Planning Policy Framework (NPPF) makes clear in paragraph 7 that the "golden thread" of Sustainable Development that runs through it, includes economic, social and environmental goals. Stagecoach Midlands recognises not just its general responsibilities as a good corporate citizen, but the particular key role our business plays in securing these objectives at a local level.
Every day, Stagecoach buses:
* connect customers to markets and employees to businesses. Stagecoach Midlands itself is a locally-significant employer and customer of UK businesses
* connect people of all socio-economic groups to school, college, further and higher education; and of course to leisure and recreation opportunities
Our operations achieve all of this in a way that reduces congestion, and emissions. DECC statistics demonstrate that in the UK, personal transport use generates as many greenhouse gas emissions as the entire residential dwelling stock.
Not only do we reduce personal travel carbon footprints radically, but we are making strenuous efforts to reduce the carbon intensity of our own operations. Stagecoach Group announced in January 2013 that it has cut the carbon impact of its businesses in the UK and North America by more than 20% in the past four years. The transport group's absolute annual carbon footprint is now nearly 56,400 tonnes of CO2e lower than in 2007-08. The annual carbon saving is equivalent to the CO2e produced by powering nearly 11,000 homes for a year. Measured by carbon intensity (kg CO2 per £ of turnover), Stagecoach's carbon impact now is 22% less than four years ago.
As a result, Stagecoach Group is the first Transport Company to reach the Carbon Trust standard for emissions reductions.
Where land-use planning, and local transport policies align to facilitate high quality efficient commercial bus operation, then a full range of highways management, economic development, environmental sustainability and socio-economic inclusion objectives are all simultaneously met.
Where bus services are not effectively and positively planned for, and bus operators and their customers are marginalised, then unsustainable car-dependent development is the unavoidable result, contrary to the overarching intent of National Policy, and the explicit principles set out in paragraph 17 of the National Planning Policy Framework.
Stagecoach therefore regrets that connectivity is not given much priority in Warwick District Council's Strategic Vision, although we understand the preoccupation with meeting housing need.
Transport, to the extent that as it is addressed at all in the Strategic Vision, is largely considered in terms of lists of hard infrastructure projects, designed in response to the modelled impacts of the Revised Development Strategy. Transport measures therefore seem entirely to flow out of the Development Strategy, rather than the Strategy firstly taking account of "the opportunities for sustainable transport modes (to be) taken up, depending on the nature and location of the site, to reduce the need for major transport infrastructure" as required by NPPF paragraph 32.
This risks a strong misdirection of attention into physical highway works without looking at more creative and holistic approaches which better address the wider needs of communities, now and in the future. This is explicitly required by paragraph 17 of NPPF. Specifically, it states that plan-making and decision- taking should:
"actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable."

Stagecoach also submits that the approach being taken, with its emphasis on hard engineering, is likely to prove more costly than one which identifies and takes up the existing opportunities presented by more sustainable modes of transport, in deciding the location for new development. This approach risks the delivery of that development, by imposing additional burdens on development viability than might strictly be necessary. We note that, just before this consultation closed, the promoters of the greater part of the Myton Garden Village site west of Europa Way, have tabled an application for up to 800 dwellings, of which only 20% are affordable, rather than the 40% sought in Warwick DC's emerging Local Plan policies. The applicants submit a full viability appraisal, by professional development economic specialists, that demonstrates that the cumulative burden on viability of planning requirements, including transport, does not permit the Council's target to be met.
NPPF is clear that planning should also ensure that:
"improvements can be undertaken within the transport network that cost-effectively limit the significant impacts of the development."

NPPF paragraph 31 also explicitly requires that plan-making bodies should
"...work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development."

We therefore are disappointed that the Revised Development Strategy and supporting Warwick Strategic Transport Assessment (WSTA) makes little or no provision for infrastructure to support delivery of high quality bus services, and in particular, bus priority at key points and on key corridors to the South and North of Leamington where congestion is already becoming a significant difficulty for us, and where future development proposals will greatly increase pressure on the highway network.
Stagecoach Midlands is very concerned that, based on the Warwick Strategic Transport Assessment Phase 3 modelling, undertaken in support of this strategy, the following effects arise, even with all the prioritised mitigation in place:
* A deterioration in traffic conditions in both Leamington and Warwick Town Centres
* A general decline in traffic speeds during peak hours, especially in the network south of the Avon
* That with all model runs, the biggest residual deterioration in road network performance occurs on the south and eastern flanks of Leamington Town Centre, on the one hand, where scope for engineering-driven mitigation is most limited; and on the Europa Way and Tachbrook Road corridors.
* A general increase in peak delays and queuing, in both town centres and on key arterial routes. The modelled increase in queues even at full mitigation at the Victoria Terrace/Spencer Street lights, and the Old Warwick Road/Princes Drive junction, through which a large number of our services must pass to serve the proposed southern focus of planned development, is especially worrying; and barely less so at the Tachbrook Road/Heathcote Lane junction. We are equally concerned, on the opposite side of the urban area, that a similar deterioration in traffic conditions is anticipated at the A46 Thickthorn Interchange.
The result is that each bus within our Leamington and Warwick network will cover less mileage in a given period of time, at the end of the Plan Period. Therefore, just to "stand still" in terms of journey frequency, Stagecoach Midlands will have to find additional resources: buses, drivers and overhead; to maintain the current timetable offer within the urban area and environs. Actual journey times will be slower, which ordinarily would be expected to produce a decline in overall patronage.
There is a real risk that, far from improving the conditions to deliver improved modal choice, in conformity with the requirements of NPPF, the Revised Development Strategy undermines it, because of the absence of specific targeted and comprehensive measures to deliver bus priority.
With regard to the developments themselves, while we do note WCC's preferred strategy on bus service specification to serve specific major development south of the towns in particular, the sense from the consultation document is these and all other bus services, will also have to fight for space on the existing network, alongside all other traffic, with negligible rebalancing of the highway network in favour of the bus as a more sustainable travel mode, as required by NPPF Paragraph 29.
WSTA Phases 2 and 3 modelling do assume certain very limited bus priority measures, though these are largely focused at the northern end of Europa Way. These mainly take the form of priority bus gates to allow buses to enjoy priority release from signals, but do not allocate dedicated lanes for bus services over any distance.
We also note that there is a considerable discrepancy between the Virtual Park and Ride frequency for which WCC are seeking developer funding, and that modelled in WSTA. The Revised Development Strategy sets out a 30-minute frequency service to Warwick, and a 20-minute frequency service to Leamington. WSTA Phase 3 assumes a 9-minute service frequency to Leamington, and 12-minute to Warwick throughout the day (WSTA Phase 3 section 9.2, p.95).
There is also some lack of clarity about the P&R routing and operating mode assumed by the WSTA models. It appears the WSTA Phase 3 modelled a dedicated direct Park and Ride bus service as it is not clear that any allowance is made in the journey time for the service to stop en-route to pick up and set down between the facilities and the town centres, as the "virtual P&R" concept envisaged in the Revised Development Strategy anticipates.
We are also very concerned at the journey time penalty suffered by Park and Ride users, compared with car users, that the model produced. We are therefore extremely sceptical that the mode shift assignment of travel demands to the bus service will occur at the level anticipated by the Plan. We do not see that motorists will see any advantage in parking, waiting up to 20 minutes for a bus to Leamington, and then suffer a slower journey than cars taking a parallel route into town (WSTA Phase 3 figure 30, page 101).
To re-iterate, the Park and Ride bus services are anticipated to operate as a conventional bus routes, and will therefore also act as the main bus links from the proposed development allocations to the Town centre. We do not believe that this service should make an initial journey first to the park and ride facility, before making its way into town, without enjoying any bus priority at any stage. In the absence of bus priority measures, the 15% mode shift target required by the Strategy would be much better achieved by those services serving the developments taking the most direct route into town.
The time disadvantage that WSTA assumes for bus passengers at peak times seriously undermines the credibility of the mode shift targets for bus use required by the Strategy. This time penalty can only be addressed by the introduction of comprehensive bus priority measures on the main affected corridors, and in the town centres of Warwick and Leamington.
We also note that the Leamington Park and Ride Route has been modelled to operate through the Myton Garden Suburb area, a parallel but not comparable route with Europa Way in terms of speed. In fact, depending on urban design approach, this route, with the potential for multiple accesses, side roads and on-street parking, is likely to be, and perceived to be, slower and more circuitous than a service running directly along Europa Way, if conventional urban and highways design approaches are used.
We are aware that a formal outline planning application for the bulk of this area was submitted just before this consultation closed (W13/1016/OUT). It is clear that the Master Plan and Movement Strategy is quite conventional.
We will be making our own submissions in response to the application. For now, in response to this Policy consultation, we would say that there are a number of ways to address this journey time disadvantage by Master Planning and highway design within the Myton Garden Suburb site, which we cover later in this submission. For the avoidance of doubt, we can see the considerable merits of combining a service through the Myton Garden Suburb with the "virtual" Park and Ride operation, BUT for this to work effectively and be attractive to potential passengers, great care needs to be taken in the overall design approach to the actual bus corridor within and adjoining the scheme, and the urban design of the proposals as a whole.
The approach taken within the modelling to the assignment of patronage to P&R is high-level and is therefore relatively inaccurate. Experience over many years demonstrates that park and ride delivers significant mode shift, and commercially-sustainable levels of patronage, only when parking at the destination is highly constrained, very frequent bus services are offered, and significant on-line bus priority exists, to allow motorists to see buses passing them while they sit in queuing traffic.
Looking both at the national experience of successful Park and Ride schemes, and then at a growing list of failed Park and Ride operations in some other towns, we consider that the virtual Park and Ride proposals need far more robust and nuanced operational and commercial modelling, based on a service design that offers very much clearer and more credible advantages for potential customers, if this part of the Revised Development Strategy is to achieve the necessary impacts.
To conclude and summarise, no bus operator can provide high quality mode choices when its costs are increased by operating in heavy congestion, while its customers face delays and unpredictable journey times. Real mode choice requires that the relative attractiveness of more sustainable travel modes needs to be enhanced. The Revised Development Strategy makes almost no explicit provision for such rebalancing, at least as far as bus services are concerned.
Indeed, the relative silence of the Development Strategy on the role of bus services in securing a sustainable form of development is quite notable, despite the weight attached to the effectiveness of certain bus-based elements in the WSTA.
The Councils' own retained specialist transport consultants conclude at the end of the WSTA Phase 3 Report that "further detailed assessment of the potential benefits of the P&R should be undertaken although it is imagined that such testing would be intended to compliment an over-arching feasibility study of the P&R site meaning allowances for mode share and interception could be included within the modelling to allow a better understanding of both the benefits and impacts of delivery." We strongly agree. In fact, we do not understand how the Revised Development Strategy can be considered robust without this work having informed the Strategy.
WDC/WCC's own highways technical consultant explicitly states that "it is critical that sustainable transport improvements form part of the mitigation package to support the housing and employment growth proposals within the District." (WSTA Phase 3 Appendix H Technical Note 21/5/13, page 1).
Stagecoach Midlands considers, having carefully reviewed the revised Plan proposals and the supporting evidence base, that a considerable amount of further work needs to be undertaken, in partnership with promoters, WCC and bus operators, as required by NPPF paragraph 31, to arrive at a deliverable, robust package of sustainable transport measures in support of a much more sustainable local Statutory Development Plan for Warwick.
RDS1 Stagecoach Midlands has no comment to make.
RDS2 Stagecoach Midlands has no comment to make.
RDS3 Stagecoach Midlands wishes to object to the proposed preferred option for the broad location of development, because of the difficulty in serving the sites on a sustainable commercially viable basis.
We strongly agree that a strategy of urban concentration makes best use of existing public transport infrastructure, and allows existing bus services to perform significantly better in terms of load factor. Such an approach also gives scope for a virtuous cycle of service enhancements to be delivered based on an overall larger quantum of demand from which to draw, by developing the network.
This supports travel mode shift not just from within the new developments, but across the improved network as a whole. It is likely, for example, that new or augmented routes serving development to the south of Warwick would continue, as today, across the town centres providing new direct links as well as enhanced frequency. This would improve the overall attractiveness of the service offer, subject to operating conditions being at least as supportive as today.
There is currently virtually no bus priority within the Warwick and Leamington urban area. Were measures to achieve bus priority to be introduced, then the positive effects outlined above would be greatly magnified.
We also concur with WDC and WCC that there is scope through a concentration of development south of the towns, to kick-start a radically improved level of service in an area in which historically it has proved very hard to offer frequent, direct bus services, not least because of car-dependent urban design, and a lack of critical mass of demand. In addition, the major local highway corridors, in particular Tachbrook Road and Europa Way, are already affected by peak-time congestion, even before any new development is constructed.
This opportunity to improve the public transport offer will only be realised, however, by positively planning for the bus to play a much enhanced role. While some of this is implicit in the intent of measures set out in the Revised Development Strategy, we are concerned that overall there is no clear agenda, nor specified measures, to ensure that the opportunities provided by the Strategy to deliver a much higher quality of public transport offer have been taken up, in the form of sufficiently well-developed actions required by Policy. We will address the opportunities we identify in more depth later in our responses.
As such we submit that the Strategy is not in conformity with NPPF.
Stagecoach Midlands OBJECTS to the location and distribution of the quantum around the south of Leamington and Whitnash.
In general, we consider that insufficient consideration has been given to achieving higher density development across the sites, or parts of them, sufficient to make best use of existing and credible future quality public transport provision. While we recognise the attractiveness and desirability of the Garden Suburb vision, the provision of effective high quality bus services is undermined by the relatively low housing densities involved, and the consequent likely impact on the dwelling stock mix.
The current Strategy, in proposing a relatively large development footprint also effectively gives rise to a much greater expanse of development south of Harbury Lane, than is easy to serve by a single high frequency bus route. Diverting existing service 68 through these areas will pull it away from existing development at Warwick Gates OR risk creating a circuitous service design that will be very unattractive to existing bus passengers, while being even less attractive to car owners.
Large parts of the development footprint in Myton Garden Suburb in particular, are much closer to existing local employment and amenities, and are also most closely related to the existing urban area. This development proposal is expected be within easy reach of the proposed high frequency bus corridor incorporating the "virtual Park and Ride". Depending on the master planning approach, higher densities might be justified in Myton Garden Suburb adjoining this bus corridor, either on the eastern flank if the service uses Europa Way, or, if a bus priority corridor were delivered within the scheme, within 250-300m of that. Higher densities, of up to 45 dwellings/Ha, would support much better patronage levels for the proposed bus service.
If it were possible to accommodate a larger development quantum at Myton Garden Suburb overall, which is the location best able to take advantage of sustainable transport measures, it might be possible to avoid the need for land releases elsewhere, which are currently very much less easy to access by sustainable transport modes.
In particular Stagecoach Midlands considers that several small-scale proposed land allocations east of Whitnash/South of Sydenham look to be difficult to serve on a sustainable basis, by attractive public transport services, without significant infrastructure measures being put in place, that are not anticipated by the Revised Development Strategy.
As stated above, the Strategy proposes that the development footprint extends much more than 300m south of Harbury Lane. The development quantum on land allocated beyond this threshold would be equally hard to serve with a bus service sufficiently frequent and direct to be attractive. In addition the wider public concerns expressed about incipient coalescence with Bishops Tachbrook could also be mitigated by a revised approach that reduced the development quantum that needs to be accommodated here by achieving a higher-density more compact urban form on development sites better related to existing and future sustainable transport opportunities.
We particularly object to the smaller scale releases of land south of Sydenham/east of Whitnash. These areas are well beyond 400m of existing bus services. Extending services into this area will require an additional vehicle resource, even at a modest half-hourly frequency. We do not consider that the potential patronage that would be generated by the proposals would sustain a credible commercial service in the long term. In fact, the need to split access to land south of Sydenham with a second access across the current Campion School site, makes this problem much worse, with only an additional 300 dwellings available to support the operating additional operating costs involved, which are likely to be between £130-140,000 per year at current prices.
However, were direct bus-only vehicular access provided across the railway between Whitnash and the land South of Sydenham, we see much greater potential to incorporate these areas into a high-quality commercial bus network, subject to appropriate pump-priming funding being available during the build out period to deliver this service appropriately early. This would require a bus gate incorporating a pedestrian and cycle link; and a high-quality bus circulation facilitated through the site, also picking up the proposals at Fieldgate Lane west of the railway.
Such an approach would lead to Sydenham potentially being directly connected to employment both existing and proposed south of Leamington. We consider that this would significantly enhance its connectivity to these opportunities and greatly improving the socio-economic sustainability of the Strategy. A dedicated transport crossing would also give public transport and other sustainable modes a major advantage over private car use from all the development east of the railway, and as a result these additional measures would offer a much more sustainable location compared with further development south of Harbury Lane.
We support the proposals at Redhouse Farm Lillington where the whole proposal falls within easy reach of an existing commercial high frequency service. It is the one proposed allocation that best makes use of existing public transport services and infrastructure in a location that is already sustainable.
We note the current proposed approach at Kenilworth. We recognise the need to meet the housing requirements of the town, and can see the landscape and other factors that favour Thickthorn. However we object to the current proposals because:
* We see that with the main access being proposed on to the A46 interchange, it will prove to be an exceptionally attractive location for car-based commuting, causing additional peak time congestion and undermining the effectiveness of the Strategic Highway Network, and potentially delaying our existing services, not least those offering fast links to Coventry and Warwick University via A46.
* When evaluating how we might serve the development, it is unclear that the quantum of development proposed there, and that existing adjacent, is sufficient to support a dedicated high-quality bus service longer term. Were we to divert existing routes it would in effect lead to other large parts of Kenilworth which currently enjoy frequent services, being either unserved or much more poorly served.
We also strongly support the additional development envisaged outside the main towns, particularly in larger villages. Bus services to these villages already typically offer hourly services, or better, but the longer-term sustainability of the current level of service does depend in most cases on higher levels of demand. We submit that, at a time when Warwickshire County Council is faced with ever increasing pressure on its budget for socially necessary but uneconomic bus services in rural areas, the approach taken by the Revised Development Strategy outside the main urban areas, is a prudent one to maintain and indeed possible allow some enhancement of bus services to outlying settlements. Walking and cycling do not present as credible a sustainable travel choice in these locations.
We would suggest there is likely to be scope for the kick-start of improved service patterns in certain rural corridors, facilitated by limited developer funding sought across multiple developments served by a rural bus route corridor. This may not only involve added frequency, but also more direct services, making elapsed journey times much more competitive with other modes such as car or scooter.
RDS 5 Proposed Allocations
Station Approach: Stagecoach Midlands would point out that a substantial portion of this site is our existing operational depot for the area. The depot provides the bus services for Leamington, Warwick and most of the surrounding area. No suitable or cost-effective alternative location for a replacement facility has yet been identified. Therefore the site is not available and is thus not currently deliverable or achievable.
Hampton Magna: If it were possible to create a greater allocation here, this would offer a larger population and a wider socio-economic mix that would be much better able to support the ongoing commercial operation of a bus service in this location, and one that is less circuitous than the present route, which given existing levels of patronage, requires Local Authority financial support.
Hatton Park: If it were possible to create a greater allocation in this area, this would offer a larger population and a wider socio-economic mix that would be much better able to support the ongoing commercial operation of a bus service in this location, and one that is less circuitous than the present route, which given existing levels of patronage, requires Local Authority financial support.
The current design of internal roads also makes the existing development exceptionally difficult for bus services to penetrate, owing to the detailed design of traffic calming features. Any traffic calming measures introduced must be low floor bus friendly and very minor works within the highway could address this as part of future development proposals, and should be required to do so.
RDS 6 Employment Land requirement: Stagecoach Midlands has no comment to make.
RDS7 Location of new employment land.
Stagecoach Midlands supports the provision of employment land at the western end of Thickthorn, which could be served by our existing services; and also and allocation adjoining Warwick Technology Park (WTP).
The augmentation of employment at WTP could help create greater critical mass of demand for existing and future augmented services here, as well as reducing the average distances residents in the locality will need to travel to work from the new development overall. Shorter travel to work distances give scope for more sustainable modes, including bus services, to offer attractive options compared with personal car use.
It should be possible to address the current very unsatisfactory bus circulation and stopping arrangements within the existing Technology Park site, and the problems associated with on-carriageway and other inappropriate parking. Rigorous Travel Planning formulation and delivery should accompany proposals for this location to avoid exacerbating existing car-dependency and congestion. If a direct bus-only link could be provided from the north or north-east of WTP, through a Technology Park extension sited north of Harbury Lane, and into the wider Myton Garden Village beyond, this would make the resulting bus journey quicker than the car for many trips at peak times.
Chapter 5, Strategic Development proposals
Stagecoach Midlands has concerns that the strategic development proposals set out in the Strategy are coming forward through the development control system in an uncoordinated manner, in advance of the strategic Policy framework to guide this development being in place. These proposals now account for the majority of the strategic quantum. Having reviewed all of them, we find that in most cases, little consideration has been given to providing a sustainable high quality bus service within convenient walking distances of homes. We will make our separate representations on individual proposals in due course.
In general, Stagecoach Midlands believes that the density proposals do not support high-quality public transport provision. Within an average density of 30-35 dwg/Ha Master Plans should make provision for higher density along proposed bus corridors, even if this is offset by lower densities in the more remote areas.
Myton Garden Suburb: We are aware that a formal application has been submitted by the promoters ref W13/1016/OUT, for the bulk of the proposed allocation west of Europa Way, and was registered less than a week before this consultation closes.
This proposed allocation offers by far the most compact urban form of the sites identified in the Revised Development Strategy. In the view of Stagecoach Midlands, this site is the most critical to the success of the proposed Strategy. This is because it sits between the existing urban area, including Leamington Town Centre, and most of the proposed new strategic development. The main new strategic bus corridor is proposed to run either alongside or within the site. En-route, this corridor serves key destinations such as the Station, Morrisons, Leamington Shopping Park, existing employment at Europa Way, and the existing and expanded Technology Park, before continuing to serve the greater portion of residential development proposed in the Strategy.
Creative and imaginative urban design and master planning could deliver bus priority through or alongside the development, thus unlocking the viability of:
* The proposed virtual Park and Ride
* The new bus route
and by extension all the other public transport initiatives supporting the strategy
By linking together the Technology Park, its extension, the Park and Ride, and the residential area using a dedicated bus-only link through or alongside the development to create a bus priority route to Europa Way; the opportunity will have been taken to protect and exploit sustainable transport modes in line with NPPF paragraph 35.
A number of alternative approaches within the control of the promoters of Myton Garden Village could secure this outcome, including:
* peak bus priority along the dualled Europa Way, with the nearside carriageway being a bus lane at peak times.
* An additional bus lane or dedicated bus road provided over and above the dualling of Europa Way for general traffic
* A purpose designed bus corridor within the Garden Suburb, which may be used by vehicular traffic for portions of its length, but with a bus gate or gates to prevent rat-running.
Without such measures, we believe that the Strategy as a whole will only perpetuate and exacerbate the existing car-dependence in this area, in direct contravention of NPPF. Such an approach would be unsound, as it would be inconsistent with national policy.
South of Gallows Hill: Stagecoach Midlands supports this allocation in principle. The initial proposals made in a formal outline application by the developers for the eastern portion of this area did not anticipate bus services entering the site. The road layout would involve excessive circuity and only allow buses to serve the far edge of the development, which would mitigate strongly against effective and attractive bus service provision.
Those proposals have recently been withdrawn. We submit that any future master planning approach for this site and the land to the west, should be comprehensive, and assume the retention and enhancement of the existing bus routing, with good, well-surveilled pedestrian links to quality bus stops provided on Harbury Lane, spaced between 280-330m apart. This justifies higher densities on the northern edge of future proposals.
Proposals here should help support high-quality links from the area towards Warwick and thus can be considered to support the consolidation of demand on an existing public transport corridor.
We agree this area is less suitable for employment-led development, from a public transport perspective, not least because we believe it is more operationally expedient to provide the P&R and the Technology Park extension to the north of Harbury Lane, immediately adjoining the Technology Park and its extension.
West of Warwick Gates: Stagecoach supports this allocation in principle. Stagecoach Midlands reiterates that this site needs to make provision for high-quality roadside infrastructure and associated pedestrian links to them if the site is to be sustainable, and the overall Transport Strategy is not to be undermined.
Lower Heathcote Farm: We note a formal planning application was made for the northern portion of this site. Stagecoach Midlands notes that the promoter has made no provision for a bus service to penetrate the site directly or indirectly in those proposals. These have now been withdrawn. We found this omission most concerning. We submit that any future proposals for this land should assume the retention and enhancement of the existing service along the existing route/s, with attractive pedestrian links to quality bus stops provided on Harbury Lane. This approach justifies higher densities on the northern edge of future proposals that come forward. As a corollary it may be appropriate to reduce densities at the southern edge especially if these plots end up being outside a reasonable 400m walking distance of stops on Harbury Lane.
This would also support wider urban design and planning objectives.
We object to the development footprint extending further south onto land beyond the initial application site, as this land is well over 400m away from Harbury Lane and will not be within reasonable walking distance of a good bus service.
Former Sewage Treatment Works: Stagecoach Midlands objects to the proposed allocation. The Company does not see that a viable bus service could be provided, as this area could foreseeably be within 400m of a quality public transport corridor. Planning applications made on adjoining land to the east (Grove Farm) and west (Lower Heathcote Farm) make no apparent provision for an efficient bus route linking through this land. In any case, as discussed above, even if a comprehensive approach is taken to deliver a bus corridor south of Harbury Lane, this would draw any service away from the existing development north of Harbury Lane, or lead to the splitting of the provision such that the frequency of service offered would not be sufficiently high to be attractive. We therefore submit that, with the possible exception of some limited development on the northern edges of the site, this option is not sustainable.
Grove Farm: This site is not currently within easy reach of existing bus routes operating at regular high frequency. It is possible that a new service might be provided along Harbury Lane to the north of the site. Alternatively the existing hourly X18 running to the east of the site offers a much more direct route to the town centre, and might be augmented. We note an application for an initial 220 dwellings, all within 400m of Harbury Lane, is already submitted (W/13/0036/OUT). We can see that the layout affords a potential link to land to the south. The full quantum proposed, alongside proposals to the NE at Woodside Farm, might support the provision of a new local bus service, or a wider network recast to improve local bus frequencies serving the site.
However while in landscape terms this site functions as a unity with proposals to the west in particular, and equally adjoins the urban area, it will be much harder in this area to take advantage of the bus service improvements serving the wider area proposed by WCC. We consider this site less sustainable in terms of making best use of existing bus services, or logical improvements to the local network. We believe developer contributions from this site, and Woodside Farm, would be justified to kick-start a much better frequency of service on the Tachbrook Road corridor serving both this site and Woodside Farm, over and above those already being sought by WCC.
Woodside Farm: We note the site is the subject of an undetermined application W/13/0776/OUT. This site is relatively hard to serve directly by public transport. Providing a bus turning circle within the site, in line with the current proposals submitted earlier this year, or a bus-only gate giving through access to Harbury Lane, might achieve a 30-minute commercial service at final build-out when combined with the full quantum at Grove Farm, and a suitable means of running buses within the wider Grove Farm development. We recognise an existing PRoW offers direct access to our existing G1 Goldline service, but its width and quality is very poor, and many dwellings will be beyond the limits of a 400m walk to the stops on Coppice Road.
In our view, as stated for Grove Farm, additional proportionate developer contributions might be secured towards kick starting a new or augmented bus service via Tachbrook Road running at least every 30 minutes, and preferably every 20 minutes, serving these sites, and the poorly-served eastern end of Warwick Gates.
Employment Site Option 2: As noted above we support this option over a site south of Gallows Hill, subject to effective linkage both between the existing Technology Park and the site; and also the proposed residential development further north at Myton Garden Suburb. As discussed above we see a number of means whereby a creative and effective solution might be achievable.

Chapter 5.1: South of Leamington Infrastructure requirements
Stagecoach Midlands objects to the infrastructure strategy as the measures would not deliver a high quality public transport service and is thus inconsistent with the objectives of the strategy.
We have been previously notified by WCC of its intentions and approach to securing bus service improvements in support of the Strategy. We broadly concur with the overall shape of the strategy.
However it is clear to us that the 15% mode shift sought demands much higher bus frequencies, in particular on the virtual Park and Ride services. This would demand the pump priming of additional vehicles, above the four for which WCC is seeking funding.
Not least, the additional development quantum south of the towns that that RDS now proposes, demands significant additional capacity to achieve the required mitigation. Today the bulk of our town services operate with 38-seat midibuses. A 20-minute frequency would offer only 112 one-way seats per hour to Leamington. Full sized single decks would offer up to 46 seats per journey. If the Park and Ride is to be successful, and secure a significantly higher bus mode share from new residential development, which accounts for up to 3195 new dwellings and a new population of about 7,200, this capacity will not be sufficient
In particular we believe that a second new direct service needs to be offered via Europa Way and there must be sufficient bus priority to ensure that the speed of the service is attractive enough to encourage its use by the residents of this area.
We also strongly endorse WCC's view that a Park and Ride needs to be an integral part of the wider bus network to be viable.
We consider that a 20-minute direct and 30-minute indirect service to Leamington town will be not sufficiently attractive to persuade motorists passing the P&R site to use the service, or encourage local residents to make use of the facility. The time penalty associated with waiting for a bus is likely to be, or perceived to be, too high. Experience across Stagecoach operations shows that urban services ideally require a "turn up and go" frequency of between 10-12 minutes to provide an attractive choice for casual bus use by customers who have a car available. A 15 minute frequency is the absolute minimum service that might achieve this goal.
In addition to be financially sustainable the proposed Park and Ride site must be of sufficient capacity to cope with the existing pressure on parking at WTP, the proposed new employment park and shopping, casual leisure or tourism visits. We believe that a greater provision is warranted than the 500 spaces proposed due to the above demands. We look forward to working with the Council's consultants in further exploring how Park and Ride could be made to work successfully, through a robust and comprehensive design and operational approach.
Developers south of Warwick are also currently being asked to fund an additional bus resource on service 68. This service is now partly supported by WCC between Warwick Gates, Warwick town centre, and points further west. It is a 30-minute frequency service designed principally to meet essential socio-economic needs. Both in terms of frequency and routing, the service is not attractive to existing car users.
We now understand from the RDS and supporting WSTA phase 2 and 3 that the additional bus for which WCC is seeking funding, is merely to maintain the existing frequency as journey speeds slow down along what is a very long route. This is not what we, and some developers' consultants, have been previously led to believe. This no doubt arises from an assessment of the congestion produced by the proposed development; to allow further diversions into the Park and Ride; and provide possible extensions to serve some development roads. Stagecoach Midlands questions how this is either financially sustainable after a subsidy period ends, of how far such a service will perform much meaningful mitigation. This measure cannot be considered a service enhancement.
A 30-minute service 68 would not be able to perform a meaningful Park and Ride function between the proposed virtual P&R and Warwick, given that if a bus has just left, it would be as quick for a reasonably able person to walk the 1900m to Warwick Town Centre.
There is a large inconsistency between the Park and Ride service specification set out in the Revised Development Strategy, and that actually modelled by WSTA to develop and test a credible highways impact mitigation package. The WSTA Phase 3 model assumes a 9-minute bus frequency to Leamington and 12 minute to Warwick. From what we can ascertain in the Consultation Document, the Strategy and associated infrastructure schedule is seeking funding to maintain a 30-minute frequency on service 68 to Warwick and a new 20-minute frequency service to Leamington. The discrepancy between the RDS proposal and the supporting evidence base offered by WSTA is considerable, and we would appreciate clarification.
The Councils' own evidence makes clear within the results of the WSTA Phase 3 model runs, that should the P&R-based mitigation strategy fail, the implications for the wider network are very serious. This is demonstrated by the queue length outputs, and the average traffic speed outputs, presented at section 9 of WSTA phase 3, and attached appendices D-G. There appears to remain a significant risk that if congestion rises further this will create a vicious spiral of lower bus use, higher costs, and ultimately service reductions, aggravating the problem.
Stagecoach Midlands also wants to highlight the significance of the tradeoffs between the costs of on-site and off-site highways and engineering measures, other necessary infrastructure, and the delivery of other policy objectives.
We realise that the proportion of affordable housing provided is particularly liable to reduce to redress the difficulties of overall development viability.
This is very relevant to the robustness of the Plan, in terms of the opportunity to make best use of sustainable transport. We recognise that the 40% affordable housing target aspired to by WDC is relatively high. Experience nationally is starting to make clear that this does support generation of much higher bus service patronage on new developments.
In order for the package of additional bus services to the area to be sustainable long term, it is very important that the maximum affordable housing quantum is delivered. However, we can already see publicly available detailed evidence, in the form of the viability assessment provided by the applicants at Myton Garden Suburb attached to application W/13/1016,that a level only half that aspired to, may actually be deliverable based on the emerging infrastructure strategy.
On the basis of the above issues we object to the Infrastructure strategy, as it makes little or no explicit provision to rebalance modal dependence in favour of public transport. There is little provided in the way of bus priority and there is a risk that the impacts of the Strategy may undermine current bus operations.
Achieving mode shift and a parallel reduction in operating costs through higher vehicle productivity is of the essence in delivering the optimised transport strategy for the area. We are thus very concerned, that no mention is made of comprehensive measures to assist public transport and redress the current conditions in the area today that all favour personal car use over more sustainable modes.
It should be noted that today a disproportionate level of bus operating mileage within the area earmarked for strategic growth needs to financially supported, compared with the rest of Leamington and Warwick, where services are generally fully commercial. Thus the Strategy needs not only to deliver augmented service that can credibly be sustained through revenue alone at the full build out period, but to recover a modest deficit situation.
The current difficulties operating bus services in the proposed growth quadrant arise to a great extent from historic approaches to land use and urban design. Previously, planning did not make any provision for the creation of effective bus routings. In fact, master planning and detailed design of streets have led to a situation where bus services have had to be retrofitted on some roads within the Warwick Gates development that are barely able to accommodate the vehicles. There is virtually no provision of high-quality roadside infrastructure in the wider area. Any perpetuation of this approach would be inconsistent with NPPF.
We therefore welcome that the Plan Strategy makes explicit reference to high-quality bus stop infrastructure, at least incorporating high profile flags and timetable displays, a suitable boarding area to offer level access to the disabled and infirm, and additionally, high quality shelters where appropriate. We would urge that this takes a more prominent place within the final Plan. Given the difficulties encountered retrofitting bus stops after initial consent we strongly urge that sites are agreed as part of initial master planning at Outline submission stage, where urban design and effective pedestrian accessibility can be considered with bus stop location in the round, and not at the determination of Reserved Matters.
We also support WCC's design standards for residential streets (2002) which requires 6.5m widths to accommodate bus routes, or 6.2m where on-street parking bays are provided. We recommend tracking for 12.2m Scania K230UB or Optare Versa V1200 single deck buses should be assessed to test all proposed bus routes within submitted layouts for fitness. Effective and efficient bus operation means that routes for buses should avoid multiple changes in priority, and sharp bends. Equally, tight radius corners, however subtle the turn, cause buses disproportionate difficulty, and we recommend they are avoided.
Chapter 5.2 Sites at Whitnash/South of Sydenham
We object to the proposed infrastructure requirements as we believe that they will be insufficient to facilitate the provision for sustainable bus service.
The now-consented appeal site south of St Fremunds Way cannot be served by a further extension of service 67, as a further vehicle resource would be needed. Much less will be possible to serve an additional 300 units to the south, for which separate access is envisaged, and therefore an entirely separate bus route would be required. As outlined above, merely extending services into this area at existing limited frequencies will require substantial additional resource, the costs of which, if developer-funded, would neither meet CIL Tests of reasonableness across such a limited housing quantum, nor would it likely to be commercially sustainable at full build out.
As we have said elsewhere, without a bus link across the railway offering scope to tie this area into the wider network to the west we do not see how this proposal can be considered sustainable.
Final Comments
Stagecoach Midlands is very aware that land-use planning must resolve a very large number of conflicting objectives and interests, to the ultimate benefit of the community.
The Company also recognises the particular challenges involved in today's economic climate, and equally respects the plan-making efforts sustained by both Councils and other stakeholders over a very considerable period to date, that have led to the current proposals.
We trust that Warwick District Council and Warwickshire County Council recognise that we are very willing to play an active and constructive role in further shaping the Development Strategy, as key stakeholders in securing sustainable development now and into the future.
Stagecoach Midlands would be happy to meet with representatives from the two Councils, developers and their respective specialist consultant teams as required, to assist in achieving the optimum development strategy for Warwick District over the next 20 years, and to help ensure that the objectives of sustainable development are met in the detailed design of the development proposals.

A new Local Plan will be examined by an Inspector to ensure compliance with the NPPF.
6. says "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system."
The plan will have to be sustainable in these terms.

2. The existing 2007 local plan is, by virtue of NPPF 211, "not to be considered out‑of‑date simply because it was adopted prior to the publication of this Framework." And further NPPF212. says "However, the policies contained in this Framework are material considerations which local planning authorities should take into account from the day of its publication. The Framework must also be taken into account in the preparation of plans."

3. NPPF215 requires that "due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework (the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given).

4. The existing local plan was adopted in 2007 following a Public Inquiry during 2006 into objections to the proposed plan. The Inspector produced a 562 page report. Some of the issues are relevant to the new local plan proposals. Some senior Planning Officers seem to be of the view that because the current local plan was adopted in 2007 under the 1990 Town & country Planning Act Part II, it is of less value than a plan adopted since 2004. It needs to be pointed out that the Planning & Compulsory Purchase Act 2004, which came into force on 13th May 2004, did, by virtue of Schedule 6 of that Act, amend the Town & Country Planning Act 1990 to take into account changes made by the 2004 Act. So, for the purposes of NPPF214, it was in accordance with the Planning & Compulsory Purchase Act 2004 when the current local plan was adopted in 2007.

5. The local plan was adopted only 6 years ago. It settled many questions of concern for the community, in effect setting a contract with the community, up on which many people made decisions about their lifestyle arrangements. The Revised Development Strategy with a dramatic change to the size of the district and the concentration of very large amounts of new housing on land that is currently subject to Rural Area policies, is seen by many as a breach of that contract. As a result there is much concern and indeed, anger, at the proposals being consulted on and in the way that the door has been left open by the District Council for planning applications to be made that negate the purpose of any local plan and the consultation process to establish it.
The purpose of Local Government is to serve the community in the district that it covers. It is not to impose in a dictatorial manner changes that will erode the quality of life of those that live in that District unless there should be a very good set of reasons that carry greater weight than maintaining and improving the Strategic vision of the authority. At the many meetings that I have been to in the last 6 weeks, I have not found anyone that supports the proposals.
6. Since the Inquiry was only 6 years ago, I would like to draw your attention to certain key findings of the inspector, particularly where he talks about the plan after 2011.
In paragraph 11.3.8, in respect of the housing land supply position and of the need to allocate sites for housing, he finds "This Local Plan only covers the period to 2011 in the absence of firm housing or employment figures for the period beyond. The housing figures derived from the RSS for 2011-2021 are indicative only. Nevertheless, the District Council is able to show that there is no need to identify further housing sites. The balance of 2,210 dwellings to be provided between 2005 and 2021 equates to 138 dwellings per year. The District Council's estimates of windfall sites (based on past trends and emerging Local Plan policy) equate to an annual average of 282 dwellings in the urban area and 11 dwellings per year in the rural area. On the basis of these figures, I am satisfied that the District Council is justified in not identifying sites to meet the requirement to 2021. "

In paragraph 11.3.10, in respect of whether the Plan should identify a 10 or 15 year supply of housing, he finds that "New Table 5 of revised Appendix 2 shows how the residual housing requirement for the period 2005-2021 can be met. This particular objection is therefore satisfied. "
Table 5 in appendix 2 of the 2007 local plan states the following

source Dwellings
RSS housing requirement 2001 - 2021 8,091
Dwellings completed 2001 to 2005 3,324
Remaining dwellings to be provided 4,767

By the end of 2011/12 the dwellings completed had increased to 6,084. Deducted from the original requirements this leaves 2,007 remaining to be provided by 2021.

If 2,007 is the plan for 10 years, then for 18 years until 2029 it might be 200x18= 3,600.
The latest Hearn figure for the 18 years is 8,500 persons (see section 8 below) or 3,705 dwellings, so it looks as though we should be getting back the anticipated plan.

This ties in with census findings

Census House
holds % increase Homes built Running % increase population % increase Running % increase
1991 (to 1995) 48,202 856 116,522
('96 - '01) 3,537
2001 ('01 - '05) 53,356 10.69% 3,324 125,931 8.07%
2011 ('06 - '11) 58,679 9.98% 2,760 21.74% 137,648 9.34% 18.13%

The 21.74% increase in households compares with 15.32% over the whole of England for the same 20 year period. So The District has not been lagging behind but has done more than most.

7. So how did 2,007 become 12,300? Somehow in 2008 the RSS came up with a figure of 8,300 for the next 20 years up to 2029. That caused demonstrations outside the Council offices. Then came the banking and economic crisis and a change of government, with the abolition, eventually, of the RSS. Views were sought from the public and 58% agreed low growth. The first consultation was for 10,800 homes, higher than the RSS. This was rejected by 87% of respondents. A reasoned assessment based on ONS data was done that indicated a figure of 5,400 homes by 2029 was the housing need for the locality. By this time we also had the Localities Act 2011. The intention of Government was to give local people a chance to influence the way that development grew. The NPPF, in describing the way that local plans should be prepared is clear that -
150. Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities.
151. Local Plans must be prepared with the objective of contributing to the achievement of sustainable development
152. Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued.
154. Local Plans should be aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where.
155. Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.

These are important matters that the plan so far fails to do. The vision and aspirations of the local communities, the definition and implementation of sustainable development to achieve net gains on all three dimensions thereof avoiding adverse impacts on any are not only not demonstrated, they seem to be ignored.
Local plans should be aspirational but realistic and address the spatial implications of change. If 2,007 homes by 2021 was considered to be realistic by the Inspector in 2006/7, and shown to be so by the District council at the time, what are the reasons for the unrealistic numbers now? This was only 6 years ago, so within living memory.

With regard to 155., local plans should as far as possible reflect a collective vision and a set of agreed priorities for the sustainable development of the area, collaborating with neighbourhoods, local organisations and businesses. A wide section of the community is engaged and would wish that it was proactively so. But this requires a listening district council.

8. 156. Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver the homes and jobs needed in the area.

Homes and jobs go hand in hand.

In December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn updated the forecast for population growth. It starts with the following statement
5.52 The projection based on past population trends (PROJ 5) indicates modest population growth of 6.2% over the 18-year plan period - an increase in population of around 8,500 persons. Comparing the trend-based projection in this report with that contained in the SHMA we see that population growth would now be expected to be lower. This projection suggests an annual increase in the population of 473 people which compares with a previous estimate of 914.

The reasoned assessment of 5,400 homes needed by 2029 included migration trends as well as natural changes due to births and deaths, totalling 590 persons per year. Now Hearn have used later data that shows 473 persons per annum. ONS data is based on 25th September 2012, 3 months before Hearns report. It should be expected that when it is brought up to date it will use the same data as Hearn or possibly even later.

The Economic and Demographic Forecasts Study prepared by GL Hearn also states that

4.5 The District has a jobs density of 0.95 - this means that for every person of working age (16-64) living in the District there are 0.95 jobs in the District. This is significantly above average for the West Midlands or England (0.75 and 0.78 respectively). Overall there is a relatively good jobs-homes balance currently.

The conclusion I draw is that until the joint SHMA is received, the 12,300 household cannot be considered as a valid consultation. Across the neighbouring authorities, jobs ought to follow unemployment so far as it is sensible to do. Since our unemployment count is very low, and job availability is still very fragile, then building a larger volume of homes than we have ever done does not seem to be a good strategy. It could give us a dramatic employment problem.

9. Duty to cooperate with Neighbouring authorities - I understand the Inspectors rejection of Coventry's proposed plan and it clearly ties in with the joint SHMA. I note that Stratford is not part of the joint SHMA and wonder whether, due to the Gaydon dimension, which will invalidate their plan and possibly our joint SHMA as well. Since Gaydon to Nuneaton is seen as the motor industry technology banana by the district, that may be the reason for the ambition for jobs and homes in Warwick. But if Gaydon has a new town for JLR, coupled with the proximity with Banbury, then Warwick's need to grow is less.

10. Maybe part of the plan is to grow homes to get new homes bonus. But this is not a material consideration in NPPF terms. It is not a good business plan either, because the infrastructure needed to support a 29,000 or so population increase has yet to be provided. I note that the CIL paper acknowledges that there will be a funding gap unspecified. I have no detail to work with, but some quick guesstimates indicate that there could be a £100m capital cost shortfall between total public infrastructure costs (County, District, NHS, & central government) compared with CIL, section 106 and other charges to the developers after accounting for 40% number reduction for CIL-less affordable housing and approvals already given.

With a reduced housing target of 5,400 the infrastructure need would to be less because it is a smaller volume and can be spread more evenly around the district spreading not concentrating infrastructure overload.

11. The planning Inquiry in 2006/7 looked particularly at sites both in Areas of Restraint and subject to rural area policies. The decision made then needs to be seen in the context of the NPPF54, 55, 109 to 125. In particular,
NPPF54 agrees with the existing local plan rural area policies by requiring that, "In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs."

NPPF55. Would extend those policies " To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby." To do this, the local plan should have specific rural area policies. It may be that neighbourhood plans would customise such policies for particular reasons relevant to that parish.

NPPF109 requires that "The planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
* remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

NPPF110 requires that In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework.

NPPF111. Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.

NPPF112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.

The sites selected for development to the south of Warwick & Leamington do not appear to meet these requirements. The councils own Landscape consultant in 2009 has some very strong recommendations that should be taken into account.

Looking at the particular sites the inspector made the following conclusions.

11.1 Woodside Farm should remain in an area of restraint. In a lengthy and detailed consideration he concluded that
10.11.41 The AoR designation has been carried forward from the adopted Local Plan. It was established to maintain separation between Bishops Tachbrook and Whitnash. When preparing the earlier Plan the District Council successfully argued that any extension of built development to the south of Whitnash, beyond the ridge line that defines the present edge of the town onto the south facing slope, would create a major incursion into the countryside that would be highly visible and intrusive. Since that time a number of physical changes have occurred in the locality. Extensive housing development has taken place at Warwick Gates on the opposite side of Tachbrook Road. Although anticipated through a Local Plan allocation, this has affected the character of the area by bringing development to the west as far south as Harbury Lane. In addition, playing fields, open space and woodland have been laid out to the east of the objection site giving enhanced public access, and overhead electricity lines have been put underground. The objector argues that in light of these changes the objection site should be excluded from the AoR. The request is supported by a Landscape and Visual Impact Assessment and a Development Principles Plan.
10.11.42 I consider that the AoR still performs essential functions. It helps safeguard the character and setting of Whitnash, prevents urban sprawl and assists in maintaining the integrity and separation of Bishops Tachbrook as an independent settlement. The objection site is an important element of the broader AoR. It occupies an elevated position with views of it obtaining from certain directions. They include limited views driving northwards along Tachbrook Road from Bishops Tachbrook, from Harbury Lane to the east and long distance views from public locations on the northern edge of Bishops Tachbrook. From each of these positions housing development would be clearly visible for many years while structural landscaping matures. This would intrude into the rural surroundings and noticeably reduce the open gap that remains between Bishops Tachbrook and the urban area.
10.11.43 I conclude that this land should remain open as part of a more extensive AoR and that it should not be allocated for housing development within the Plan period or be identified for longer term development.

I concur with the Inspectors view. It is an essential part of the distance between Whitnash and Bishops Tachbrook and an important part of the valued change from town to country along the Tachbrook and Oakley Wood Roads and in particular their junction with Harbury Lane going east rising up through the trees up a double incline hill some 15metres high as the road reaches Mallory Court on the right hand side. Housing on Woodside would be completely counter to the NPPF

11.2 Fieldgate Lane/Golf Lane should remain in an area of restraint. In a lengthy and detailed consideration he concluded that

9.4.16 I take a rather different view. Looking first at the boundary of the AoR, I acknowledge the previous Inspector's uncertainty about whether the golf course and land to the east contribute to the AoR objective of preventing Whitnash from merging with Bishops Tachbrook. However, the south-western part of the golf course is highly visible from Harbury Lane where it forms a backdrop to the new playing fields and pavilion such that any development there would significantly close the gap between these settlements. Moreover, while the rising nature of the ground at Fieldgate Lane/Golf Lane from north to south means that development would not be visible from Bishops Tachbrook, it would be clearly seen from southern parts of Whitnash where the land contributes to the rural setting of the town. It would also, I feel, be intrusive in long range views from east of the railway line. I find that the whole of the area (that is, the golf course and the land at Fieldgate Lane) contributes to the objectives of the AoR. The land has a role to play in the structure and character of this part of Whitnash, provides open areas in and around the town, safeguards its setting and helps prevent urban sprawl. In addition, the south-western section of the golf course maintains separation between Whitnash and Bishops Tachbrook. Consequently, I see no case for excluding the golf course or the Fieldgate Lane site from the AoR. As regards land south of Harbury Lane, this land forms part of the sensitive gap between Whitnash and Bishops Tachbrook. But I believe it to be less at risk of development because Harbury Lane/Gallows Hill provides a strong boundary to the urban area. In my view, there is no need for AoR designation to extend south of Harbury Lane.

9.4.18 Finally, the objector considers that as the Fieldgate Lane site is bordered by housing to the north and south it should be considered as part of the urban area, rather than one where the Plan's Rural Area Policies apply. I do not agree. As the District Council points out, all rural areas have an urban edge. In my opinion, that boundary is properly set by the suburban housing to the north of Fieldgate Lane.

9.4.19 The objector's proposals were subject of the Omission Sites Consultation undertaken in January/February 2006. Responses received from Whitnash and Bishops Tachbrook residents, CPRE (Warwickshire Branch) and Whitnash Town Council were against any removal of the golf course or Fieldgate Lane site from the AoR, any residential allocation at Fieldgate Lane and any exclusion of the proposed development site from the application of Rural Area Policies. I note that 251 responses were received against the Fieldgate Lane site and 496 objections in relation to the golf course (of which 240 were by way of a petition from members of the Leamington and County Golf Club). This is a clear indication of the strength of local feeling.

Residents of Whitnash agree with the inspector that the site is part of the Golf course, Woodside Farm Area of Restraint set out by paragraph 9.4.19 of the inspectors report. I agree and object to this proposal.

11.3 Grove Farm (called Harbury Gardens by the developer) should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & west of Oakley Wood Road.

In the 2012 consultation, this site was described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge as part of the separation of Whitnash and Bishops Tachbrook was welcomed. Dismay ensued with the current 2013 proposal for 200+ homes.

Reacting to an objection seeking this land be included in an area of restraint, the inspector found that

9.4.4 I agree with the District Council that a cautious approach needs to be taken in respect of the AoRs in order to avoid their devaluation and to ensure that they perform a specific function. Unlike the other AoRs included in the Revised Deposit Plan, much of the land identified by Bishops Tachbrook Parish Council (even with the reductions in area put forward at the hearing) is relatively remote from the urban area and not under immediate threat from urban expansion. The gap between Harbury Lane and Bishops Tachbrook is about 1.4km compared with only 300m or so between Leamington Spa and Radford Semele. Although there are objections before this inquiry that seek to allocate or designate sections of the land in question for other uses, and anecdotal evidence of options taken by developers, this is by no means unusual when a Local Plan is under review. I consider that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for additional protection. It is not the function of AoRs to give an added layer of protection to open countryside where appropriate policies already exist to control development. Should land have to be released in the future for urban expansion then the District Council says that this exercise would be done by a review of options on all sides of the urban area including sites subject of Green Belt and AoR designation. Land south of Harbury Lane outside an AoR would, it is argued, be placed at no disadvantage.

9.4.6 I conclude that while additional development has taken place to the south of Leamington Spa during the last 10 years or so since the previous Local Plan Inspector reported, his findings remain pertinent. Given the strength of the Rural Area Policies of the Plan, the current housing and employment land supply position and the degree of protection afforded to the most critical areas by the AoRs already identified in the Revised Deposit Plan, there is no need for a further AoR south of Gallows Hill/Harbury Lane. To designate such an area in the absence of any serious threat would be premature at least and at worst a misuse of policy.

The Inspector clearly considered that rural area policies were strong enough to prevent such development. Nothing has changed that alters the communities view. Housing in this location will be very visible across the Tachbrook Valley from the south, being on the ridge line as can be seen from this photograph. Housing will be prominent half way down the field in the distance. The top of roofs to Warwick Gates can just be seen behind the hedgerow on the horizon and stretch from the coppice of trees on the left side of the picture to Grove Farm buildings to the right of centre of the photo. The photo was taken from the public footpath to the Asps from St. Chads Church and this is a prominent view along most of the path. The suggested country park to the south of the housing, because it is on the slope down to the brookstray will not hide the housing as it will be the same height as the trees that can be seen running along the Tach Brook from left to right. The NPPF paragraphs quoted at the head of this section are intended to conserve, protect and enhance landscape such as this wonderful piece of Warwickshire.



It is essential that this piece of landscape is protected as there is no credible case for housing in this location. So we object to the proposal in the 2013 consultation and support the 2012 consultation to keep this area as a green wedge. In my view, however, it does not need to be converted into any sort of country park, at considerable cost no doubt, as it is perfectly acceptable as it is. This would retain a valuable piece of agricultural land, meeting the needs of the present without compromising the ability of future generations to meet their own needs.

11.3 Lower Heathcote Farm should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & east of Europa Way.

In the 2012 consultation, this site was also described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge running from Castle Park in the west through to Radford Semele incorporating paths along the side of the Tach Brook presents recreational potential for village and urban walkers. Dismay ensued with the current 2013 proposal for 720+ homes.



The photograph shows the view north across the Tach Brook Valley from New House Farm. Housing will come down from the hedgerow along the Harbury Lane covering the top half the field between that hedgerow and the trees along the brookstray, the tops of which can just be seen. The undulating form is a 'trademark' of the rolling Warwickshire countryside that is part of the tourist attraction experience on the approach to Warwick Castle from the south and is seen as a backdrop along the Banbury Road. It is highlighted in the Morrish Landscape consultants report of 2009.

4.4 Paragraphs 109-125 of the NPPF outline conserving and enhancing the natural environment. They state that the planning system should contribute to and enhance the natural and local environment by protecting / enhancing landscapes; by recognising ecosystem services; by protecting/improving biodiversity; by avoiding pollution or environmental degradation and by remediating degraded land. LPAs should set criteria-based policies by which to judge potential impacts to wildlife, landscape, etc. and set out a strategic approach to green infrastructure in local plans.

This requirement expects that the new local plan will have such policies and implement them.

The landscape consultant also advises

5.1 Some of the elements that contribute to landscape character include the shape and scale of topography, the presence and pattern of natural geology, outcrops, water bodies and vegetation and, the patterns and features of man's intervention - including land management and settlement.
How and from where the landscape can be viewed greatly influences how it is perceived - so that the availability of access becomes influential in determining landscape character. A variety of views (long vistas, wide panoramas, framed focal points) generally adds to our enjoyment of a landscape. Landmarks are of particular value/interest in any landscape - even if they have disputed amenity value (e.g. Eden Court flats at Lillington).

This paragraph describes exactly the situation with this site. The landscape value of this area is very high. It has a large variety of views, long vistas wide panoramas and framed focal points. It shows an interesting shape and scale of topography. The brutal insertion of the development proposed is totally insensitive, tantamount to municipal vandalism. The existing landscape is an asset that everyone in Warwick District can enjoy and is part of the package that makes Warwick District a Great Place to Live, Work and Visit.

The Inspector "consider(ed) that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for the additional protection of an Area of Restraint. This set of policies should be included in the new local plan to meet the NPPF clauses referred to above.

11.4 The former Severn Trent Sewage Works between Lower Heathcote Farm and Grove Farm to the south of Heathcote Park is listed in RDS 5 and shown on Map 3. It claims to provide 225 homes.



This photo shows the site from the site across the Tach Brook Valley. It is the central greener area. At the top of the hill on the skyline there is a mature area of trees which provides a wildlife oasis to a number of mammals including deer, birds and woodland insects. The former sewage tanks are, according to old plans, many and closely aligned. The tank depths and ground contamination is likely to make this a difficult site to develop for housing and add to that the steep fall as the ground slopes down towards the brook it is unlikely to provide any practical housing land at all.

The site would however be an ideal site to develop as woodland as part of the low carbon environmental sustainability objective of the Councils Corporate Development Strategy. Carbon dioxide sequestration of woodland is calculated on the basis of 25m2 absorbs 1 tonne of CO2 per annum. If a normal house produces 4 tonnes of CO2 per annum, this provides sequestration for about 1000 of the homes to be built. Bishops Tachbrook Neighbourhood Plan is seeking sites of this nature within its boundary and will be including this site in discussions with neighbouring towns and parishes as part of its duty to cooperate with them. AS far as the NPPF is concerned paragraph 109 requires development to conserve and enhance the natural and local environment by remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

11.5 Land south of Gallows Hill between Europa Way and Banbury Road, north of the Tach Brook.

The northern section is the other half of the Tachbrook Valley and to build upon it would detract from the southern part which it has been accepted should be kept. Given that the RDS does accept that the Asps is an important part of the Warwick Castle approach, so is this northern section. it can be seen from the Warwick Castle Towers and the mound. Any development on this site will have a direct impact on the views available to visitors to the castle.

This photograph was taken from the top of Guys Tower in Warwick Castle, looking south-east, earlier this year and shows the site south of Gallows Hill in the foreground with two oak trees in the centre of the field and the hedgerows running along Europa Way. Behind the hedgerow there are fields of yellow oil seed rape which is the site south of Harbury Lane in 11.3 at Lower Heathcote Farm. To the right of the poplar tree on the left of the photo is the farm cottage to the former Heathcote Farm with, to its right, the roofs of the bungalows in Heathcote Park, mostly hidden in the trees. Beyond that are the trees bordering Oakley Wood Road with the hill rising behind them, through the Grove Plantation rising to Highdown Hill Plantation on the skyline. This is a view that has been available to Kings, Earls and visitors since 1395 when the Tower was constructed, so is significant for Tourism and should not be lost to development. No amount of landscape 'mitigation' will compensate.



The 2009 Landscape area statement by the councils Landscape Consultant Richard Morrish clearly concludes that

This study area is principally well preserved farmland that creates an attractive rural setting for the south side of Warwick and should be considered an important part of the setting for Castle Park. Any development that 'jumped' the Heathcote Lane / Gallows Hill frontage would set a major landscape precedent in extending the urban area so far south. Although it is considered that the Warwick Technology Park has possibly diminished the value of the Area of Restraint north of Heathcote Lane, its general style of low density development in a strong landscape setting makes for a reasonably successful transitional environment on the urban fringe - as do the adjacent school sports fields. To extend the urban area beyond these sites would make for a disjointed urban structure and possibly encourage intensified development at the Technology Park and around the schools. Smaller blocks of isolated development are also likely to be incongruous in this landscape.
Our conclusion is that this study area should not be considered for an urban extension and that the rural character should be safeguarded from development.

The Inspector at the 2006/7 Public Inquiry considered this site for employment purposes. In a lengthy and detailed consideration he concluded that

10.3.49 The objectors maintain that the Gallows Hill site would provide continuity in the forward supply of employment land beyond 2011. However, I believe it would be inappropriate to identify such sites now when the future employment requirements of the District are uncertain pending completion of the sub-regional employment land review and the partial review of the RSS. Until then, the RSS requires that greenfield sites, like this land at Gallows Hill, should only be released when there is no alternative previously developed land available. The WMRA, commenting on the Omission Sites Consultation, remarked that new sites being promoted involving the development of greenfield land "appear to be inconsistent with the principles of the RSS" and requested that the Inspector rigorously scrutinise such proposals. I agree with the District Council that as and when further greenfield land releases are necessary this should be done through a DPD where a full comparative assessment of all potential sites can be made in the context of a sustainability appraisal and following a process of public consultation. In this regard, I note that the objection site is classified as very good (Grade 2) agricultural land and that a full Transport Assessment would be required in respect of development on this scale. I believe that the ad hoc release of a large greenfield site like this located on the urban fringe and currently in agricultural use would not be in the best interests of the District. The Council's Local Development Scheme commits it to begin preparation of a Core Strategy DPD immediately following adoption of this Local Plan. That will tie in with completion of the partial review of the RSS, enabling up-to-date employment requirements for the District to 2021 to be accommodated.

10.3.50 I conclude that land at Gallows Hill should not be allocated under Policy SSP1 for employment (Class B1) purposes, nor should the site be excluded from the rural area defined on the Proposals Map. To do so would result in an over-provision of employment land relative to the Structure Plan requirement, at the expense of the surrounding countryside.

The site is shown in the RDS as residential and employment but this we believe is wrong because all the advice is that it should be retained as agricultural land with a high landscape quality, hidden for the most part behind hedges on Harbury Lane but with occasional glimpses through it at gates and breaks in the hedge. It is on the only high quality approach road to the Castle

12 Separation of settlements.

The District Council to date has rigorously resisted any development that reduced the gap between Bishops Tachbrook and Whitnash/Warwick. We believe that the NPPF requires the district to continue to implement those policies as part of the social role within sustainable development, supporting strong, vibrant and healthy communities.





13 Conclusion.
We strongly request that you reconsider the quantity of housing needed by the plan, limiting it to no more than 5,400 homes by 2029. This will produce all the homes needed by the locality, gives achievable 5yr land supplies through the plan period, reduces the infrastructure cost and spreads traffic volumes, avoids the need to take valuable greenfield sites and restores the confidence of the electorate in the local authority. It has been produced as an objective assessment, that takes all the requirements of the NPPF as well ONS projections into account, establishes a realistic employment strategy that recognises greater problems in neighbouring areas but allows a controlled and realistic amount of economic growth.
That should then mean that we have a sustainable local plan that will fit well into the limited space we have available.

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

I feel it necessary to object most strongly to the plans for new housing in the area "SOUTH OF WARWICK AND WHITNASH", the main problem being traffic
1) WOODSIDE FARM
My main objection to your plan for Woodside Farm is on the grounds of traffic and road infrastructure as the one and only entrance to the development would appear to be only a short distance from Ashford Road and directly opposite Othello Avenue.
Apart from the saturation of the areas roads at present, Othello Avenue is at present used as a high speed rat run to the areas of Tachbrook Park Drive and beyond to Leamington Spa and Warwick. The introduction of a housing project of 280 units would add significantly to the areas problems even if all traffic is "encouraged" to go via Harbury Lane to Warwick or via Tachbrook Road to Leamington Spa. I understand that a set of traffic lights with pedestrian controls was the likely scenario at the junction of the development and Tachbrook Road/Othello Avenue and that these would be synchronised with the Harbury Lane lights and the current pedestrian lights near Ashford Road. This would apparently also have some computer input from traffic flow in both directions along Harbury Lane.
This apparently is designed to make the traffic flow evenly, but this is not my experience in practice if other closely situated traffic lights with pedestrian control in the areas are anything to go by at peak times.
Even if these highly technical lights do work as they are intended to, I think all will be controlled by human nature and despite your assurances that it will be "better" for drivers to avoid Othello Avenue most people will still use this route. It was suggested to me that some traffic calming would probably be added to Othello Avenue in order to guide motorists away to alternate routes but in November 2012, I noticed 2 lots of severe ruts on grass verges near the already present "traffic calming roundabouts". Vehicles had obviously left the road at these points having failed to negotiate the 2 islands in question crossed the pavement and travelled a large distance along the adjacent grass areas - one of which was the children's play area - do I need to comment further!! From the length and depth of the ruts speed must have been a major factor but my main point is that if plans for traffic diversion are to come to pass the calming measures which I appreciate are the prerogative of the highways dept. and not yours need to be quite draconian. My suggestions would be very frequent speed humps or road narrowing with alternate give way in each direction, (slight inconvenience to residents as there is always a route off the estate, but major bar to those using it as a "rat-run"). Ignoring the "Othello Question" the area is already heavily blighted by traffic and despite improvements to the Banbury Road junction with Harbury Lane the traffic on this road is at saturation levels especially at work and school times.

2) GROVE FARM & LOWER HEATHCOTE FARM

Despite improvements to the Banbury Road junction with Harbury Lane the traffic on this road is at saturation levels especially at work and school times (not to mention Othello Avenue being used as a "rat-run"). I believe that the inadequacies of Harbury Lane along with further overload would inflame this beyond all acceptable levels, especially as the plan shows 2 PRIMARY SCHOOLS and possibly 1 SECONDARY SCHOOL in the area between Tachbrook Road traffic lights and Earl Rivers Avenue roundabout. I have looked at the map and infrastructure requirements (5.1.15) and can see no evidence for any alteration to this stretch of road. The traffic in the area is already (7.30am-9.00am & 4.30pm-6.00pm especially) at saturation point and the addition of 1520 houses plus 2/3 schools would be a formula for total mayhem. Accidents and inevitable injury and loss of life would not be a certainty it would become virtually mandatory!! Especially to huge volumes of children crossing Harbury Lane even with light controlled crossings with or without supervision.
The lights at the junction with Tachbrook Road are already used as a "starting grid" for "The Harbury Lane Grand Prix" and coming the other way with many motorists the trick seems to be to get up enough speed to clear those lights before they change back to red. My point here is that the current speed limit is often ignored, so even if it is reduced to 30mph I can foresee the same problems as highlighted above.

I have limited my objections mainly to traffic, but there are many more areas which could be raised in strong objection to your proposals.

3) OTHER AREAS OF CONCERN
The improvements to the junction of Gallows Hill with Banbury Road has made a great improvement, but all would be lost by the addition of 3000+ houses and more additions to Warwick Technology Park and the junction in its present form would become in the modern annoying idiom "not fit for purpose"! With respect to more vehicles needing access to The Technology Park, I see from map 3 that a grade 1 improvement is proposed for the entrance to the site and this is long overdue. However a glaring problem has been overlooked as the site has insufficient car parking space already without further expansion. Those of us who travel this stretch of road on a regular basis are all too aware of the large number of cars parked on the grass verge on the South side of Gallows Hill during work hours, obviously much to the annoyance of local farmers who have put up no parking signs by their gates. (There used to be a smaller problem on the North side but the resident there has put up wooden posts to stop the parking). Of course this problem will "go away" when the proposed building takes place on the South side - just one problem here - where will the cars be parked then?!
I can also see major knock on problems for Tachbrook Park Drive, where parking by HGV traffic blocks the road on a regular basis even at non-peak times. Quite often there are several large trucks and car transporters lined up on both sides of the road as there is little or no option for them to park at the delivery sites. I appreciate this is a commercially orientated road but not enough thought was given to parking facilities for loading and unloading. This situation will only deteriorate with extra traffic converging on the area. One might suggest removing the grass verges (those not ploughed up by encroaching HGVs) and providing loading bays. If total chaos is not to arise the whole road may need alteration including a cycle track between Heathcote Lane and Sainsburys if this building in the area goes ahead- more expense and another reason for not going ahead with this project.
I have limited my objections mainly to traffic, but there are many more areas which could be raised in strong objection to your proposals and the cost of all the required infrastructure improvements would seem prohibitive under present austerity conditions.
I appreciate, as previously mentioned that roads and their planning are the remit of The County Council, but all my points and no doubt some that I have missed, do I feel need serious consideration.

Finally I do not wish to be categorised as a NIMBY but all or most of the development is in the South Warwick Area (North of Leamington Spa having been abandoned -perhaps for political reasons if some press articles are to be believed). It seems that Warwick District Council is trying to make an issue of Green Belt Versus Green Field to find a reason for putting most the development in one area. The underlying fact is that in either case valuable Green Areas of once "Leafy Warwickshire" are to be sacrificed on the high alter of so called "Future & Sustainable Prosperity". I have to tell you now that a lot of people do not think that these plans will "Make Warwick District a Great Place To Live Work and Visit."

I am sending copies to Chris White, my local MP with whom I am already in touch

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WARWICK DISTRICT COUNCIL LOCAL PLAN Helping Shape the District
REVISED DEVELOPMENT STRATEGY Consultation response July 2013.
BISHOP'S TACHBROOK PARISH COUNCIL'S RESPONSE
Section 1
The Proposed Housing Numbers and the Assessment of the Availability of Housing Land.
1. Assessing the housing number to be included in the plan.
1.1 Bishops Tachbrook Parish Council, having studied this issue in great detail, is of the opinion that the 12,300 new homes proposed in the RDS, 1500 more than the number proposed in the May 2012 Preferred Options consultation, is not an objective assessment based on the latest projections for the population expected by 2021 and 2029. It is noted that it is more than the number that Coventry thinks it needs (11,373) and this is a city currently with population of over 316,000.
Although the high number might be aspirational it is not realistic, as it is beyond the physical capacity of the usable part of the district to provide it, the infrastructure to support it and the local economy to provide related employment. Because of the large amount of Green Belt in the district (80%) and the limited capability of the urban area to take very much more development, such a large amount of new housing is being allocated to the rural part of the district using greenfield land of equal or better value than the Green Belt. To compare with Coventry again, its area is 9,864 ha and has 132,700 dwellings giving an average of 13.47 dwellings per ha. Warwick has 28,288 ha but 80% is in Green Belt and 9% is part of rural Warwickshire. The remaining 11% or 3,111 ha has 60,427 dwellings, giving an average of 19.42 dwellings per ha. The Warwick figure needs detail adjustment to take out dwellings in the green belt but it shows that the Warwick urban area density is at least equal to or more than a densely populated city.
The district wide community cannot see this is going to achieve the Strategic Vision of the Authority "to make Warwick District a great Place to Live, Work and Visit," but can only conclude that it will be much worse at a range of levels.
The consensus not only within the Parish, but across the district is that this level of population growth, put simply, does not feel right. With census data showing that there has been an 18% population increase over the last 20 years (1991-2011), can a further 20% over the next 15 years really be required? Is a population growth increase from 0.9% p.a. to 1.33% really
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likely, particularly with the economy where it is at the moment and a long slow recovery ahead? How has the district arrived at this unrealistically high growth estimate?
1.2 We know that NPPF47 requires the number of homes to be provided to be objectively assessed using a proper evidence base. It is therefore important to make sure that the evidence base is up to date. The NPPF6 states that "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system." Therefore, NPPF 54 and 55 regarding housing in rural areas should be part of that objective assessment as well as NPPF 109 regarding the protection and enhancement of valued landscapes.
The Local Plan will have to be sustainable in these terms otherwise it will not be accepted by the Inspector. In our view the current consultation plan is not sustainable as so defined.
The proposed aggressive levels of housing growth proposed will require the loss of large areas of outstanding Warwickshire landscape. The unique value placed upon of this natural environment by previous planning inspectors and the District's landscape consultants as well as the inhabitants that live in and pass through it, is high and is discussed in Section 3.
1.3 It is also a question of the level of housing and population growth that the district can reasonably absorb, without undermining the quality of life for those that live here and irreparably damaging the historic context of Warwick district. In this regard, NPPF 10 requires "Plans and decisions need to take local circumstances into account, so that they respond to the different opportunities for achieving sustainable development in different areas."
1.4 Estimates of housing numbers for the future must be based on ONS statistical projections. These are based on historical data, medical records and estimates for migration.
The May 2012 consultation was based on the SHMA dated March 2012. In fact it was finalised in November 2011 and was based on 2001 census and ONS actuals and migration estimates up to mid-2010. The SHMA gave a range of example projections. They were all based on the trend based projection anticipating an average annual increase of 914 in the population over the 20 year period with 2031 population estimate being 156,959. The report showed the ONS 2008 based projection for 2031 as 165,852, a 19.6% increase, (2021 estimate being 152,742), based on the period 2003 - 2008 migration estimates.
1.5 The BTPC study took place during July 2012 (see Paper A, appended to this response). It resulted in an average annual increase of 590 estimating the
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census result as 136,093, with a 2021 projection of 141,904. When the 2011 census 1st release was available it became evident that ONS projections were high, as they predicted the 2011 census as 138,680, whereas it was 136,000. The statistical data needed review and this was done by ONS in September 2012, reducing the ONS projections to some degree. ONS Sub-regional population estimates and projections only go as far as 2021 and the 2021 projection is now 148,414.
1.6 In December 2012, G L Hearn produced an Economic & Demographic Study. This was able to use the mid 2011data and now the trend based projection was an average of 473 rather than 914 (as para 1.4). The 2021 projection is now 143,270 This study included Coventry but was not the joint study thought necessary by the Inspector of Coventry's proposed local plan, who considered that there was a duty to cooperate over a wider area.
1.7 BTPC are monitoring their study in the light of later data as it becomes available. The original study included for a 20year plan to 2031 with a full 5% contingency, (not a buffer brought forward from later years) rounded up to give 5,400 homes. If the 5,400 homes is kept as a target, spread over 18 years this gives 300 homes a year or a population growth of 695 and a 2021 potential population of 144,686. In the first monitoring year the actual growth was 451, assuming ONS estimates for migration are right. This is 244 less than predicted but is only a 1 year result.
1.8 The ONS projections will be updated in due course using the latest data, If Hearn's trend continues, a comparative fall is to be expected in the ONS projections. BTPC estimates that if the latest Hearn rate of change is applied to the last set of ONS figures, then the 2021 estimate will be 145,422.
1.9 The conclusion is that since 2011, the statistical data shows a reducing population projection which is hovering around the BTPC study result of 5,400 homes. Given the economic position, the increased control over migration by government, the levelling out of increased births due to mothers delaying families for career purposes and a similar slippage in deaths as people live longer, ONS projections for 2021 on which the District's plan must be based to satisfy the inspector, have come down from 152,742 in 2011, to 148,414 in 2012 and is estimated to fall further to 145,422 in 2013. For comparison, the ONS mid-2011 estimate was 137,736.
Taking the plan period of 2011 to 2029, for a trend based projection, Hearn's Dec 2012 estimate will require 3,708 extra homes for a 146,243 population, BTPC study providing 5,400 homes will give a potential population of 148,356 and the current ONS projection adjusted to Hearn's rate of change would need 5,970 homes for a total population of 151,431 all compared with the 2011 population of 137,648. In terms of housing numbers this reduces the ONS projection from the 2011 estimate of 12,150 homes, to the 2012
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estimate of 6,500 homes, which is anticipated, if it falls in line with Hearn's estimate, to drop to about 5,970 homes.
1.10 ONS estimates for internal and international migration are based on the best statistical data available. Because there is no count at point of entry to the UK, inward and outward movements can only be estimated from very limited data. The major indicator is the doctors register as it covers both groups, but this tends to take time to catch up with changes and is not complete. It was reported on 28th July 2013 by The Public Administration Select Committee that it had found ONS migration figures are "not fit for purpose". So although it is necessary to work to it, caution must be exercised. The joint SHMA should come up with the most up to date guide.
2. How was the 12,300 target arrived at?
2.1 The 12,300 homes target is not adequately explained in the RDS. The conclusion in RDS1.10 suggests that it may be due to the 2011 ONS data (12,130) but it may also have other objectives.
But for very many people in the district it is not believable. They remember that the existing local plan was adopted in 2007 following a Public Inquiry during 2006 into objections to the proposed plan. The Inspector produced a 562 page report. Some of the issues are relevant to the new local plan proposals.
2.2 Some senior Planning Officers seem to be of the view that because the current local plan was adopted in 2007 under the 1990 Town & country Planning Act Part II, it is of less value than a plan adopted since 2004. It needs to be pointed out that the Planning & Compulsory Purchase Act 2004, which came into force on 13th May 2004, did, by virtue of Schedule 6 of that Act, amend the Town & Country Planning Act 1990 to take into account changes made by the 2004 Act. So, for the purposes of NPPF214, it was in accordance with the Planning & Compulsory Purchase Act 2004 when the current local plan was adopted in 2007. If it were not so the Inspector would have said so.
2.3 The local plan, which is still up to date except where the NPPF is not in agreement with any particular policy, was adopted only 6 years ago. It settled many questions of concern for the community, in effect setting a contract with the community, up on which many people made decisions about their lifestyle arrangements. The Revised Development Strategy, with it's dramatic change to the size of the district and the concentration of very large amounts of new housing on land that is currently subject to Rural Area policies, is seen by many as a breach of that contract. As a result there is much concern and indeed, anger, at the proposals being consulted on and in the way that the door has been left open by the District Council for planning applications to be made that negate the purpose of any local plan and the consultation process to establish it.
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2.4 Since the Inquiry was only 6 years ago, BTPC would like to draw your attention to certain key findings of the inspector, particularly where he talks about the plan after 2011.
In paragraph 11.3.8, in respect of the housing land supply position and of the need to allocate sites for housing, he finds "This Local Plan only covers the period to 2011 in the absence of firm housing or employment figures for the period beyond. The housing figures derived from the RSS for 2011-2021 are indicative only. Nevertheless, the District Council is able to show that there is no need to identify further housing sites. The balance of 2,210 dwellings to be provided between 2005 and 2021 equates to 138 dwellings per year. The District Council's estimates of windfall sites (based on past trends and emerging Local Plan policy) equate to an annual average of 282 dwellings in the urban area and 11 dwellings per year in the rural area. On the basis of these figures, I am satisfied that the District Council is justified in not identifying sites to meet the requirement to 2021. "
In paragraph 11.3.10, in respect of whether the Plan should identify a 10 or 15 year supply of housing, he finds that "New Table 5 of revised Appendix 2 shows how the residual housing requirement for the period 2005-2021 can be met. This particular objection is therefore satisfied. "
Table 5 in appendix 2 of the 2007 local plan states the following
source
Dwellings
RSS housing requirement 2001 - 2021
8,091
Dwellings completed 2001 to 2005
3,324
Remaining dwellings to be provided
4,767
By the end of 2011/12 the dwellings completed had increased to 6,084. Deducted from the original requirements this leaves 2,007 remaining to be provided by 2021.
If 2,007 is the plan for 10 years, then for 18 years until 2029 it might be 200x18= 3,600.
The December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn states that for the 18 year plan period a population increase of 8,500 persons is expected (see para 5.52 below) or 3,705 dwellings, so it looks as though we should be getting back the anticipated plan.
5.52 The projection based on past population trends (PROJ 5) indicates modest population growth of 6.2% over the 18-year plan period - an increase in population of around 8,500 persons. Comparing the trend-based projection in this report with that contained in the SHMA we see that population growth would now be expected to be lower. This projection suggests an annual increase in the population of 473 people which compares with a previous estimate of 914.
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This ties in with the census findings
Census
House
holds
% increase
Homes built
Running % increase
population
% increase
Running % increase
1991 (to 1995)
48,202
856
116,522
('96 - '01)
3,537
2001 ('01 - '05)
53,356
10.69%
3,324
125,931
8.07%
2011 ('06 - '11)
58,679
9.98%
2,760
21.74%
137,648
9.34%
18.13%
The 21.74% increase in households compares with 15.32% over the whole of England for the same 20 year period. So The District has not been lagging behind but has done more than most.
2.5 So how did 2,007 become 12,300 when it may have been expected to be about 3,600? The 2012 Preferred Option document was based on a need for 10,800 homes. We understand that 87% of respondents considered this to be too high. The RDS 4.1.1 describes it as an interim level of growth dependent on the joint SHMA. This should also take into account employment need.
When plan-making, NPPF155 requires "Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made." A wide section of the community is engaged and would wish that it was proactively so. But this requires a listening district council.
2.6 NPPF156. Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver the homes and jobs needed in the area.
Homes and jobs go hand in hand.
In December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn updated the forecast for population growth.
4.5 "The District has a jobs density of 0.95 - this means that for every person of working age (16-64) living in the District there are 0.95 jobs in the District. This is significantly above average for the West Midlands or England (0.75 and 0.78 respectively). Overall there is a relatively good jobs-homes balance currently."
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The conclusion drawn is that until the joint SHMA is received, the 12,300 household cannot be considered as a valid consultation. Across the neighbouring authorities, jobs ought to follow unemployment so far as it is sensible to do. Since our unemployment count is very low, and job availability is still very fragile, then building a larger volume of homes than we have ever done does not seem to be a good strategy. It could give us a dramatic employment problem.
2.7.1 Why are significant new jobs required? The June 2013 figures for Warwick District Indicate that there is only 1.6% (or 1,472 persons) of the working population claiming Job Seekers Allowance which is a very low figure. It should be recognised that there will always be a small number of people who are between jobs, or who are long term unemployed.
In other parts of Warwickshire there are significantly higher levels of unemployment. In June 2013, Coventry had 4.42%; Rugby at 2.27% and Nuneaton and Bedworth at 3.53% & North Warwickshire at 2.04%, totalling some 14,345 people, some being due to the closure of the Daw Mill Colliery after a disastrous fire and the winding up of UK Coal. New jobs in the region should be directed towards these more deprived areas.
2.7.2 Coventry's employment problem is that in the 1980's/90's it increased housing but changing circumstances meant that its manufacturing base declined dramatically. Although it has reinvented itself quite well, it now does not have enough jobs to support its population. We must not go down the same road by getting incomers living here and then hope new jobs will be generated. That is not a good plan
2.7.3 The Parish Council was concerned to witness a statement made by a Warwick District Council planning officer at the Planning Committee Meeting on 23rd July referring to planning application W0607 that house building is a good thing because it generates jobs in construction. Of course employment in construction is a good thing, but it cannot be a justification for approving unnecessary house building, besides which the jobs only last as long as the construction period.
2.7.4 On 29th July, the proposed Coventry Gateway Development was called in by the Minister of State for his determination, due to concerns regarding conflict "with national policies on strategic matters". Even if this development is approved at Coventry Airport it would only produce about 1,270 jobs for Warwick district residents and some of those may not be new jobs, just a transfer of location.
2.8 If 5,400 homes are built, at least one person in that home will require employment. It is possibly closer to 2 persons than one. So jobs for getting on for 10,000 people will still be needed and that is at a time when we may have the employees, we may have the land, but we still need the employers.
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2.9 Duty to cooperate implications may be two fold.
2.9.1 In the Examination of the Coventry Local Development Plan - Core Strategy - Concerning the Duty to Cooperate the Inspector found Coventry Council has not engaged constructively with neighbouring local planning authorities on the strategic matter of the number of houses proposed in the Plan and consequently it has not sought to maximise the effectiveness of the plan making process.
Coventry had a Core Strategy which made provision for some 33,500 dwellings (26,500 of which would have been in Coventry, 3,500 in Nuneaton & Bedworth and 3,500 in Warwick). That plan was withdrawn and a new plan( now being examined) made with a provision for 11,373 houses - a significant reduction in housing numbers. (para 5 of the report). Was this 3,500 in Warwick included in the then 10,800 consultation exercise? If so, it was not obvious in the consultation documents.
In the "Statement of Common Ground and Cooperation for the Coventry, Solihull and Warwickshire Sub-Region (SOCG)", Paragraph 4.2 states that the current interpretation of evidence shows that all member authorities are capable of meeting their housing requirements within their borders and there is no requirement for any local authority to meet any part of its housing requirements in another area. & 4.3 states that local planning authorities in the sub-region will continue to plan to accommodate their own needs. However, if an authority cannot accommodate its own needs (because of an increased housing requirement and because of strong evidence of constraints on the provision of housing sites within its boundaries) then, and only then, would the shortfall be addressed through discussions with neighbouring authorities within and beyond the sub-region. Since the outcome of this situation was indeterminate, the Duty to cooperate was not demonstrated.
It seems that this housing arrangement did not take into account employment need either. Coventry may be right to limit their increased housing requirement because they already have a housing/ jobs imbalance and it would also reduce the risk of not being able to make their provision within their boundary. BTPC would have thought that an essential part of the joint SHMA consideration was establishing the capacity of each area to meet its own need and limit expansion to that capacity. This makes it all the more important to make a realistic assessment of need rather than an aspirational assessment that cannot be made to work.
2.8.2 The joint SHMA is now being carried out. In the last few weeks, Stratford has announced a new Gaydon development to serve JLR. This will have a significant effect on Warwick district and will reduce demand on it for housing but will be the nearest centre for shopping and other services.
Stratford are not in the SHMA and do not seem to have cooperated with its neighbours. It would seem that there is a danger that when their plan is examined, it will be similarly rejected. The same could happen to our plan, even though attempts were made to cooperate.
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2.8.3 Coming out of this, if there was an initial inclusion of 3,500 housing in the Warwick target to serve Coventry and this remains in the 12,300 then it should be removed to comply with the SOCG agreement.
3. Housing Land Supply
3.1 This consultation concerns the proposed number of houses to be built in the plan period of 12,300. Last year it was 10,800. The BTPC study last year was 5,400 and emerging population projections from the ONS are similar to that and from G L Hearn, are something below it.
The RDS identifies a range of sites to for new housing. The May 2013 HLS document uses the current consultation figure of 12,300 which is not substantiated by the joint SHMA yet and the consultation is not yet ended. Therefore, 10,800 is the figure that has been consulted on and this was objected to by 87% of the respondents. BTPC's calculation shows that the objectively assessed requirement for the locality is 5,400. This gives us 3 options in terms of the housing increase.
This table sets out site allocations for the plan period 2011-2029.
A
B
C
D
Housing provision by 2029
RDS
based on Jun 2013 5yrhls
a
Target
12300
12300
10800
5400
b
sites completed between 2011 & 2013
447
447
447
447
c
Dwelling sites with permission (not started)
1681
1084
1084
1084
d
Dwelling sites with permission subject to S106
0
0
0
0
e
SHLAA sites
300
514
514
514
f
Less 5% non-implementation
-80
-80
-80
g
Windfall allowance (@116 per year)
2800
2808
2808
2150
h
Poseidon Way
50
50
50
i
old town regeneration
750
750
j
Warwick town regeneration
500
500
k
Add dwelling sites under construction
506
506
506
l
add since April Sydenham
209
209
209
m
Consolidation of employment +urban brownfield
830
inc
inc
inc
n
Warwick Gates employment land
220
220
220
220
o
add vacant dwelling return 250 @ 50 /year
500
450
250
p
East of Kenilworth
700
700
700
q
redhouse farm
250
250
250
r
Villages
1000
1000
1000
300
s
Myton garden suburb
1250
1400
1000
t
east ofwhitnash AoR
600
400
400
u
Greenfield
2230
1050
Total
12308
12308
10808
5433
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3.2 Column A sets out the site allocations made in the RDS as closely as possible. The target provision is 12,300. Lines a to g are from RDS 4.2 Table 1.
Line m comes from RDS 4.2.5 Table 2 for consolidation of existing employment areas of 450 homes and urban brownfield sites listed in RDS 4.4 Table RDS5 giving 380 homes.
Line n comes from para 5.1.2 that was approved in july 2013.
Line p east of Kenilworth RDS 4.3.15 Table RDS4.
Line q comes from RDS 5.3 Table RDS5 Red house Farm , Cubbington
Line r villages are as Table RDS5
Line s Myton garden Suburb is from RDS 5.1.2
Line t is Whitnash East of 500 plus Fieldgate Lane of 100
Line u is the greenfield sites in 5.1.2 being land south of Gallows Hill (430), land at Lower Heathcote Farm ( 720), Former Severn Trent Sewage Works (225), Grove Farm (575) and Woodside Farm (280).
Sites p to u are in Green Belt, villages or in rural areas and Area of Restraint. It illustrates that to get to the very high target, very controversial sites have to be listed all of which should not be selected if the NPPF is to be complied with.
The selection of sites mainly to the south of the District because Green Belt covers the land between Coventry and Leamington and Warwick is addressed in Section 2.
3.3 Columns B, C, and D select sites to match the 3 option levels of 12,300, 10,800 and 5,400 but adds in other ways of meeting those targets to try to avoid the use of greenfield rural area agricultural land. It is based on the 5yr HLS.
3.4 Column B is the 12,300 option. It attempts to improve the plan by identifying other brownfield sites and reducing the amount of greenfield to be taken.
Lines c to g and k are taken from the 5Yr HLS.
Line h is a change of use of a small piece of employment land off Poseidon Way , south of the AP factory, which has not been taken up and could take 50 affordable homes.
Line i introduces a regeneration scheme to improve the land south of the railway and north of the canal from Tachbrook Road in the east to the old market square providing multilevel mixed use shopping, entertainment, apartments, fit for the 21st century whilst respecting the remaining pieces of the past. It would improve the poor aspect of the town from the railway line.
Line j includes an allowance for residential arising from the recent Warwick Town plan document.
Line l is the housing scheme at Sydenham when the appeal was allowed for 209 dwellings.
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Line n is land north of Harbury lane that was recently approved as a change of use from employment land to residential with outline approval for 220 dwellings.
Line o is the inclusion for the return of long term vacant dwellings to residential use. In the past 5 years 300 dwellings have been brought back in to use but there still remains 1,452 vacant properties. The intention is to bring 500 back into use over the 18 year plan period.
The Kenilworth, Red House Farm and villages requirements are retained in the list.
Line s increases the dwellings to 1400 on land west of Europa Way to increase the number of affordable homes at a higher density.
Line t is reduced to 400 because of line l subject to the appeal decision.
Line u reduces the requirement to use greenfield land for 1,180 dwellings equivalent to the sites south of Gallows Hill and Lower Heathcote Farm.
This option still takes Grove Farm, Woodside Farm, the remainder of land east of Whitnash and Fieldgate Lane as well as Kenilworth, Redhouse and the villages and so is still an unacceptable option.
3.5 Column C is an option for 10,800. The differences to the 12,300 option are -
Line o reduces vacant dwelling return from 500 to 450.
Line s reduces the dwellings to 1000 on land west of Europa Way
Line u omits all greenfield land subject to rural area policies.
This option still takes the sites at Whitnash, Fieldgate Lane, Kenilworth, Redhouse Farm and the villages and still requires substantial regeneration schemes lines I & j.
So the option is better but still difficult.
3.6 Column D is an option for 5,400.
It omits Kenilworth and Redhouse Farm, Green Belt sites, Lines p & q.
It omits lines s to t - Myton gardens, East of Whitnash and all greenfield sites.
It reduces line 4, villages to 300 across all villages.
It reduces windfall allowance to 2,150
It reduces the requirement for vacant dwelling return to 250 over the 18 year period.
It omits Old Town regeneration & Warwick Town regeneration.
This is an option with the maximum support of the community, provides the level of new homes that will be needed, and is achievable in the time scales available.
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4. The Five year Housing Land Supply
4.1 The District has to have a 5 year housing land supply of specific deliverable sites. To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five years, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans.
4.2 The June 2013 5 year housing land supply shows that the District does not have this supply identified. Of 12,300 said to be required, the 5 year supply is calculated as 4,550 giving a 2.8 year supply. This creates a problem because NPPF 49 states that, "Housing applications should be considered in the context of the presumption in favour of sustainable development. Relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites".
4.3 It is essential to choose a strategy that the district can justify and which provides the 5year supply required. BTPC has found that
a. The calculation of the 5year supply required for 12,300 is incorrect and
b. If the 12,300 option is chosen, not only is it way beyond that which an objectively assessed need requires, it is almost impossible to ever get a 5 year supply because of the time allowed for implementation.
4.4 The 5year housing Land Supply for each of the 3 options is calculated as follows -
Requirement 2011 - 2029
12,300
10,800
5,400
Completions 2011 - 2013
447
447
447
Requirement 2013 - 2029
11853
10353
4953
Annual requirement for 16 years
741
647
310
5 year requirement 2013- 2018
3704
3235
1625
Plus buffer of 5%
185
162
77
The 5 Year Requirement 2013-2018
3889
3397
1625
Total deliverable sites as Table 2 in May 2013 5yr HLS
3474
3474
3474
Number of Years Supply
4.47
5.11
10.69
13
In the list of Components of Supply, the deliverable sites including sites under construction are as follows -
 The dwellings with permission not started, the SHLAA sites and windfall allowance are as the Districts list, but in this calculation, the 5% non-implementation deduction is not applied to the windfall allowance because it already contains a final phase discount.
 Adding the sites not started to the SHLAA sites the number is 91 short of the 1.681 quoted elsewhere. This is added back into the calculation.
 Approvals given since 1st April at Sydenham and land west of Warwick Gates are added in.
 Provision is made for the vacant dwelling return at 50 per year based on past performance and known lists of properties to be brought up to standard. The district has arrangements in place with a Housing Association to implement properties identified as ready to be brought up to standard and with new homes bonus incentives and meet the tests to be included. In addition NPPF51. Requires that "Local planning authorities should identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and, where appropriate, acquire properties under compulsory purchase powers." This makes it a relevant issue as a component of supply
 Studies have been ongoing with villages for the last year as to where the 1000 village sites might be possible. With some application, sites to give 20 dwellings per year for the 5 years can be identified.
COMPONENT OF SUPPLY
12,300 dwellings
10,800 dwellings
5,400 dwellings
Dwelling sites with permission (not started)*
1,084
1,084
1,084
Dwelling sites with permission with S106
0
0
0
SHLAA sites*
514
514
514
Less 5% non-implementation
-80
-80
-80
Windfall allowance (@116 per year)
580
580
580
SUB TOTAL
2,098
2,098
2,098
Add dwelling sites under construction
506
506
506
Add missing commitments (1681- * items)
91
91
91
Add approvals post 1Apr Sydenham May 2013
209
209
209
Ditto Gallaghers triangle 10.7.2013
220
220
220
add vacant dwelling return 250 @ 50 /year
250
250
250
add villages at a nominal 20 per year
100
100
100
Total (deliverable sites + sites under construction)
3,474
3,474
3,474
The 5 Year Requirement 2013-2018
3889
3397
1625
Number of Years Supply
4.47
5.11
10.69
14
4.5 If the correct actions are taken, then the 12,300 still does not give a 5 year supply whereas both the 10,800 and 5,400 options do give a 5.11 and 10.69 year housing land supply. In order to protect the District's ability to produce a plan-led Local Plan by complying with NPPF49, the 5 year plan should be brought up to date without delay.
Section 2
The Balance and Distribution of the Proposed New Housing across the District presents real problems.
1. In addition to the increase in housing numbers the Parish Council is deeply concerned that, because of the unnecessarily high numbers of housing, the focus of new house building has shifted further to the south of Leamington and Warwick, further skewing the balance in the location of new housing. The reasons for this deep concern is as follows.
a. Such an imbalance of housing to the south will lead to significant congestion from traffic trying to access the town centres, particularly at the canal, railway and river crossings where there is no practical and economic mitigation option.
b. It places significant pressure on the southern landscape and the historic setting of Warwick in particular. These matters are dealt with in more detail elsewhere in this response.
c. It adds to the pressure on the coalescence of settlements and in particular threatening the rural identity of Bishop's Tachbrook.
2. Therefore, the high housing numbers proposed must be reduced in order to address this in balance and to meet the NPPF 54, 55, 109..
3. The principle reason for this shift and the discounting in the RDS of significant housing sites to the north of the towns is because of the large amount of green belt (80% of it's area) in Warwick District.
4. The additional status afforded to the green belt has the effect of saying that one area of rural Warwickshire to the north is more precious than another area of at least equivalent landscape worth to the south. This is unreasonable and unfair. Further, it comes as a result of an application of the Green Belt principle that was not intended when green belt was established. Town & Country Planning legislation used rural area policies to control development in designated rural area locations. These were intended to be strong enough to prevent such arguments arising.
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5. The Parish Council fully supports Green Belt policy. At the same time we expect that rural areas and landscapes close to urban areas should be controlled by strong rural area policies. The contrast between town and country is important to the well-being of everyone and provides a high value recreational benefit for all, whether they drive, cycle or walk through it - or even take to the air and go by double decker bus to see over the hedges.
6. Green Belt was established to prevent Cities expanding in a uncontrolled way and according the NPPF it serve 5 purposes:
o to check the unrestricted sprawl of large built-up areas;
o to prevent neighbouring towns merging into one another;
o to assist in safeguarding the countryside from encroachment;
o to preserve the setting and special character of historic towns; and
o to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
7. The West Midlands Green Belt was established to prevent large urban areas such as Birmingham and Coventry expanding uncontrollably into the surrounding countryside. So the fact that the Green Belt touches the north of Leamington and Warwick is incidental because both at that time and now, the real threat of expansion on landscape and coalescence comes from Coventry.
8. The New Local Plan proposals have potentially far reaching affects for the district, with the potentially vast numbers of new homes being proposed. BTPC considers that you have 2 choices, either you distribute the housing through all parts of the district including green belt to satisfy large number of inmigrants or you reduce the number of houses to that which the locality needs to meet sustainable objectives and respect the long standing purposes of green belt and rural areas.
9. Therefore if the District Council considers that it should ignore the views of the electorate and decide to plough on with an overlarge number of new houses because of a subjective assessment concerning hopes for economic expansion that the market is unlikely to support, it should take a strategic look at the Green Belt to see if the exceptional circumstances prevail to justify redrawing green belt boundaries to distribute the new housing in a balanced way around the district. The NPPF reference is Chapter 9: para. 83 "Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period."
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The Local plan Review is the only time when Green Belt boundaries can be changed. New Green Belts can only be established in exceptional circumstances.
10. In considering the impact of increased traffic due to the expansion of the population by some 30,000, a 21.5% increase, officers have concluded that those exceptional circumstances do not exist to develop in greenbelt. It therefore follows that the exceptional circumstances do not exist either to disregard the NPPF112 in its requirement to maintain protection of rural and agricultural areas because the subjective judgement on the level of economic growth cannot be substantiated and therefore demonstrated to be necessary.
112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.
11. If the Local Plan eventually decided includes the Myton Gardens as a major urban extension, then the Parish Council urges the District Council to establish a new green belt from Castle Park, along the Tach Brook valley south of Harbury Lane and Gallows Hill too provide long term protection of the landscape from urban sprawl as provided for in NPPF 52. The supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities. Working with the support of their communities, local planning authorities should consider whether such opportunities provide the best way of achieving sustainable development. In doing so, they should consider whether it is appropriate to establish Green Belt around or adjoining any such new development.
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Section 3
Rural Area Policies and loss of landscapes and agricultural land.
1 The planning Inquiry in 2006/7 looked particularly at sites both in Areas of Restraint and subject to rural area policies. The decision made then needs to be seen in the context of the NPPF54, 55, 109 to 125. In particular, NPPF54 agrees with the existing local plan rural area policies by requiring that, "In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs."
NPPF55. Would extend those policies " To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby." To do this, the local plan should have specific rural area policies. It may be that neighbourhood plans would customise such policies for particular reasons relevant to that parish.
2. In relation to proposals to select rural areas for development, the NPPF requires the following clauses to be taken into account.
2.1 NPPF109 requires that "The planning system should contribute to and enhance the natural and local environment by:
 protecting and enhancing valued landscapes, geological conservation interests and soils;
 preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
 remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.
2.2 NPPF110 requires that In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework.
2.3 NPPF111. Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities
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may continue to consider the case for setting a locally appropriate target for the use of brownfield land.
2.4 NPPF112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.
The sites selected for development to the south of Warwick & Leamington do not appear to meet these requirements.
2.5 In particular, the district has not demonstrated that housing at the 12,300 or the 10,800 levels is needed to support the local community. Indeed, as housing projections are updated, the amount of housing needed for both objectively assessed natural and migration projections is reducing. 5,400 homes in the plan period is the best projection available.
2.6 NPPF156. Requires that Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver: climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape.
The councils own Landscape consultant in 2009 has some very strong recommendations that should be taken into account. The 2012 "Considerations for Sustainable Landscape Planning" also advises in paragraph 8.8 that
"This landscape is important in perceptions of Warwick and Leamington - especially as it provides a rural buffer between the towns and the M40 and the setting to Castle Park. Future planning must sustain overall landscape character and viable agricultural units whilst creating appropriate portions of multifunctional public landscape. Development design must aim to avoid wider visual impacts (including 'secondary' impacts such as might arise from service infrastructure provision and night lighting). It should also be a primary planning goal to avoid creating barriers to non-vehicular movement - e.g. with the increasingly busy local road system."
And further, it concludes, in paragraph 9 that
"The scale and extent of development presently being considered in Warwick District is possibly unprecedented and will undoubtedly have major implications for the character and appearance of the towns and parishes affected for many decades to come. There is presently considerable pressure on local authorities to act quickly and to facilitate development. However, it is essential that good decisions are made for the long term. There is extensive contemporary guidance highlighting the importance of landscapes, ecology,
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historic fabric and all ecosystem services in creating sustainable development. "
3 Looking at the particular sites the inspector at the 2006 Public Inquiry reached the following conclusions.
3.1 Woodside Farm should remain in an area of restraint. In a lengthy and detailed consideration he concluded that
10.11.41 The AoR designation has been carried forward from the adopted Local Plan. It was established to maintain separation between Bishops Tachbrook and Whitnash. When preparing the earlier Plan the District Council successfully argued that any extension of built development to the south of Whitnash, beyond the ridge line that defines the present edge of the town onto the south facing slope, would create a major incursion into the countryside that would be highly visible and intrusive. Since that time a number of physical changes have occurred in the locality. Extensive housing development has taken place at Warwick Gates on the opposite side of Tachbrook Road. Although anticipated through a Local Plan allocation, this has affected the character of the area by bringing development to the west as far south as Harbury Lane. In addition, playing fields, open space and woodland have been laid out to the east of the objection site giving enhanced public access, and overhead electricity lines have been put underground. The objector argues that in light of these changes the objection site should be excluded from the AoR. The request is supported by a Landscape and Visual Impact Assessment and a Development Principles Plan.
10.11.42 I consider that the AoR still performs essential functions. It helps safeguard the character and setting of Whitnash, prevents urban sprawl and assists in maintaining the integrity and separation of Bishops Tachbrook as an independent settlement. The objection site is an important element of the broader AoR. It occupies an elevated position with views of it obtaining from certain directions. They include limited views driving northwards along Tachbrook Road from Bishops Tachbrook, from Harbury Lane to the east and long distance views from public locations on the northern edge of Bishops Tachbrook. From each of these positions housing development would be clearly visible for many years while structural landscaping matures. This would intrude into the rural surroundings and noticeably reduce the open gap that remains between Bishops Tachbrook and the urban area.
10.11.43 I conclude that this land should remain open as part of a more extensive AoR and that it should not be allocated for housing development within the Plan period or be identified for longer term development.
BTPC concur with the Inspectors view. It is an essential part of the distance between Whitnash and Bishops Tachbrook and an important part of the valued change from town to country along the Tachbrook and Oakley Wood
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Roads and in particular their junction with Harbury Lane going east rising up through the trees up a double incline hill some 15metres high as the road reaches Mallory Court on the right hand side. Housing on Woodside would be completely counter to the NPPF
3.2 Fieldgate Lane/Golf Lane should remain in an area of restraint. In a lengthy and detailed consideration he concluded that
9.4.16 I take a rather different view. Looking first at the boundary of the AoR, I acknowledge the previous Inspector's uncertainty about whether the golf course and land to the east contribute to the AoR objective of preventing Whitnash from merging with Bishops Tachbrook. However, the south-western part of the golf course is highly visible from Harbury Lane where it forms a backdrop to the new playing fields and pavilion such that any development there would significantly close the gap between these settlements. Moreover, while the rising nature of the ground at Fieldgate Lane/Golf Lane from north to south means that development would not be visible from Bishops Tachbrook, it would be clearly seen from southern parts of Whitnash where the land contributes to the rural setting of the town. It would also, I feel, be intrusive in long range views from east of the railway line. I find that the whole of the area (that is, the golf course and the land at Fieldgate Lane) contributes to the objectives of the AoR. The land has a role to play in the structure and character of this part of Whitnash, provides open areas in and around the town, safeguards its setting and helps prevent urban sprawl. In addition, the south-western section of the golf course maintains separation between Whitnash and Bishops Tachbrook. Consequently, I see no case for excluding the golf course or the Fieldgate Lane site from the AoR. As regards land south of Harbury Lane, this land forms part of the sensitive gap between Whitnash and Bishops Tachbrook. But I believe it to be less at risk of development because Harbury Lane/Gallows Hill provides a strong boundary to the urban area. In my view, there is no need for AoR designation to extend south of Harbury Lane.
9.4.18 Finally, the objector considers that as the Fieldgate Lane site is bordered by housing to the north and south it should be considered as part of the urban area, rather than one where the Plan's Rural Area Policies apply. I do not agree. As the District Council points out, all rural areas have an urban edge. In my opinion, that boundary is properly set by the suburban housing to the north of Fieldgate Lane.
9.4.19 The objector's proposals were subject of the Omission Sites Consultation undertaken in January/February 2006. Responses received from Whitnash and Bishops Tachbrook residents, CPRE (Warwickshire Branch) and Whitnash Town Council were against any removal of the golf course or Fieldgate Lane site from the AoR, any residential allocation at Fieldgate Lane and any exclusion of the proposed development site from the application of Rural Area Policies. I note that 251 responses were received against the Fieldgate Lane
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site and 496 objections in relation to the golf course (of which 240 were by way of a petition from members of the Leamington and County Golf Club). This is a clear indication of the strength of local feeling.
Residents of Whitnash agree with the inspector that the site is part of the Golf course, Woodside Farm Area of Restraint set out by paragraph 9.4.19 of the inspectors report. BTPC agrees and objects to this proposal.
3.3 Grove Farm (called Harbury Gardens by the developer) should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & west of Oakley Wood Road.
In the 2012 consultation, this site was described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge as part of the separation of Whitnash and Bishops Tachbrook was welcomed. Dismay ensued with the current 2013 proposal for 200+ homes. It is noted that the land allocated for development in the current consultation is much larger than the application currently being considered and takes the whole of the northern side of the Tach Brook reducing the separation of the settlements to an unacceptable low level.
Reacting to an objection seeking this land be included in an area of restraint, the inspector found that
9.4.4 I agree with the District Council that a cautious approach needs to be taken in respect of the AoRs in order to avoid their devaluation and to ensure that they perform a specific function. Unlike the other AoRs included in the Revised Deposit Plan, much of the land identified by Bishops Tachbrook Parish Council (even with the reductions in area put forward at the hearing) is relatively remote from the urban area and not under immediate threat from urban expansion. The gap between Harbury Lane and Bishops Tachbrook is about 1.4km compared with only 300m or so between Leamington Spa and Radford Semele. Although there are objections before this inquiry that seek to allocate or designate sections of the land in question for other uses, and anecdotal evidence of options taken by developers, this is by no means unusual when a Local Plan is under review. I consider that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for additional protection. It is not the function of AoRs to give an added layer of protection to open countryside where appropriate policies already exist to control development. Should land have to be released in the future for urban expansion then the District Council says that this exercise would be done by a review of options on all sides of the urban area including sites subject of Green Belt and AoR designation. Land south of Harbury Lane outside an AoR would, it is argued, be placed at no disadvantage.
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9.4.6 I conclude that while additional development has taken place to the south of Leamington Spa during the last 10 years or so since the previous Local Plan Inspector reported, his findings remain pertinent. Given the strength of the Rural Area Policies of the Plan, the current housing and employment land supply position and the degree of protection afforded to the most critical areas by the AoRs already identified in the Revised Deposit Plan, there is no need for a further AoR south of Gallows Hill/Harbury Lane. To designate such an area in the absence of any serious threat would be premature at least and at worst a misuse of policy.
The Inspector clearly considered that rural area policies were strong enough to prevent such development. Nothing has changed that alters the communities view. Housing in this location will be very visible across the Tachbrook Valley from the south, being on the ridge line as can be seen from this photograph. Housing will be prominent half way down the field in the distance. The top of roofs to Warwick Gates can just be seen behind the hedgerow on the horizon and stretch from the coppice of trees on the left side of the picture to Grove Farm buildings to the right of centre of the photo. The photo was taken from the public footpath to the Asps from St. Chads Church and this is a prominent view along most of the path. The suggested country park to the south of the housing, because it is on the slope down to the brookstray will not hide the housing as it will be the same height as the trees that can be seen running along the Tach Brook from left to right. The NPPF paragraphs quoted at the head of this section are intended to conserve, protect and enhance landscape such as this wonderful piece of Warwickshire.
It is essential that this piece of landscape is protected as there is no credible case for housing in this location. So we object to the proposal in the 2013 consultation and support the 2012 consultation to keep this area as a green wedge. In BTPC's view, however, it does not need to be converted into any sort of country park, at considerable cost no doubt, as it is perfectly acceptable as it is. This would retain a valuable piece of agricultural land, meeting the needs of the present without compromising the ability of future generations to meet their own needs.
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3.4 Lower Heathcote Farm should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & east of Europa Way.
In the 2012 consultation, this site was also described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge running from Castle Park in the west through to Radford Semele, incorporating paths along the side of the Tach Brook, presents recreational potential for village and urban walkers. Dismay ensued with the current 2013 proposal for 720+ homes.
The photograph shows the view north across the Tach Brook Valley from New House Farm. Housing will come down from the hedgerow on the horizon along the Harbury Lane covering the top half the field between that hedgerow and the trees along the brookstray, the tops of which can just be seen. The undulating form is a 'trademark' of the rolling Warwickshire countryside that is part of the tourist attraction experience on the approach to Warwick Castle from the south and is seen as a backdrop along the Banbury Road. It is highlighted in the Morrish Landscape consultants report of 2009.
4.4 Paragraphs 109-125 of the NPPF outline conserving and enhancing the natural environment. They state that the planning system should contribute to and enhance the natural and local environment by protecting / enhancing landscapes; by recognising ecosystem services; by protecting/improving biodiversity; by avoiding pollution or environmental degradation and by remediating degraded land. LPAs should set criteria-based policies by which to judge potential impacts to wildlife, landscape, etc. and set out a strategic approach to green infrastructure in local plans.
This requirement expects that the new local plan will have such policies and implement them.
The landscape consultant also advises
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5.1 Some of the elements that contribute to landscape character include the shape and scale of topography, the presence and pattern of natural geology, outcrops, water bodies and vegetation and, the patterns and features of man's intervention - including land management and settlement.
How and from where the landscape can be viewed greatly influences how it is perceived - so that the availability of access becomes influential in determining landscape character. A variety of views (long vistas, wide panoramas, framed focal points) generally adds to our enjoyment of a landscape. Landmarks are of particular value/interest in any landscape - even if they have disputed amenity value (e.g. Eden Court flats at Lillington).
This paragraph describes exactly the situation with this site. The landscape value of this area is very high. It has a large variety of views, long vistas wide panoramas and framed focal points. It shows an interesting shape and scale of topography. The brutal insertion of the development proposed is totally insensitive, tantamount to municipal vandalism. The existing landscape is an asset that everyone in Warwick District can enjoy and is part of the package that makes Warwick District a Great Place to Live, Work and Visit.
The Inspector "consider(ed) that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for the additional protection of an Area of Restraint. This set of policies should be included in the new local plan to meet the NPPF clauses referred to above.
11.4 The former Severn Trent Sewage Works between Lower Heathcote Farm and Grove Farm to the south of Heathcote Park is listed in RDS 5 and shown on Map 3. It claims to provide 225 homes.
This photo shows the site from the site across the Tach Brook Valley. It is the central greener area. At the top of the hill on the skyline there is a mature area of trees which provides a wildlife oasis to a number of mammals including deer, birds and woodland insects. The former sewage tanks are, according to old plans, many and closely aligned. The tank depths and ground
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contamination is likely to make this a difficult site to develop for housing and add to that the steep fall as the ground slopes down towards the brook it is unlikely to provide any practical housing land at all.
The site would however be an ideal site to develop as woodland as part of the low carbon environmental sustainability objective of the Councils Corporate Development Strategy. Carbon dioxide sequestration of woodland is calculated on the basis of 25m2 absorbs 1 tonne of CO2 per annum. If a normal house produces 4 tonnes of CO2 per annum, this provides sequestration for about 1000 of the homes to be built. Bishops Tachbrook Neighbourhood Plan is seeking sites of this nature within its boundary and will be including this site in discussions with neighbouring towns and parishes as part of its duty to cooperate with them. AS far as the NPPF is concerned paragraph 109 requires development to conserve and enhance the natural and local environment by remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.
11.5 Land south of Gallows Hill between Europa Way and Banbury Road, north of the Tach Brook.
The northern section is the other half of the Tachbrook Valley and to build upon it would detract from the southern part which it has been accepted should be kept. Given that the RDS does accept that the Asps is an important part of the Warwick Castle approach, so is this northern section. it can be seen from the Warwick Castle Towers and the mound. Any development on this site will have a direct impact on the views available to visitors to the castle.
This photograph was taken from the top of Guys Tower in Warwick Castle, looking south-east, earlier this year and shows the site south of Gallows Hill in the foreground with two oak trees in the centre of the field and the hedgerows running along Europa Way. Behind the hedgerow there are fields of yellow oil seed rape which is the site south of Harbury Lane in 3.3 at Lower Heathcote Farm. To the right of the poplar tree on the left of the photo is the farm cottage to the former Heathcote Farm with, to its right, the roofs of the bungalows in Heathcote Park, mostly hidden in the trees. Beyond that are the trees bordering Oakley Wood Road with the hill rising behind them, through the Grove Plantation rising to Highdown Hill Plantation on the skyline. This is a view that has been available to Kings, Earls and visitors since 1395 when the Tower was constructed, so is significant for Tourism and should not be lost to development. No amount of landscape 'mitigation' will compensate.
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The 2009 Landscape area statement by the councils Landscape Consultant Richard Morrish clearly concludes that
This study area is principally well preserved farmland that creates an attractive rural setting for the south side of Warwick and should be considered an important part of the setting for Castle Park. Any development that 'jumped' the Heathcote Lane / Gallows Hill frontage would set a major landscape precedent in extending the urban area so far south. Although it is considered that the Warwick Technology Park has possibly diminished the value of the Area of Restraint north of Heathcote Lane, its general style of low density development in a strong landscape setting makes for a reasonably successful transitional environment on the urban fringe - as do the adjacent school sports fields. To extend the urban area beyond these sites would make for a disjointed urban structure and possibly encourage intensified development at the Technology Park and around the schools. Smaller blocks of isolated development are also likely to be incongruous in this landscape.
Our conclusion is that this study area should not be considered for an urban extension and that the rural character should be safeguarded from development.
The Inspector at the 2006/7 Public Inquiry considered this site for employment purposes. In a lengthy and detailed consideration he concluded that
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10.3.49 The objectors maintain that the Gallows Hill site would provide continuity in the forward supply of employment land beyond 2011. However, I believe it would be inappropriate to identify such sites now when the future employment requirements of the District are uncertain pending completion of the sub-regional employment land review and the partial review of the RSS. Until then, the RSS requires that greenfield sites, like this land at Gallows Hill, should only be released when there is no alternative previously developed land available. The WMRA, commenting on the Omission Sites Consultation, remarked that new sites being promoted involving the development of greenfield land "appear to be inconsistent with the principles of the RSS" and requested that the Inspector rigorously scrutinise such proposals. I agree with the District Council that as and when further greenfield land releases are necessary this should be done through a DPD where a full comparative assessment of all potential sites can be made in the context of a sustainability appraisal and following a process of public consultation. In this regard, I note that the objection site is classified as very good (Grade 2) agricultural land and that a full Transport Assessment would be required in respect of development on this scale. I believe that the ad hoc release of a large greenfield site like this located on the urban fringe and currently in agricultural use would not be in the best interests of the District. The Council's Local Development Scheme commits it to begin preparation of a Core Strategy DPD immediately following adoption of this Local Plan. That will tie in with completion of the partial review of the RSS, enabling up-to-date employment requirements for the District to 2021 to be accommodated.
10.3.50 I conclude that land at Gallows Hill should not be allocated under Policy SSP1 for employment (Class B1) purposes, nor should the site be excluded from the rural area defined on the Proposals Map. To do so would result in an over-provision of employment land relative to the Structure Plan requirement, at the expense of the surrounding countryside.
The site is shown in the RDS as residential and employment but this we believe is wrong because all the advice is that it should be retained as agricultural land with a high landscape quality, hidden for the most part behind hedges on Harbury Lane but with occasional glimpses through it at gates and breaks in the hedge. It is on the only high quality approach road to the Castle.
12 Separation of settlements.
The District Council to date has rigorously resisted any development that reduced the gap between Bishops Tachbrook and Whitnash/Warwick. We believe that the NPPF requires the district to continue to implement those policies as part of the social role within sustainable development, supporting strong, vibrant and healthy communities.
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Section 4
Traffic and pollution
BTPC has serious concerns that the 12,300 homes proposal the largest part of which is in one concentrated area to the south of the urban area of Warwick and Leamington will have serious traffic implications. This must be correct because the traffic engineers advise that 24 or more large junction improvements must be made to reduce the effect of this proposal estimated at this stage to cost £39,000,000 but likely to exceed that when all the problems are known.
Even then, we are advised, at peak periods due to the high traffic volumes, the myriad traffic light junctions are unlikely to speed things up very much. Traffic is bad now and will continue to be so.
The problem is the historic road layout and the combination of rail, rivers and canals requiring bridges that give a very limited number of north south routes for road traffic and because of concentrated development in the towns it is not possible to find a new route through, the problem is difficult to resolve.
But Warwick is an old town most of which was built for horse powered traffic. Many roads are narrow and restricted and the buildings are close to roads some with narrow pavements. The paraphernalia of signalled junctions, multiple lanes and traffic signs for every purpose, as well as the high levels of road lighting do not fit well with the elderly buildings and character of the town. The increased traffic arising from developments south of the town will have a severe and unacceptable impact on the town, which can be avoided by accepting that the objectively assessed level of local housing need amounting to 5,400 homes. As these will be better distributed around the district, major traffic concentration would be avoided. Depending on where development are located, some traffic junction improvements may be required but not on the scale being proposed.
Air pollution is also a concern, particularly for those properties that line the roads and ventilate into the narrow streets. No reassurances, with independent continuously measured air pollution levels, have been provided by the District to indicate whether this is a real concern or not. It must be assumed therefore that such measurements would show that the problem is real and from time to time at unacceptable levels. If that is shown to be the case, then any development as included in the consultation would not be in compliance with NPPF 109*4 "The planning system should contribute to and enhance the natural and local environment by: preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability."
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Section 5
Housing and Rural Settlements
We reject the proposed Settlement Hierarchy because it uses the wrong criteria to decide what each village might be able or want to do. Careful change to the Limited Growth Villages policy, could identify sympathetic housing developments in rural areas which the local community would support.
The tone of the suggested policy is contrary to the spirit of the Localities Act and seeks to impose from above rather than be formulated by the residents who live there.
1 RDS 5 categorises 5 villages as Primary Service Villages and another 5 as Secondary Service Villages. But, apart from a checklist of facilities, nowhere is the logic set out to explain the distinction. Many residents would argue that Barford is better served with facilities than Bishop's Tachbrook, and other awkward comparisons can be made.
2 Nor is it clear why a further 14 Smaller Feeder Villages could not be included in the first 2 categories.
3 It is not necessary or fair to exclude Smaller and Very Small Villages from having the opportunity to grow organically. All might benefit from some new housing, provided it is built in small numbers of units and phased over the period of the plan; and of course sensitively designed to harmonise with the existing settlement in terms of topography and landscape. We agree with points made in 4.4.5
We recommend that new housing in rural areas should be dispersed evenly across the District.
4 We agree therefore with the tenets set out in 4.4.3, but these should be applied to all rural communities equally. We reject the concept that villages in Green Belt have different needs and ambitions to villages in other rural areas. Village life needs to be nurtured and allowed to evolve in an even handed manner, across the whole District.
5 WDC Planning should encourage parish councils, with the support of their community, to suggest to property owners where they might bring forward plots within and adjacent to village envelopes. Confidence in the process will be established provided policy states that schemes should be no greater than for, say, 20 units (this would enable up to 8 affordable dwellings).
6 Green Belt policy does not debar some new housing, because it is possible for the green belt to " wash over" a settlement. There is some land in the green belt which does not contribute to the quality of the environment or landscape, where appropriate schemes would be beneficial and would improve unkempt parts.
7 "Sustainability" is a prerequisite not just for villages with shops and pubs. Most smaller settlements will have WIs, allotments, churches, and a range of groups and activities which ensure a thriving community life. Planning policy should underpin this.
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8 As per 4.4.3 most PCs and Neighbourhood Plan teams will respond positively to close working with WDC Planning. Stephen Hay has started the process well.
We reject the proposal that Bishop's Tachbrook has to have 100-150 new houses.
9 No clear reasons are set out why PSV's should have 100-150 new houses and SSVs 70-90. If it is based on population it could as well be argued that smaller and medium sized villages should be allowed to grow more in order to balance up with larger villages. There is no intrinsic merit in large villages getting much bigger whether absolutely or in proportion to their existing size. It cannot be the intention that large villages become the size of small towns.
10 Bishop's Tachbrook village consists of about 750 houses, so that the additional number would represent a 13 - 20% increase. Such incremental growth would be excessive and dilute the village atmosphere.
11 Time and again residents have stressed that their reason for choosing to live in BT is that they wish to enjoy village life. In our Parish Plan survey residents emphasised that they are passionate to retain the rural setting of the village; and in this regard consider the agricultural land that currently separates us from the southern edge of Leamington and Whitnash as critical. (Happily people living in Warwick Gates and Whitnash share the same view!)
12 The aerial photo shows clearly the compact form of the village. There are no obvious spaces to accommodate 100 plus new houses. New residents living on a
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periphery estate would feel remote form the village centres and may find it difficult to integrate with existing residents.
13 The community's view is that the school, shop, club and pub do not require sustaining by population growth - and given the propensity of estate dwellers to jump into their cars, our shop and hairdresser would not expect to derive much additional turnover.
14 The Housing Needs Survey conducted in 2008 resulted in 14 new dwellings being required to meet local needs - on the basis that 10 of these were affordable and using the 40% norm that infers a top line figure for new housing of 25.
15 We were able to test this figure in June as part of our Neighbourhood Plan engagement. Of 189 residents responding at a public exhibition, 68% felt that the village need was for 0-14 houses, with the balance of respondents suggesting higher figures, but declining markedly over 100.
16 We urge WDC Planning to trust this community via its on-going Neighbourhood Plan process to arrive at a realistic figure; and to continue its discussions with owners of property both within the village boundary and adjacent to the envelope.
This less rigid approach is essential if the Council's Strategic Vision "to make Warwick District a great place to live, work and visit" is to be achieved.
Section 6
Sustainability
The purpose of the planning system is to contribute to the achievement of sustainable development. The broad principles of sustainable Development are to meet the needs of the present without compromising the ability of future generations to meet their own needs.
The UK Sustainable Development Strategy Securing the Future set out five 'guiding principles' of sustainable development:
1. living within the planet's environmental limits;
2. ensuring a strong, healthy and just society;
3. achieving a sustainable economy;
4. promoting good governance; and
5. using sound science responsibly.
In plan-making it is essential to ensure that plans meet all the relevant NPPF requirements and in particular
150. Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities. Planning decisions must be taken in accordance with the development plan unless material considerations indicate otherwise.
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151. Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. To this end, they should be consistent with the principles and policies set out in this Framework, including the presumption in favour of sustainable development.
152. Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where adverse impacts are unavoidable, measures to mitigate the impact should be considered. Where adequate mitigation measures are not possible, compensatory measures may be appropriate.
So, is the consultation plan sustainable in the terms laid down by the NPPF?
Is the assessed housing need at 12,300 assessed objectively for the District?
Are the sites selected for development acceptable in principle and compliant with the NPPF?
Is the effect on the environment, taken as a whole, of enlarging the population by another 20% in 15 years necessary and acceptable?
Does the development require associated infrastructure other than provided in the housing development and are the costs of their provision covered by the proposed developments?
Are there any significant adverse impacts from the development?
What are the social impacts of the plan?
From the content of this response, it is clear that BTPC consider that none of these requirements pass the test of the NPPF and that the plan is non-compliant. The base problem is the housing number which is excessive for the needs of the population and the recent trends in migration. But the additional 30,000 if they were to arrive as planned would change the District dramatically and reverse the strategic vision promoted by the Council. The plan will result in making Warwick District a less good place to Live, work and Visit.
Nor do we think that the District will become known as a place of sustainable "Garden towns, suburbs and villages". It will still, if we don't ruin it, still be famous for its castles, history, spa town regency layouts, and rolling countryside but we don't think these developer led estates are likely to join them .
What would make the plan better? The single most effective way to take all the communities forward together, without splitting north from south, green belters from rural folk and making happy people sad to see the place destroyed, would be to adopt the objectively assessed number of new homes as 5,400 as it would
 be achievable within the terms of the NPPF and so get an examiners approval rather than rejection
 use sites that are uncontroversial and fit in from the outset
 provide all the housing requirements needed by the people in the locality and give a reasonable margin to allow trend based migration to occur
 Provides a good set of affordable homes more quickly into urban locations with existing services and communities giving organic growth of the towns
 Reduce car travel miles by using urban locations closer to facilities
 allow a 5year housing land supply to be established forthwith and remove the impediment of developers usurping the local Plan process
 Be economically viable for all the public bodies that would otherwise be left with having to find the costs of additional infrastructure from the 12,300 plan, as with the 5,400 plan the effect would be spread wider and be largely met by existing provision. This is an important point since public sector funding is set to get less and less and CIL (the WDC paper acknowledges will leave a funding gap unspecified but an educated guess indicates something in the region of £100,000,000) and 106 agreements will be insufficient to meet all the costs that the 12,300 proposal will engender. We have not found a business plan for the Local Plan yet.
 Retain rural area policies intact into the new local plan, retaining agricultural land and high visual quality landscapes, which tend to get taken for granted but are only there because previous council members have ensured the right policies to do so
 Retain green belt which is so valuable in differentiating the character of Warwick district from the surrounding conurbations
 Retain the attractiveness of the district that is basis of our thriving tourism industry
 Retain the good jobs homes balance that we have, despite the continuing economic situation, which although it is gradually improving, is thought to be a long repair job
 Be aspirational but also realistic because 5,400 homes still produces 10,000 employees that will need employers, which, short of a miracle will be hard to find.
 Be better to grow more slowly and controllably than rashly and eratically
 Regain the trust in our elected representatives which in the last few years has suffered due to the assault that people feel has been made on their lives by threatening circumstances.
Bishop's Tachbrook Parish Council hopes you find this response helpful. If there are any aspects that you would like further information about we would happy to work with you.
02/08/2013
Bishop's Tachbrook Parish Council
Planning Lead : rRay Bullen

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Hello, I would like to object to the plans for building houses on harbury lane looking towards bishops tachbrook, I live at ryefields overlooking these fields and for this plan to go ahead is disgusting. There has been planning canceled in the past years for building on the same land so why now is it planned for again. This will devalue my property as I paid more because of the view and not a eyesore of a housing estate.The road system is overflowing now so with 1200 new homes and 2 cars per home how are the roads going to cope with that many more car on them. I also noticed no planning for new houses or traveler sites on the fields along kenilworth road, is this because most of the councilors and upper brass at warwick district council live in north leam .

ONCE AGAIN , I OBJECT TO YOUR LOCAL PLAN AND THE BUILDING OF HOUSES NEAR BISHOPS TACHBROOK

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I am writing to voice my objection and concerns about the revised development strategy.

Having attended several of the public meetings and discussed the proposals with representatives I feel that I must object to the current plan on a number of points.

TRAFFIC
It is widely known and accepted that there are issues with the traffic in the area around Europa way and the plan to develop up to 1200 homes within this area will generate a significant increase in the current traffic volumes.
I am concerned with the calculations and models being used to predict the expected increase in traffic as the numbers are significantly less than 1 car per household.
It is my understanding that a national model has been used to predict the number of cars yet t he average number of cars per household in the area is significantly more than this.
Much of the traffic mitigations are aimed at not making the current situation worse, and little has been done, or made public to validate the models being proposed. The recent junction changes for the new supermarket have not in my experience improved the traffic situation as the traffic lights mean traffic is forced to back up.

POLLUTION
There is currently a major health issue with pollution levels ABOVE the legal limit and and errors in the predicted numbers of cars adding to the traffic and the effectiveness of the traffic flow and bottleneck works will mean an INCREASE in this pollution health risk

FLOODING
During the recent periods of heavy rain, the cycle path and some houses newly built on the site of the old school have flooded.
This is with all the land off Europa way being farmland and hence available to soak away rainfall. The amount of water that runs off into the culvert is significant and building on the land will dramatically reduce the amount of soakaway and I am concerned that the current plans will not address this significant flood risk.
Should any existing homes flood after any development I would expect the council and or developers to be liable for any subsequent flooding and premium increases that may result.

There has been much discussion about improving traffic flow from the south of the leamington/warwick, indeed directing it around the towns. Surely it makes sense to actually build the homes to the North where all the traffic is heading.
It has been stated that land to the north cannot be built on unless there is no other places to build, yet the King Henry VIII land was protected from development, a condition of the building of the technology park and the council already has a legal obligation to resucr eht pollution - this surely will not be possible with the addition of all the extra traffic.

This plan proposes changes to the local area that have health and flooding risks that affect existing residents that have not been addressed or any mitigations adequately published.
I would need to see

1. A full independent health study on the pollution levels and the effects of increased traffic.
2. A review on the expected levels of traffic based on the currently demographic of the area and not a model that the council are allowing developers to use ( as quoted to me by a representative)
3. a full review of the flooding risk.

I do not know of a single home in the area that is not opposed to the proposed local development plan and I find it hard to accept that it will be pushed through given the clear issues that have not been addressed.

Dear Sir/ Madam
Local Plan Revised Development Strategy proposed developments to the South of Warwick
Please accept this letter as my formal objection to the "New Local Plan" document dated May 2012.
The specific areas I object to are, the housing proposals on:
1) Land at Europa Way and Gallows Hill
And also:
2) Land South of Sydenham and east of Whitnash
3) Land at Woodside Farm, north of Harbury Lane, Whitnash
4) Land west of Europa Way, Warwick
5) Land South of Harbury Lane
My objections are based on the following:
* Air pollution would suffer massively with the increase in traffic that would entail from the
development of the south side of Warwick etc. Currently the air pollution does not meet
European Directives so by adding 3000-4200 houses in this area I cannot see how this could
be improved in any way whatsoever, only that it would become much worse leaving the
residents of the area open to higher health risks associated with poor air quality. I believe that
this is now the responsibility of the Council to ensure that these directives are met (as it is on
the statute) so if Air Pollution was to increase as a result of the new developments I would
suggest they would open themselves for prosecution (possibly) for failing to ensure the health
of its residents or even endangering the health of its residents. Both My Daughter and my
mother suffer from Asthma, any increase in Air pollution would be detrimental to their health
prospects and it is on this point I strongly object.
* On the Understanding that we need further housing I can appreciate that the land the end of
Harbury Lane could be used. This would not lead to such infrastructure problems that people
would start to leave the area as they could not stand the hassles which is the complete
opposite of what is trying to be achieved (in creating a nice environment to live in) but any
further expansion could lead to the above.
* An additional 3000 houses on the south side of the town creates an imbalance to the area as
it would mean that with Warwick Gates and the proposed additions there would be around
4400 houses in that area with only 3 roads to get in to town? (Banbury road, Princes Drive
and Lower Avenue) Taking an average of 2 cars per family that would me there would be an
additional 6000 cars to add to the 2800 already in Warwick Gates. This is a wholly
Kenneth McEwan
8 Trinculo Grove
Warwick Gates
Warwick
CV34 6EG
unacceptable and unfeasible suggestion and myself would look at moving it already takes me
25 minutes some days to get from my house to the Coventry road in Warwick.
* Large estates lack social cohesion which leads to anti social behaviour and poor education
performance. This proposal is the same size as Warwick Gates, Chase Meadow and Hatton
Park all put together; what kind of community is likely to be born as a result of this
development? Especially as 40% will be social / council housing in an area with poor transport
links to the areas that give the most support to the under privileged i.e. the town centres.
* We think that such a number of new homes contradicts the vision that Warwick District
Council has, "providing a mix of historic towns and villages set within a rural landscape of
open farmland and parklands".
* Utilities, Services (Police, Dentists, and Doctors etc.) are all stretched to the limit now. With
both the major hospitals only accessible across congested bridges over the river Avon, we
fear for how long it will take emergency cases to get the medical resource they need. Siting
the vast majority of the Housing does not help this problem and indeed exacerbates it.
* The huge increase in traffic arising from at least 8000 new cars in this area will result in
pollution and add to existing air quality problems in Warwick and Leamington town centres. At
peak times the traffic along Europa Way (even as far as the J14 M40), Gallows Hill,
Tachbrook Road and Tachbrook Park Drive are grid locked, your proposed development is
situated right along these roads, simply adding to the congestion already experienced. So far
you have failed to fix the current problems and there is no evidence on your part to suggest
that you will, even for when this proposed development is complete on the contrary the town
planners admitted that the current situation would not get any better in the future. Recent
studies that were conducted noted that nearly 75% of all traffic was pass through traffic i.e. did
not reside in Warwick add extra traffic and you have a recipe for disaster.
*
* We see no sense in carpeting our green spaces with housing for a mobile population to travel
elsewhere. Our remaining agricultural land should be preserved to feed future generations.
As Stratford-upon Avon district council have released plans to build a new town /village of up to
4800 homes at Lighthorne Heath/ Ashorne Is there actually a need for such a huge new
development South of Warwick. Why did you not decide to create a brand new settlement within
the district (like Norton Lindsey) maybe below the A46/J15 inter-change where direct links to the
road network are very easily accessible? A new town there would have fantastic access to Dual
carriage ways and the Motorway network, New schools could be planned including Secondary
Education as most schools are full already
I do believe that some housing maybe needed for organic growth within individual communities;
however, I feel this should be decided at a local level with the support of the local people not
imposed from the Government in a top-down approach as it is at the moment and certainly not to
the numbers you are suggesting. Local sources put the number of required houses at approx
5500 this could be achieved organically by Brownfield and Windfall site development released
over the required period
I feel that the New Local Plan is more of a Developers Charter than a logically thought out
Strategic Housing Development Plan
We urge you to rethink the development placements radically; to look again at regeneration
possibilities in the towns, to work with owners and developers on imaginative schemes to bring
forward brown field sites and possibly a new village/town in a rural position for housing
developments.
I look forward to your response