1 - DS9

Deletion of E1 : Land North of Gallows Hill, Warwick

The land north of Gallows Hill was allocated for employment purposes in conjunction with, and as part of, the allocation of the Strategic Urban Extension to the south of Warwick and Leamington. (Paragraph 2.39 of the Publication Draft Local Plan refers.) William Davis and Hallam Land Management object to the deletion of this site for employment purposes for the following reasons:

1. The site was assessed as part of the Strategic Employment Land Study (October 2014) and is included as one of the 'Potential Strategic Employment Sites' (Appendix B refers). Of the criteria against which the site's suitability was assessed it had a significant number of high scores, as summarised below:

High: o suitability of site for intended use;
o suitability of site for targeted growth sectors;

Good: o accessibility to strategic transport network;
o links/proximity to areas of high unemployment;

Positive: o neighbouring uses;

Reasonable: o accessibility by public transport;
o relationship to strategic corridor.

1. In conclusion, it was stated the site was "Excellent location for research and development and IT companies but relatively small in size" (although as large or larger than the other two employment allocations). In these circumstances, and in view of the policy imperative to support economic growth by ensuring that sufficient land of the right type is available in the right places and at the right time, it is not considered that such an eminently suitable site for employment should be de-allocated. On this basis, it is considered that the Plan, as proposed to be changed, is not sound because it is not consistent with national policy nor is it justified as it is not the most appropriate strategy when considered against reasonable alternatives.

2. If the justification for the site's re-designation as a residential allocation arises as a result of the Council's recognition of the case made on behalf of William Davis and Hallam Land Management in their representations to the Publication Draft (that additional land needs to be allocated for housing in sustainable locations), there are other more suitable sites available, not least of which is the land south of Gallows Hill. The suitability of this site was recognised in earlier stages of the Local Plan's preparation and has been expanded upon in submitted representations.

3. If the deletion of this allocation proceeds, the strategic urban extension to the south of Warwick will not deliver a sustainable community providing not just the homes, services and facilities which people require but also the jobs which residents should be able to easily access by sustainable modes of transport.

The "justification" for the allocation of the land at Stratford Road for employment purposes is that it is an alternative employment option to the land north of Gallows Hill. It is therefore reasonable to presume that it would have been assessed as such. However, by reference to the Strategic Employment Land Study (October 2014), there is no reference to the site. Without any assessment of the site's potential for employment, it is impossible to compare and contrast its suitability for this purpose. Some information is provided in the Sustainability Appraisal of the site but, in comparison to that contained within the Strategic Employment Land Study, it appears to be based on a subjective premise that it "is not being allocated for housing as it is considered to be more suitable for employment" which cannot be described as a ringing endorsement of the site's suitability for development.

One aspect of the site's assessment which appears to be lacking is that in respect of Heritage. In view of the acknowledged proximity of the site to some Listed Buildings, a Registered Park and Garden, Warwick Conservation Area and a Scheduled Ancient Monument, it is reasonable to expect that this matter would have been given more attention in the supporting evidence even if there are "significant" barriers between the development site and the historic assets, including the river.

For this reason it is not considered that the allocation of the land at Stratford Road for employment purposes is sound as it is not justified as it is not the most appropriate strategy when considered against the reasonable alternatives.




Site H01 : Land West of Europa Way, Warwick

Representations have been made to the proposed deletion of the employment allocation on this site (known as Land North of Gallows Hill) on the basis that it is not justified, in that it is not the most appropriate strategy when considered against the reasonable alternatives and the associated evidence; hence the Plan is not sound. Not only is the site to the north of Gallows Hill eminently suitable site for employment purposes but as such, it should form an intrinsic part of the sustainable urban extension to the south of Warwick.

It therefore follows that objections are raised to the re-designation of the site from employment to housing to form an enlarged allocation for housing to the west of Europa Way.

For the avoidance of doubt, William Davis and Hallam Land Management are of the opinion that the provision of additional housing to the south of Warwick is justified for the reasons given in their representations to the Publication Draft Local Plan.

The "justification" for the allocation of the land at Stratford Road for employment purposes is that it is an alternative employment option to the land north of Gallows Hill. It is therefore reasonable to presume that it would have been assessed as such. However, by reference to the Strategic Employment Land Study (October 2014), there is no reference to the site. Without any assessment of the site's potential for employment, it is impossible to compare and contrast its suitability for this purpose. Some information is provided in the Sustainability Appraisal of the site but, in comparison to that contained within the Strategic Employment Land Study, it appears to be based on a subjective premise that it "is not being allocated for housing as it is considered to be more suitable for employment" which cannot be described as a ringing endorsement of the site's suitability for development.

One aspect of the site's assessment which appears to be lacking is that in respect of Heritage. In view of the acknowledged proximity of the site to some Listed Buildings, a Registered Park and Garden, Warwick Conservation Area and a Scheduled Ancient Monument, it is reasonable to expect that this matter would have been given more attention in the supporting evidence even if there are "significant" barriers between the development site and the historic assets, including the river.

For this reason it is not considered that the allocation of the land at Stratford Road for employment purposes is sound as it is not justified as it is not the most appropriate strategy when considered against the reasonable alternatives.

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Warwick District Council Local Plan - Focussed Modifications and associated Sustainability Appraisal

Proposed additional Gypsy and Traveller site off Stratford Road, Warwick and associated Sustainability Appraisal

Thank you for providing an opportunity to comment on these proposals.

My consideration and response is based on the expectation there has been a proper assessment of the significance of heritage assets affected, including their settings ; and the proposals support the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework (NPPF), with one of the core dimensions being the protection and enhancement of the historic environment .

The NPPF requires Local Plans, as a whole, to set out a positive strategy for the conservation and enjoyment of the historic environment. This means ensuring that the sites which it is proposing to put forward for development, will assist in delivering such a strategy and not contradict it.

Employment land allocation on land off Stratford Road, Warwick
This stretch of the Stratford Road is a surprisingly understated and pleasant entrance to Warwick from the M40. It's positive characteristics should be recognised to inform strategic landscaping and moderate highway works which may be required to facilitate any future development.

The proposed allocation is adjacent to Longbridge Manor, a Grade II* listed building with circa 14/15 century origins. The Manor is served to the south by a pleasant 'rural' lane and entrance. Development immediately to the east will affect its significance.

Opposite the site is the Old House and its ancillary barn, both Grade II listed buildings. Beyond to the east are the Warwick Castle Park (Grade 1) and Warwick Conservation Area.

Unfortunately there appears to be no evidence to demonstrate a consideration of how the proposed allocation site contributes to the significance of these designated heritage assets, particularly Longbridge Manor (NPPF Paragraph 129). Neither is there evidence to demonstrate where development may be inappropriate because of its positive relationship to adjoining heritage assets (NPPF Paragraph 157), or how harm might be avoided (NPPF Paragraph 152). The commentary in the SA is rather rudimentary and dismissive, failing to provide an accurate or reasonable assessment of the impact of future development.

The selection of sites for development needs to be informed by the evidence base and the Plan should avoid allocating sites which are likely to result in harm to the significance of heritage assets. Where adverse impacts are unavoidable and justified, in accordance with the NPPF, the Plan should consider how that harm might be reduced and any residual harm mitigated. This could include measures such as a reduction of the quantum of development, avoiding locating development within a particular part of the site, ensuring reinforced strategic landscaping, and limiting the height and volume of development.

Without such evidence Warwick DC cannot assert that the allocation and the amount of development proposed (11.7ha) can be delivered without causing harm to heritage assets of national importance contrary to explicit legislation and national planning policy. Consequently I remain concerned that the Local Plan as proposed is unsound.

It is important to note that:-

- great weight should be given to an assets conservation and the more important the asset, the greater the weight to the assets conservation there should be (NPPF Paragraph 132);

- special regard must be given to the desirability of preserving the setting of a listed building (S66, Planning (Listed Buildings and Conservation Areas) Act 1990;

- development will be expected to avoid or minimise conflict between any heritage asset's conservation and any aspect of the proposal (NPPF Paragraph 129).

Following the ruling in Barnwell Manor Wind Energy Limited v East Northamptonshire District Council, English Heritage, the National Trust and the Secretary of State for Communities and Local Government [2014] EWCA Civ 137, considerable importance and weight should be given to the desirability of preserving the setting of a listed building. Less than substantial harm does not equate to a less than substantial planning objection. There is a presumption that preservation is desirable.

Further analysis is therefore vital. I would strongly recommend the application of The Setting of Heritage Assets (English Heritage, 2011).

Gypsy and Travellers Site on land off Stratford Road, Warwick
The secondary/indirect impact of the proposal should be considered. For example could the 'rural' character of the lane serving the site, and the Grade II* Longbridge Manor, be retained as a consequence? Are intrusive highway works to facilitate the development required? How might these issues be addressed?

Change of proposed uses on Land North of Gallows Hill, Warwick
English Heritage acknowledges the potential for development to the north of Gallows Hill /west of Europa Way, but the implications of a stadium on Castle Park and the intermediate historic landscape must be appreciated, as should the consequences of accommodating additional traffic through the town. I will avoid repeating again the reasons why evidence to inform the principle and form of allocations is required. Needless to say I consider further work is necessary.

I look forward to further updates in due course. Do contact me to discuss any of these matters at your convenience.

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This is a further representation on this part of the Local Plan following publication of new information by the District Council.

The consultation process for Warwick District Council's Publication Draft Local Plan is seriously flawed. As we highlighted in our response to the previous consultation, policies that depend on the Strategic Economic Plan ('SEP') are not justified because key evidence was missing. The current 'focused consultation' is far too narrow to make good these fundamental flaws.

For example, the current consultation document makes no mention of the Strategic Housing Market Assessment ('SHMA') Addendum dated September 2014. This is a critical document that should inform the local plan and its omission renders the current consultation unsound. It appears that WDC is misleading potential consultees, resulting in an unsound local plan - it is not justified.

This consultation response outlines objections to new material and its relationship to earlier material:
1. Summary of issues with the Strategic Employment Land Study ('SELS');
2. Issues with the SHMA Addendum;
3. Issues with the Sustainability Appraisal ('SA'), including the recent SA addenda.

This focused consultation response adds more weight to our previous submissions that the proposed local plan is unsound and it policies are not justified.
Summary of Issues with the Strategic Employment Land Study
The SELS claims that it provides a robust evidence base for the Strategic Economic Plan ('SEP') produced by the Coventry and Warwickshire Local Enterprise Partnership ('CWLEP'). However, the SELS's recommended scenario is based on the CWLEP's own prediction of new jobs. The SELS is neither independent nor robust evidence - it depends on circular arguments. Its call for two or three new sub-regional sites is based on impressions of the chosen consultees rather than substantiated evidence.

The SELS's forecasts of demand for employment land yield vastly differing results with the highest figure being nearly 6 times the magnitude of the lowest. There is no satisfactory explanation for either this very wide disparity or for other conflicting trends across forecasts. The chosen forecast is likely to prove wildly inaccurate.

The SELS forecast based on Cambridge Econometrics' Baseline requires 201 hectares and is stated to be the minimum amount of employment land to meet the CWLEP's plans. The SELS ignores the fact that this forecast is significantly higher than the alternative forecast (Experian's) used in the SHMA Addendum.

In contrast, the SEP claims that the Employment Land Review recommends 250ha. Yet the SELS now recommends that its 'growth figure' of 326ha should be used as a minimum estimate of need. The SELS 'growth figure' is predicated purely on the CWLEP's unsupported prediction that its City Deal would create 8,800 new jobs in advanced manufacturing and engineering by 2025. The SELS takes this figure at face value, without subjecting it to any form of independent verification, and compounds it with unvalidated assumptions. The SELS thus alights on the resulting number as its recommended demand figure, apparently for no better reason than it is what the CWLEP would like to see in order to promote its interests. No justification is given for compounding high growth on a highly optimistic/risky forecast of demand.

On the supply side, SELS starts with a figure of 353ha of available employment land and applies invalid discounts and unjustified reductions until this figure is reduced below the now grossly inflated demand figure. This artificially shrunken supply figure still fails to take proper account of the planned new 100ha employment site at Gaydon. Despite all of these highly dubious exclusions, the SELS still acknowledges that 197ha of employment land is available.

When evaluating strategic employment sites in the LEP area, the SELS acknowledges that planning policy such as Green Belt is relevant but then the skewed selection criteria chosen by SELS omit this key consideration. For example, the SELS does not even mention that Green Belt is precluded from a presumption in favour of sustainable development. Also omitted is another key criterion for large strategic employment sites, particularly logistics sites: namely, direct rail connection. The SELS grossly undervalues rail-connected sites such as DIRFT3, Birch Coppice and Daw Mill.

Despite recognising that the greatest socio-economic need is in the north of the CWLEP area, the SELS uses a Site Appraisal Assessment Methodology that depends on very selective and short-sighted measures. This highly questionable methodology results in good assessments for sites in the south of the area regardless of how ill-served they are by public transport from the area of greatest socio-economic need in the north.

Based on its methodology, the SELS claims that "Coventry and Warwickshire Gateway (Zones A and B) in particular satisfies all the strategic sites criteria." This amazing claim is despite the fact that:
* It is in the Green Belt;
* Access requires extensive off-site highway improvements;
* There is no direct rail link;
* There is serious contamination;
* There is currently poor provision of facilities and amenities;
* There is currently poor public transport accessibility to the site;
* At best, there would be only moderate access to A roads (from Zone A in particular);
* Emergency access (to Zone A) is very restricted in a cul-de-sac passing directly adjacent to Coventry Airport's runway end;
* It is not in the north of the CWLEP area where socio-economic need is greatest;
* It has negative environmental impact.
Additionally, twelve of the SELS's Potential Strategic Employment Sites are identified as being a good match to the CWLEP's strategy, all offering good alternatives to the Gateway. However, even this list of 12 alternatives is an under-estimate because others sites are unjustifiably criticised. Additionally, key strategic sites on the periphery of the CWLEP area, such as DIRFT, the MIRA Enterprise Zone and Blythe Valley Business Park, are omitted without justification. Put simply, there is no shortage of alternative sites.

The recently published version of the SELS has clearly been written with a view to providing, for the already 7-month-old SEP, post-hoc justification for a stream of questionable assertions and heroic assumptions in the SEP, which reflects long-held aspirations. The SELS is nowhere near good enough or cohesive enough to meet even that very limited objective. Its many technical weaknesses and its inherent bias mean that it cannot be taken seriously as an independent assessment of the need for, and supply of, employment land in the CWLEP area. It does not provide a valid justification for development of the Gateway site.

The new evidence does not provide a robust evidence base for the proposed policies in the emerging WDC Local Plan. Multiple forecasts are provided in the various new reports and these forecasts diverge greatly. The SHMA Addendum has one forecast - by Cambridge Econometrics - that is 45% higher than the other (Experian's). The SELS is based on the higher of these forecasts but then it chooses an even higher forecast - its higher growth forecast that is 62% higher again - as the basis of its recommendations. None of these choices of forecast is justified adequately.

The recommendations in the SELS are based on the LEP's prediction of jobs growth; the SELS is neither independent nor robust evidence. The LEP's SEP claims to be supported by the SELS even though the SEP pre-dates the final version of the SELS by 7 months. Such circular arguments are fatally flawed.

The SA makes it clear that the policy to create a new Sub-Regional Employment Site is dependent on the claimed economic benefits. Such claimed benefits are highly speculative. Site selection ignores key constraints such as Green Belt. The SA is unsound and proposed policies are not justified.

The further information we have provided in this focused consultation response adds weight to our previous submissions that the proposed local plan is unsound and it policies are not justified. In particular, it adds to our previous submissions that proposed policies DS16, DS8, DS9, DS19, EC1 and EC3 are unsound and unjustified; the remedies remain as we have previously submitted.

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I am writing to object to the proposal to site employment land on the fields opposite my house. The objection is based on the following:
* The council proposal is flawed in that it states the land is predominately brown field, when it is not - over 30 acres of this land is greenfield, and identified as green space in the existing local plan
* There is no need for new employment land when the existing site of Tournament Fields (approved in 2000) is still far from fully sold / developed, and at the rate of development to date, will still have capacity well beyond 2025
* The land is adjacent to at least two significant listed properties, and this will adversely affect their standing, in an area of historical significance, as identified by Warwick County Council.
* Development of the land for employment will result in a significant increase in traffic on the A429 - main artery route into Warwick. Only recently the A46 flyover was built at huge expense to reduce traffic in this area, and ease congestion, and yet already traffic queues have started to return to this area, and if this land is developed (along with that at Tournament Fields already so earmarked) then the traffic congestion will mean significant delays getting into and out of Warwick, which will significantly affect the Tourist industry and existing businesses.
* This land is the last, attractive, area of green on the run in to Warwick, and is identified as greenfield on the existing local plan - for t he overall appeal of warwick to those visiting it should remain so.
* There already exist many brownfield sites that are not yet developed within the WDC area, that should be used before any encouragement is give to destroying green fields.

I urge you to accept this objection and reject the proposal to re-allocate this green field site as employment land.

see attached

The Save Warwick Group sees no objection to the proposal to allocate employment land off the Stratford Road in Warwick as an exchange for the land previously allocated for employment north of Gallows Hill.

We strongly object to the proposal for a football stadium in the latter location where it would form a serious physical and visual intrusion into the historic heritage landscape consciously designed by the Earl of Warwick in the late 18th century as a formal entry into Warwick from the south. The importance of safeguarding this area from the harmful impact of new development was picked up by the inspector at the examination into the existing local plan and was repeated by English Heritage in their objection to the local plan and to the subsequent application for housing on the Strawberry Field which lies to the immediate south of Gallows Hill. The need to protect this area from distant visual intrusions was reinforced by the appeal decision into the proposal for 125 houses at Mallory Road where the appeal was rejected due to the impact of the development on the settings of listed buildings and the views into and from St Mary's. The visual intrusion from the development of a football stadium in this location with its lighting towers and grandstands would be unavoidable and far more intrusive than the appeal site especially at night when the floodlighting will be a major source of light pollution.

The potential impact of developments to the north of Gallows Hill on the open area to the south that forms the context to Warwick Castle Park was fully appreciated by Warwick District Council in the 80s when they approved the Warwick Technology Park with the condition that it should be shielded by earth embankments and heavy planting with dense established trees. With this precedent it would clearly be desirable for this landscape strip to be continued along the northern edge of Gallows Hill within the county council's site to mask the residential development from the heritage landscape area to the south. Whilst this may be too much detail it is of sufficient importance to require it to be built into either the local plan or as a condition to be imposed on the development proposed to the north of Gallows Hill.

Local Plan Focused Consultation December 2014 including Stratford Road Gypsy & Traveller permanent site at Stratford Road.
from Bishops Tachbrook Parish Council

Part A - Personal Details

Sean Deely, Chairman, Bishop's Tachbrook Parish Council.

3. Notification of subsequent stages of the Plan.
Please specify whether you wish to be notified of any of the following

The submission of the Plan for independent examination Yes

Publication of the recommendations of any person appointed to carry out an independent examination of the Plan Yes

The adoption of the Plan Yes




Part B - Your representations
Representation 1
4. Which part of the plan does this representation relate?
Focused changes
Paragraph number REFERENCE 1.
POLICY number DS9
POLICIES MAP 2(Reference 5, 11 & 12)
5. Do you consider the Plan is:
5.1 Legally compliant? Yes
5.2 Complies with Duty to Co-operate Yes
5.3 Sound? Yes
MODIFICATION Delete 8ha employment land north of Gallows Hill & 3.7ha at Opus 40 & add 11.7 ha employment land at Stratford Road Warwick.
Bishop's Tachbrook Parish Council SUPPORT this amendment
Because a) It is a better employment location than Europa Way because it is immediately adjacent to the M40 junction 15. This would minimise any resultant traffic on Warwick Town Centre. The Europa Way employment location would have added significant additional employment related traffic on both Warwick and Leamington as well Europa Way itself and Greys Mallory roundabout and the links to junctions 14 and 15 on the M40. The modification is betteras it reduces traffic congestion, air quality in the towns, traffic noise to the new residential areas and global CO2 emissions.
b) It releases land on the 2 sites for residential use and in the case of Opus 40 increases the amount of brownfield utilised in the Urban area.
c) It improves compliance with Strategic Policies DS3 (b), (c), (e) & DS4 (a) & (c).


Part B - Your representations
Representation 2
4. Which part of the plan does this representation relate?
Focused changes
Paragraph number REFERENCE 2 & 3.
POLICY numbers DS11 & DS14 SITE : H01
POLICIES MAP 2(Reference 6 & 7)
5. Do you consider the Plan is:
5.1 Legally compliant? Not certain
5.2 Complies with Duty to Co-operate No
5.3 Sound? No
6. If you answered no to question 5.3 , do you consider the Plan unsound because it is not
Positively prepared No
Justified No
Effective No
Consistent with National Policy No
MODIFICATION Amend the following in relation to land west of Europa Way to increase number of dwellings from 1,190 to 1,300 and add Infrastructure requirements and other uses : add "Community Stadium and associated uses".
Bishop's Tachbrook Parish Council DO NOT SUPPORT this amendment.
Because a) The number of dwellings stated of 1,300 does not reflect the capacity of the site released. If 8ha of employment land is released and a community stadium is located on 3 ha then 5 ha is available for additional housing. The local retail, medical and community facilities, including 4 football pitches and a running track that is available for community use, are already allocated at the southern end of the recently approved 735 dwelling proposal. Hence working on 35 dw/ha, 5 x 35 = 175 to add to the declared 1,190. Hence 1,365 dwellings could be expected.
b) 35 dwellings per ha is the density accepted for market homes. However, 40% of the site should be affordable homes. To be affordable a density of 50 dwellings / ha can provide a perfectly spacious layout for affordable homes particularly where one and two bed dwellings provide a reasonable part of the mix, as is shown in countless examples around the country. The affordable and market homes should be mixed, giving a better distribution of open space.
If 1,190 homes are built at 35 dw/ha As the current frat of the Local Plan, they will occupy 34 ha. If 5ha. are added to that, then 39ha are available. If market homes are built at 35 dw/ha and affordable homes at 50 dw/ha, then the capacity of the whole site west of Europa Way is 1,550 dwellings. (60% of 1,550 = 930, at 35dw/ha requires 26.572ha and 40% of 1,550 = 620, at 50 dw/ha requires 12.4 ha. Total land requirement = 39 ha.)
c) Proposed "Community Stadium and associated uses". This is described elsewhere as a 5,000 seat stadium with conference and other facilities to make it financially viable together with associated parking and other external facilities. Bishop's Tachbrook parish council OBJECT to the location of such a development as inappropriate for this area west of Europa Way which is designated for over 1500 houses. It is out of scale with new garden suburb residential development and the massing of a stadium of this nature will be an unacceptable intrusion. A stadium designed for and occupied by a professional football club conflicts with
* the interests of families growing up in this new residential area and
* the traffic implications when match days coincide with normal peak times would be totally unacceptable on Gallows Hill and the roads around Warwick, Leamington and down to the Motorway which are already overloaded before any new housing is built
* light and noise pollution from evening and night time games that would be disruptive to the residents;
* problems of pedestrian and vehicular movements within the housing complex as crowds seek to get to the stadium.

Current trends are to move stadia away from residential areas, not to put them close to new garden town suburbs.
The proposal appears to be uncosted and the costs will be high in
* land costs (even if county land, it must be accounted for at alternative use value that could go to the County if released for housing) and
* construction costs for the stadium, pitch(es) facilities (Stadium ground not normally used for training so additional training area is likely to be necessary), parking
* running costs that are unlikely to be met by gate income even if there are conference and other facilities attached.
These decisions should not be made without a well costed business plan without which the club could get into serious financial difficulties and the District Council would not be able to bail them out. The Ricoh Arena in Coventry is an example of what can happen.
d) If the stadium is moved to this location, it will take land that could be used for housing, moving the housing further out towards the valued landscape of the Tachbrook Valley. The net car travel miles from housing and pitch activity will increase. This does not comply with the NPPF either for protection of the natural environment, protection of best & most versatile agricultural land and unnecessary increased car miles, so it is not a sustainable development.
e) If the land is used for housing instead, then the capacity of the land west of Europa Way increases to 1,670. (60% of 1,670 = 1002, at 35dw/ha requires 28.64ha and 40% of 1,670 = 668, at 50 dw/ha requires 13.36 ha. Total land requirement = 42 ha.)
The Opus site gives a further 100 dwellings. That is a total of 1,770 dwellings compared with the existing allocation in DS11 of 1,190 which is an additional 580 dwellings. Thus, any further encroachment into the Tach Brook Valley on either Grove Farm or Lower Heathcote Farm is not justified to meet the objectively assessed housing need.
f) The proposal does not comply with strategic policies DS3 (a), (d), (e), and policies Be1 (a), (f), (m), Be2 (d), (h), Be3 & TR2

Part B - Your representations
Representation 3
4. Which part of the plan does this representation relate?
Focused changes
Paragraph number REFERENCE 4.
POLICY number DS11
POLICIES MAP 2(Reference 9 & 10)
5. Do you consider the Plan is:
5.1 Legally compliant? Yes
5.2 Complies with Duty to Co-operate Yes
5.3 Sound? Yes
MODIFICATION Add new site under urban brownfield H39 - Opus 40, Birmingham Road, Warwick
Bishop's Tachbrook Parish Council SUPPORT this amendment for the reasons set out in our response to Reference 1 paragraph (b) and Reference 2 & 3 paragraph (e).
11 December 2014

Part B - Your representations
Representation on Stratford Road Gypsy & Traveller Permanent site.
4. Which part of the plan does this representation relate?
Focused changes
Stratford Road Gypsy & Traveller Permanent site.
5. Do you consider the Plan is:
5.1 Legally compliant? Yes
5.2 Complies with Duty to Co-operate Yes
5.3 Sound? Yes
Bishop's Tachbrook Parish Council SUPPORTS the proposed site off Stratford Road, for the use of permanent pitches for the Gypsy and Traveller community. In summary this site offers a larger number of positive characteristics than any other site proposed during the previous rounds of consultation.
Specifically this site can better meet the health needs of residents, with a number of GP surgeries and dental practices within walking distance: Warwick Hospital is only a short drive away. Educational needs are well served by a number of schools also within close walking distance.
Access to and from the highway for articulated vehicles is made safe with excellent sight lines along the Stratford road in both directions. Also this site provides excellent access to major roads, the M40 and A46 which is important for periods of touring.
This site is lower lying and the proposal would have minimal impact on the local landscape and create negligible visual impact, particularly with the proposed landscaping. Flooding risk has been assessed as low and we note that the ecology report is awaited.
Finally the site is well served by public transport and there are a range of amenities available in nearby Warwick.

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Longbridge has Rural Area status and as such nothing should be done which will compromise its character. There is already a large scale commercial development (Tournament Fields) standing half empty- across the main road from the site, so it is hard to believe that yet more commercial/industrial space is needed in the vicinity. Should this development go ahead a major thoroughfare into Warwick would be dominated with industrial parks on both sides of the road. The site is unique in that it is an open area of green space on the edge of the town giving views along to the Castle and historic battlegrounds - we should do everything in our power to retain it.

There needs to be balance and an appreciation of the pleasant open green space that will be taken away should this proposal go ahead.

With reference to the proposed site for commercial development on the Stratford Road:
A Council Survey recently referred to the land in question as follows:
'it is essential to consider....the landscape setting and the proximity to the M40.....the landscape setting of the river'; re the north section of the site.....'Flood risk and proximity to the sewage works are likely to be considerable restraints' re the southern side of the site....'flood risk, landscape setting and proximity to the M40 will limit potential development'
WDC would do well to heed its own words
In my opinion the initial proposal to use land off Europa Way would still be the better option. Road networks are already established and development here would not have a negative effect on Tournament Fields.
In studying the Sustainability Assessment I note that several objectives remain in question. The lower level assessments referred to should be addressed thoroughly before any informed decision can be made by the Council. This should be done in a measured and timely way, without undue haste to ensure the correct decision is made.
As things stand at present, the suitability of the proposed site is in doubt.
These issues need to be addressed:
an urgent assessment of the impact of development on traffic and existing networks which, in the words of the SA 'are not known'. I can vouch for the weight of traffic along the A429 at present. At peak times the traffic is at a standstill from the M40 junction to the Edgehill Drive roundabout which brings into question the wisdom of more development on this stretch of the A429.
an assessment of the potential for noise, air and light pollution for the neighbouring residents.
a noise and odour assessment due to the sewage works being so near. As a nearby resident I am only too aware of the frequent impact of odour on the locality at certain times.
an assessment of the possible negative effects on the River Avon with the presence of Priority Habitats of Coastal and Floodplain Grazing Marsh and Undetermined Grassland. The issue of negative effects on biodiversity should not be ignored. The cost of buffering should be examined for costs.
an assessment of likelihood of flooding and the 'potential minor negative effect'
a land quality assessment due to the proximity of the 'historic landfill site with the potential for contaminants'
With regard to any proposed development of the site the following issues need to be addressed thoroughly:
The visual impact of any development should take into consideration its situation at the Gateway to our historic town of Warwick. Immense care was exerted to ensure that the landscaping around Tournament Fields was fitting for a prestige Business park as befits its prime location on the approach to Warwick; this should also be an absolute requirement for anyone planning to build on the proposed site.
Adequate landscaped noise mounds as on the north borders of The Peacocks Estate would need to be established to protect neighbouring residents from the impact of development.
It would be totally inappropriate to consider any category other than B1 for this locality, high class office units along the A429.
It is not suitable for category B2, manufacturing as this would impinge on the aesthetic approach to Warwick and impact heavily in local residents in terms of noise and air pollution
Category B8 storage and distribution would likewise have a negative impact on the main route into Warwick
The road system is not capable of handling the increase in volume of heavy traffic that would inevitably ensue; the visual effect of large units would not be in keeping with the aesthetic aspect of approaches to Warwick.
In conclusion I feel that as the progress of the Local Plan does not hinge on the establishment of this site, time should be given to a full and thoughtful assessment of the issues I have listed. We should safeguard and reassure our town and its environs and not to anything in haste to jeopardise its future as one of England's prime historic tourist towns.

see attachement