3 - DS14

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.

I object to the provision in this revised local plan for a new sports stadium on farmland fronting Gallows Hill. The stadium will have a damaging effect with regard to light pollution, increased traffic on already over-crowded streets and the fact that it will be a visual eye-sore detracting from the historic surroundings of the parkland setting.

I object to a specific sports stadium being built in a proposed residential area in the previous local plan. small local play areas and other small local open spaces are justified within the proposed residential area. However, a relatively large open space for a football stadium will have a damaging impact on the amenities of the new residential area through: on street parking and movements of traffic from treams and spectators through the residential area, predominently at weekends when children will be around: noise pollution in a residential area: physical and visual intrusion of grandstands and lighting pylons: light pollution from the floodlighting: the site of the stadium is on a prominent hilltop and the pylons and stands will stand out for miles around and will intrude into views of the Grade 1 Listed Castle Park: the floodlights, which will be required to be lit every evening, will be intrusive in a residential area.
The community need cannot be met by a prescriptive, perimeter controlled football stadium. A lower key sports/social facility available 24/7 for all sections of the community self-run by the community would be more appropriate.

1) A football stadium is a totally inappropriate development within a proposed residential area, and there seems to be no justification for moving it from a perfectly adequate existing site on Harbury Lane. If a move is essential, then the proposed Country Park to the South of Harbury Lane appears to be a better location, where the stadium would be far less intrusive to its neighbours.
2) The proposed site is in a prominent position where its stands and floodlights would scar the skyline as seen from Warwick and much of the surrounding area, especially the outlook from the castle. The historic context of the castle and Castle Park would be irretrievably damaged. The area should be given such protection as was included in previous developments, such as Warwick Technology Park.
3) A stadium would be of benefit to only a very small number of local residents, but all of the Warwick area would be seriously affected by increased traffic (which the road system cannot accommodate) and the associated parking and exhaust pollution issues. These are issues that have already been raised many times with regard to the excessive housing developments currently proposed for Warwick, and no satisfactory solution has been forthcoming.
4) Noise pollution and light pollution from floodlights (potentially over a wide area) are also important issues that do not seem to have been considered in proposing this location.
5) It is highly probable that community amenities and sports/recreational/play facilities would be curtailed if such a development should go ahead, in order to avoid substantial reductions in the housing numbers that WDC seems intent on providing, in spite of clear evidence that such high numbers are not required.

The Town Council have no adverse views regarding the use of Leamington Football Clubs ground as a site.

However, the Town Council would not support the football ground being relocated to a site on farm land off Gallows Hill.

The sports stadium will impact directly on the residential development of the area and Leamington Football Club does have expectations of moving up in the football leagues and will want to build a stadium with parking etc. commensurate to those hopes and expectations.

In the interests of present residents and future residents the Town Council considers that the proposal should be resisted and removed from the Plan for the following good planning reasons:

i) A football stadium will have a damaging impact on the residential amenities of the residential area.

The loss of amenity will derive from on street parking, traffic movement, possible high levels of spectators through the residential areas, particularly on Saturdays and evenings and which will not be acceptable to residents.

ii) Attendees at the games and those going to and from the games will create noise nuisance.

iii) The grandstand stadium and associated works including the pylons for flood lighting, will be visually intrusive.

iv) The flood lighting will without doubt be a source of light pollution to residents whenever lights are required for games or training.

v) The intrusion of the stadium buildings and pylons will be exacerbated by their location on a prominent hill top and this will intrude upon views from Warwick Castle and the Collegiate Church of St Marys. A consideration supported by the Planning Inspectorate, as demonstrated by the recent appeal decision.

A stadium development would be most obtrusive, not only effecting the landscape from the Castle and Church, but also impacting on the Grade I listed Castle Park and the landscaped approach area to Warwick, which the Planning Authority have in the past been protected, but now appear ready to abandon.



To prevent an excessive visual or other dominance of an area by a sports stadium the Government's advice is that any sports stadium should be judged on high standards not only of design and landscaping but also on siting. It is also expected that a sports stadium would have high levels of community support for its development. To locate a stadium at the proposed location would not meet the criteria regarding siting or community support.

The open space area will be lost to the community forever and the area is an open space warranting protection in its own right. However, a sports stadium will not only will it impact on the immediate and local residential area, but also a stadium will impact on the historic landscape of Warwick.

Furthermore, the impact of a football ground in a residential area is fully known to the District Council for there is the comparatively recent example of the Brakes Ground being relocated.

The Government's Planning Policy statements do not contemplate a football stadium as part of a provision of a new area of open space, in connection with the provision, and in association with residential development and the use of land for public sport and outdoor recreation. No value is being placed on those green areas of Warwick, but only the possible financial interest of the club and the need for a Gypsy and Traveller Site, rather than the views of the whole community and the impact of a football stadium on the community.

see attached

Reference 3 (OBJECT)

Under Policy D14 the Publication Plan allocates land for a 'Community Hub' which we are informed would include a "community sports complex". Under paragraph 2.63 in the same version of the Plan we are also informed that the sports complex "...could include a small stadium with complementary uses, should such a scheme be viable". In written representations to Publication Draft Local Plan the Consortium also drew attention to the fact that in the officer's report on the Submission Draft Local Plan, which was presented to the Full Council & Executive Committees (23 April 2014), officer's stated that the stadium proposals are associated with the relocation of Leamington FC from their current site located on Harbury Lane approximately 2km beyond the urban edge of Whitnash; a site which the District Council has separately identified as one of their preferred sites for meeting Gypsy and Traveller needs. In the same committee report officers' also suggest that other 'complementary' uses include land to assist with parking problems currently experienced at Warwick Technology Park. From what is now proposed in the Focused Consultation document, it is clear that it is a football stadium which is, and always has been, central to the Community Hub idea.

Whilst the District Council and other stakeholders may wish to see Leamington FC relocate their existing stadium, the Consortium is not aware of any detailed proposals for, or evidence base to support a new 'Community Stadium' at this location. The site for the stadium is not only in a location which we feel would raise amenity concerns for existing and future residents, due to visual impact, noise and traffic, but it is also proposed is in a location which is at odds with other policies in the Draft Local Plan, in particular Policy CT1 which encourages such facilities to be located in town centre locations.

Finally with specific regard to the matter of viability we are unclear how such a facility would be funded as this item of infrastructure is not included in the Draft IDP. How big is a 'small stadium'?

For the aforementioned reasons the Consortium remains opposed to the Council's proposals for a new Community Stadium and "associated uses" on Land at Myton/West of Europa Way (Strategic Site H01).

Reference 5 (SUPPORT)

The Europa Way Consortium supports the proposed amendment to Policies Map: 2 so that it reflects the removal of land allocated for employment in the Publication Draft version of the Local Plan.

It is our considered view that the southern part of the Land at Myton/West of Europa Way (Strategic Site) should not be allocated for employment for the following reasons:

* Whilst the site does sit adjacent to Warwick Technology Park (WTP), there are no existing pedestrian or vehicular links between the two and, given existing development on WTP and local topography (WTP sits in a 'bowl'), there is no recognised prospect of any being established in the future. Therefore we strongly disagree with previous suggestions that having employment in this location would serve as a natural extension the existing Technology Park.
* Having regard to the existing employment land supply within the District we contend that there will not be the market for additional employment land in this part of the District, during the first phase of the Plan. An argument supported by the Council's recent decision to grant planning permission for housing on allocated employment sites, including a site located opposite off Heathcote Rd/ Harbury lane.
* If there were a delay in the take up of employment land on the Strategic Site it could have a detrimental impact on the wider proposed urban extension, in particular the delivery of new infrastructure including a proposed spine road which would link Gallows Hill (road) with Europa Way (A452). The spine road is not only proposed as a public transport (bus) route, but would provide convenient pedestrian and cycle access for those children from the Warwick Gates area who currently attend Myton School or would attend the School in the future.
* A major employment allocation at this location would also generate significant traffic movements and therefore would be detrimental to opportunities to secure safe and convenient pedestrian and cycle access to Myton School for children in the wider area, but in particular those from Warwick Gates and the planned urban extension south of Harbury Lane.
* A major employment allocation at this location is considered incompatible with residential proposed on the same site. In particular the amenity of residents is likely to be compromised in terms of visual impact, noise and traffic especially at peak periods.

* General Industrial (B2) employment is considered incompatible with B1 uses and clearly at odds with the Council's stated reason for allocating employment in this location (paragraph 2.32). Having B2 on the same site as B1 will dissuade most high-tech office based companies from investing in the site because they would be concerned over the type of neighbouring employment use which might come forward at a later stage.

* The southern end of Land West of Europa Way commands an elevated position compared to land to the north, west and south. It is therefore considered that the visual impact of large offices will be harder to mitigate than 2 to 3 storey houses which offer more flexibility in terms of mitigating their visual impact through the physical arrangement of units/ roof lines and tree planting throughout the site and other screen planting.

Finally with specific regard to the Land at Myton/West of Europa Way (Strategic Site) we consider that by simply providing residential development within this part of Warwick, the result will be a more sustainable pattern of development through the creation of a better mix of land uses. The strategic site is already surrounded by retail, education and employment opportunities which are within easy walking /cycling distance including. With regards to the latter opportunities are not limited to Warwick Technology Park (WTP) but also Tachbrook Park, Spa Business Park and Heathcote Industrial Estate.


Reference 6 (OBJECT)

Although it is inferred that the Proposed Modifications results in a change in the housing allocation depicted on Policies Map: 2, no such change has been made. Policies Map: 2, in both the Publication Draft and Focused Consultation versions of the Local Plan depicts all of the Land at Myton/West of Europa Way (Strategic Site) as being allocated for residential, with other land use allocations overlapping, such as those for employment, community hub/stadium and/or education. The Policies Map should not have the same area of land allocated for different land uses unless a dedicated mixed-use scheme is proposed, which, in this case, it is not.

Recommendation: It is recommended that Policies Map: 2 is amended to only show Land at Myton/West of Europa Way allocated for housing and education.


Reference 7 (OBJECT)

For reasons set out in our response to Proposed Modification reference # 3, the Europa Way Consortium does not support the allocation of Land at Myton/West of Europa Way for a sports stadium and therefore requests that the allocation is deleted from Policies Map: 2.
Land at Myton/West of Europa Way


Reference 8 (OBJECT)

The Consortium wishes to take this opportunity to restate that boundary for the 'Major Education Allocation' (DS12) on Land at Myton/West of Europa Way is incorrect on Policies Map: 2 in both the Publication and this, the Focused Consultation, Draft versions of the Local Plan.

Historically the Consortium has been informed by WDC and Myton School that 9.18 hectares (22.3 acres) of land is needed south of the existing school boundary to deliver the proposed new Education Campus. To help facilitate this, the Consortium and WCC-Property (who own the adjacent site) have agreed to safeguard the following: 2.06 hectares (5.4 acres) on County Council held land with the balance 7.12ha (17.3acres) being safeguarded by the Consortium. These respective areas and proposed amendments to the policy boundary are shown on the attached plan and align with Illustrative Masterplan for outline planning applications Land at Myton (Application No. W/14/1076; approved 5/12/14) and Land North of Gallows Hill (Application No. W/14/0967).

Recommendation: Amend the Major Allocations (DS12) boundary on Policies Map: 2 so that it aligns with the land safeguarded for education on the Illustrative Masterplans for Land at Myton (Application No. W/14/1076) and Land North of Gallows Hill (Application No. W/14/0967).

1. Small local play areas and other small local open spaces are justified within the proposed residential area. However, a relatively large open space for a football stadium will have a damaging impact on the amenities of the new residential area through:-
a. on street parking and tidal movements of traffic from teams and spectators through the residential area, predominantly at weekends when children are likely to be around
b. Noise pollution in a residential area
c. Physical and visual intrusion of grandstands and lighting pylons
d. Light pollution from the floodlighting
2. The proposed Country Park to be established to the South of Harbury Lane appears a better location where the stadium can contribute to the viability of the open space and be less intrusive to neighbours.
3. The proposal would result in a reduction of the numbers of houses which can be constructed on the site and by doing so would lead to the need for most Greenfield areas to be taken elsewhere in order to meet the Council's targets for housing in the district.
4. The site of the stadium is on a prominent hilltop. Its pylons and stands will stand out for miles around and will intrude into views from Warwick Castle and from St Mary's Church. The recent rejection of the planning appeal at Bishops Tachbrook shows the concerns that the Planning Inspectorate has over the need for protection of the context of listed buildings and we heed to apply that lesson in this case.
This proposal is potentially even more damaging by intruding into the context of not only the buildings referred to above but also into views of the Grade 1 Listed Castle Park and into and out of the historic designed landscape area adjoining the Banbury Road. This forms an approach to Warwick which has been protected over previous iterations of the local plan and even by the District Council in the conditions attached to Warwick Technology Park. The latter required a deep landscaping strip to protect the area from the potential intrusiveness of the new developments there.
5. Surely the Council will appreciate the inappropriateness of a professional football club being located in a purely residential area. (the "Brakes" ground was moved from Tachbrook Road years ago for this reason and even the Coventry City Football ground was relocated to an area far from any residential area).
6. There is a perfectly adequate football ground at Harbury Lane for the club and while we do not know the inducements the council has offered to the club to move, any contribution the council makes to the development costs represent lost opportunity for investment in other infrastructure which benefits the local community at large rather than caring for the interests of a small community, the investors in Leamington Football Club.

The community need cannot be met by a prescriptive, perimeter controlled football stadium, but should be provided for by means of a lower key sports/social facility making possible a wide range of sports and recreational activities which are accessible 24/7 for all sections of the community self-run by the community.

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.

see attached

see attached

see attached