Whitnash East (South of Sydenham)

I object to the amount of houses planned for this area.
Already there is approval for 209 houses. Anextra300 will place extra burdens on the facilities in this area.
It will also join the two individual communities of Whitnash and Sydenham by removing the green barrier between the two.

Extension of the existing area around Whitnash East as a suitable location for additional housing.

Insufficient access and exit to site as only one road is planned via the school and could potentially be unsafe for school children. If an accident occured at the roundabout to Sydenham Drive and Prospect Road it could cause a major blockage. 500 houses means potentially a minimum of 500 cards but more likely to be 2 cars per household, 1 for work and 1 for schoolrun etc. Another worry is insufficient access roads to the north of the town as from Sydenham to Warwick there are only 4 access roads across the river. In the event of flooding (we all know this can happen), major accident or any such incident a huge problem can arise due to traffic build up. Our hospital as you know is north of the river along with other major services, and with all other massive planned development south of the river between Leamington and Warwick the road network will be horrendous. Whitnash itself is becoming swamped with all the building that is taking place and the 500 houses planned will be taking away a much loved local walk down to the brook, it is our bit of countryside please leave it as it is for us, our children and our grandchildren and all future generations of Whitnash. Enough is enough go north of the river.

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 access road to this development will increase traffic at the entrance to Campion School and may endanger childrens' lives. The roundabout outside the school is already very busy with traffic going to the Asda supermarket.

The development to the east of Whitnash will have a significant detrimental impact on both the town and wider area. At present the railway line provides a clear boundary to the town and access to open countryside thus enhancing the quality of life of residents within the town. The proposals are excessive for an area that is already stretched in regard to the capacity of local schools, medical facilities and transport infrastructure. The area has traditionally been agricultural land, with historic interest and should remain as such. Flooding has also been a significant problem in the proposed area in the past and this development will only worsen this. Taking in to account the additional proposals around Warwick Gates, the area south of Leamington will be changed beyond recognition by the local plan. Such large scale development focused on such a small area is unsustainable. This is a development that the majority of residents within the district do not want and should not therefore be given the go ahead.

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.

Has Campion school agreed to this plan which could cause problems of speeding traffic and children going to school.
Also what is to happen with the railway crossing at the end of Church Lane. This would appear to be a natural way in and out of this new estate but the bridge would need to be redesigned and Church Lane itself would be unsuitable - so it would need to be pedestrian / bycycle access only

Affordability - can this be increased to 50% affordability
Also Lifetime Homes - can this be increased to 40%
There appears to be no mention throughout the document of Sustainable homes and it would be great to build all the new homes with solar panels, ground source heat pumps, insulated walls, roof spaces and double glazed throughout as a pre condition of any houses being built under this plan

Generally I am pleased to see an increase in use of brownfield land for housing. This should be extended by utilising the land next to Morrisons formerly intended for offices, and the Chandos Street car-park development for housing.
This will allow a reduction in numbers of houses at Whitnash East, an area of restraint. In particular I should like to see greater protection for the Local Nature Reserve and the up-stream length of Whitnash Brook. As a resident of 15 years I know the Nature Reserve is already depleted in bird species and the proposed development will damage it even more.

Too much traffic for South of the river.
devaluation of what was once an attractive village and conservation area.
Whitnash is and will continue to become more of a rat run, to avoid what is terrible traffic.
Flood risk. Any development so close to a river has to have an effect the run off has to go somewhere and all that permeable surfacer will be replacewd by hard landscape. green field s are being pushed further away from the village of Whitnash. The continued overdevelopment of Whitnash is unreasonable.

Representation (objection) relating to WDC Local Plan, Revised Development Strategy section 5.2, Whitnash and south of Sydenham.

Representation

Reference should also be made to Representation no. 47686 to LDF section PO4 that relates to the above proposed developments.

Section 3.1 of the Revised Development Strategy (RDS) refers to WDC's Vision "to make Warwick District a Great Place to Live, Work and Visit".

Section 3.4 states that the Strategy seeks to care for our built, cultural and natural heritage, to protect areas of special significance and to provide for appropriate transport, green and other infrastructure.

Section 3.5 states that the Strategy aims to promote the regeneration of the more socially and environmentally deprived areas and to support the rural economy. Reference is also made to the protection of biodiversity, high quality landscapes and other areas of significance.

Section 3.6 refers to health and wellbeing.

The RDS does not appear to acknowledge the threat to the health and wellbeing of the residents who will live in the lee of a high railway embankment where the prevailing winds are likely to concentrate the pollutants from diesel locomotives working hard on the climb from Leamington and brake dust from trains slowing on the approach to the town. Commercial pressures may well dictate that the 40% of affordable houses are built within this environment. Noise pollution cannot be discounted. It should be noted that there is no residential development on the Sydenham Estate close to the railway.
As regards the regeneration of the more socially and environmentally deprived areas, such as much of South Leamington and parts of Sydenham, the Strategy does not address this matter to any great extent. Part of this regeneration must take into account the need for residents of these areas to enjoy easy access to the countryside, a benefit taken for granted by residents of the more affluent areas. Green corridors with cycle tracks and footpaths along the length of the Whitnash Brook, for example, would facilitate access and provide, in conjunction with improvements to the Whitnash to Radford Semele bridleway, a traffic-free route from Whitnash to Leamington. It is hoped that such a route would reduce the need to use private transport. None of this could be achieved if the bridleway (not footpath as in the RDS) were to be severed or crossed by the proposed access road via the realigned Campion School.
This ancient bridleway between Whitnash and Radford Semele is an important part of our cultural and natural heritage and should not be put in jeopardy by the proposed developments. The development would also very adversely affect the high quality landscape between Whitnash Brook and Crown Hill, the highest point in the vicinity.
Finally, the aim to make Warwick District a "Great Place to Live, Work and Visit" will fail if it takes away from many of its residents those attributes that currently make this motto so appropriate. Imaginative use and improvements to what we already have will allow Nathaniel Hawthorne's vision of rus in urbe whilst walking from Leamington to Whitnash to be maintained for this and future generations.

Changes to Strategy

Because of its importance to Whitnash residents, and potentially to others from adjacent neighbourhoods, as a means of safe and traffic-free access to open countryside, it is proposed that the area be designated as a Country Park. It is as worthy of such designation as that proposed between Bishop's Tachbrook and Warwick Gates because of its current use and its rich network of public footpaths, bridleways and tracks. Such designation could also benefit the rural economy by giving the farming community the opportunity to diversify by providing services such as cycle hire, horse riding and refreshments. The loss to housing is small compared with the total number of houses required and the shortfall could be made up by small increases in the allocation to other areas.
Should none of these observations be deemed sufficient at present to justify deviation from the Strategy, it is suggested that the development be moved from its new position in Phase 1 to Phase 3 in order to allow mature consideration and discussion of these proposals and objections.
It is also requested that consideration be given to possible access from Fieldgate Lane, Whitnash, instead of via Campion School. This may be a cost effective solution, despite the narrow bridge at the end of Fieldgate Lane and, in conjunction with a broad green corridor to protect the Whitnash to Radford Semele bridleway, would meet most of the objections raised here. It would also have the advantage of making the new development a part of the Whitnash community instead of its belonging neither to Whitnash nor Sydenham.

As a local resident, I wish to make an objection to the above for the following reasons:

Far too much of the proposed development sites fall around the area of Whitnash, - an area whose road network, schools and amenities have suffered greatly in recent years with the addition of the Warwick Gates development.

Local Doctors surgeries and primary schools are already full to capacity and over subscribed.

To ease the pressure on the road network and already stretched amenities in this area, I feel the proposed development should be more evenly spread around the district.

I visited the display/exhibition of the Local Plan in The Priors some weeks ago and spoke to one of the staff who were answering questions from members of the general public on the Local Plan. I was told that there would be "employment and schools as well as housing". My point is that none of those already exist so why should this huge swathe of development be in one area and not more evenly distributed within Warwick District Council. Whitnash isn't even marked on the map on Page 25 of the Local Plan Revised Development Strategy brochure although development of this size would have a huge impact on the area.
Local schools and doctors' surgeries are already at capacity and local roads grid-locked at times when people are going to and from their schools and workplaces.
The number of proposed properties to be built seems excessive. There is empty property both residential and office/industrial and property currently for sale within the Leamington area. All this should be taken into consideration. The housing should be primarily for local people and people working in the area not people moving into the area and commuting to their place of work.

Whilst I fear that this development is a fait accompli my concerns are as follows:
1) The wildlife buffer along the Whitnash Brook provides an essential nature reserve which enhances the quality of life for Sydenham. residents.It is also much valued by those of Whitnash and Radford Semele.
On successive developments, developers have been allowed to encroach more and more on this margin so that the latest phase considerably overshadows the Reserve.
I would like to see the widest possible margin strictly maintained as shown on your plan on the reverse of the June 2013 leaflet, ie. that shown as dark green on the west side of the brook as well as that shown light green to the east.
Please do not give in to developers petitions and allow them to build as close as they an get away with in the interest of maximising their profit.
2) The Regia Via / Roman Road / track to Radford Semele from Whitnash. This ancient road should be preserved as a route running through the development on its existing East / West alignment preferably with features to highlight its ancient significance.These could be wood sculptures/ benches/ unique streetscapes etc.
3) Developers should be required to employ archaeological consultants as the site south of the Regia Via is featured on documents as being of some significance
4) Local history groups and societies should be allowed access to the site when work commences and for its total duration to observe /record / collect information that may emerge regarding its historical backgroud possibly in partnership with the archaeological consultants
4) Considering the traffic that this development will generate.
Even though it is now proposed to shift Campion School sideways to facilitate access, the traffic emerging onto the Asda Roundabout and Sydenham Drive will I fear cause severe problems at certain times. Currently the traffic between St. Marys Road junction with Sydenham Drive and the Radford Road traffic light junction makes emerging from the northern junction of Gainsborough Drive a severe problem, in fact it can be impossible.
Whilst the pedestrian lights do provide some respite they in turn cause traffic to tail back considerably especially when St. Anthony's School is either opening or closing.
In addition to this St Helens Road/ Prospect Road /Sydenham Drive is increasingly being used as a southern Leamington By- Pass by commercial and all other traffic. Indeed this was in fact what was proposed in the 1947 Town Development Plan.
The obvious answer to this traffic problem from the new development is to have a completely new access under the railway from Golf Lane at Whitnash.

I was horrified to discover the proposed plans for further development in the Whitnash area.

Over the last 10 years the green belt has been munched up by housing - Warwick Gates to mention one, factories and shops.

I understand that some of the plans propose building of houses (and sites for travellers) on green belt land at the end of golf lane and by woodside farm/ tachbrook road. After losing a wonderful view across to Warwick thanks to the building of the vast Warwick gates I feel compelled to urge you to reconsider the plans. I was bought up locally and loved living in Whitnash as it wasn't a town but was near one and it was also countrified but with excellent local facilities. Now I feel more and more 'boxed' in. The primary schools are overloaded, GP surgeries are being stretched in some areas. Extra housing will reduce the number of jobs available in the long run not forgetting the impact of pollution and disruption on the environment. We are encouraged to recycle and lessen our carbon foot print but these plans will only increase it. We now have foxes roaming the streets at night as their homes have been disturbed. It is so lovely to drive out on to tachbrook road and head towards Mallory Court Hotelas within 2 minutes you are in countryside. Also it's a very enjoyable ramble up the bridle path at the end of golf lane. I'm sure builders will be offering huge sums of money to build on land but it's all self centred greed. Whitnash is pretty much linked to Sydenham, Radford semele, and Leamington Spa. Do we need to encorporate Bishops Tachbrook as well. Our lovely area will no longer be distinguishable as being a separate entity but will be a merged blur like Coventry is. A place where I would not want to reside.

I have never voiced how I feel but I do feel very strongly about this and would feel the image of our community sliding away

see attached

If this is not the correct channel through which to do this then please let me know.

I have 3 main objections to the plan for the following area (which I will detail later)

1) The assumption of the need for growth
2) The disproportionate new development to the south of Leamington and Whitnash
3) Particular objections to the development East of Whitnash

1) The assumption for the need for growth should be challenged by those within the authority because
a) There are areas of the UK (Including parts of the West Midlands) where proposed new employment and associated housing could be easily facilitated on brown field sites giving a positive impact on neglected communities and infrastructure. These sites may well prove less profitable for developers - but private company profits must not come first
b) Students Housing - A considerable and increasing number of houses in Leamington have been converted into student accommodation. If student accommodation was built nearer to transport hubs (or indeed the university) these houses could be converted back into normal residential use. The district should consider stopping all future conversions of housing into student housing if it genuinely believes all of the proposed homes are actually needed by local communities
c) Shops - with the rapid rise of internet shopping the conversion of shops on the fringe of the town centre into residential use should be considered as a step towards solving the perceived housing issue
2) The disproportionate new development to the south of Leamington and Whitnash
The character of the Whitnash area has already been greatly scarred with the development of Warwick Gates, Dobson Lane, recent Chesterton Heights/Sydenham encroachment on the countryside and extension of the South Farm development. It is time that other areas of district share in the development (if indeed it is truly necessary).
May be we should wait until the HS2 decision is finalised and place housing in the areas close to the line which those to the north of the town seemingly consider will be blighted beyond use anyway.
3) Particular objections to the development East of Whitnash
a) This development is a typical 'Sprawl' brought about purely by the fact that a developer is already in ownership of the land.
b) The development of Warwick Gates has already led to issues surrounding the shortage of primary school places in the local area. These new houses will be even closer to Briar Hill and St Margaret's Primary so there will be even more parents chasing few places.
c) Some of the fields in question are often subject to flooding. Any work to reduce their flooding risk could lead to increased risk elsewhere.

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

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

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

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

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

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

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

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


Affordable Housing

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

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


SUMMARY

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

Housing density and release of land

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


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

SUMMARY

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

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

see attached

see attached

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear Sir

I wish to express my objections to the fact that the new local plan places the vast majorty of new housing to the south side on the district and much of it in and around Whitnash. This area has been subject to non-stop growth & development over the past 20 years and more and has in that time lost some of its identity as a separate town within the district. Traffic on even small resiential roads has increased because of parents travelling in to drop their children off at school to the extent it now poses a hazard for the many children who do walk to school in Whitnash. Parking on our streets and particularly near facilities such as library and post office is a real problem - it is rare to find a legal parking place with cars parked on double yellows and, at the acre close shops, often backed up onto the main road. Routes from south leamington through to the north and to warwick are always busy, buses although overpriced are often overcrowded making them unpleasant and uncomfortable to use. To me it makes no sense that the plan refers on its front page to a "major sub-regional employment site in the north-east of the district" but NON of the housing is nearby. Surely this is just going to put more pressure on our roads and is not remotely sustainable.

As a specific interest to me as a resident of Home Farm Crescent is the proposal to put 500 dwellings east of whitnash. We overlook this site and as well as being important farmland and home to a good amount of wildlife, including otters, we have also noted the regular flooding of Whitnash brook which flows through/round this site. I have taken the liberty of attaching photos, taken earlier this year, to show how the brook regularly bursts its banks. It currently floods like this 3 or 4 times per year. Building on this site will just make this worse, and move the problem downstream towards Leamington itself.

It is simply unfair that the new development should all be built around areas which have already borne the brunt of so much of the regions growth. Please reconsider.

see attached

Dear Mr Barber

Warwick Local Plan - Revised Development Strategy Consultation

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

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

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

Thickthorn, Kenilworth

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

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

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

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

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

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

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

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

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

Whitnash

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

South of Gallows Lane/west of Europa Way

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Dear Dave,

Consultation response to the Preliminary Community infrastructure levy (CIL) Charging Schedule

Thank you for the opportunity to comment on Warwick District Council's Preliminary CIL Charging schedule and supporting documents.

The County Council supports the intention of introducing the Community Infrastructure levy within Warwick District.

Planned growth within the District Council will place pressure on the services we provide. We wish to make it clear at the outset that it is unlikely that other sources of funding, including our own resources, will be available to subsidise the commensurate expansion of supporting services. This may mean that some infrastructure projects are delayed or potentially never built. Careful consideration needs to be given when prioritising infrastructure projects against the pressures of growth and we recognise the difficult balance that needs to be struck. We look forward to working with you to achieve the most effective use of any CIL resource.

The delivery of the necessary infrastructure will largely depend on strong and close partnership working. We need to work together on a continuous basis to bring about the timely delivery of the necessary infrastructure to deliver the sustainable ambitions for growth.