Mod 14 - Policy DS15

I wish to have my serious concerns and objection noted regarding the proposed New Local Plan for the following reasons:
1. The proposed modifications may address the shortcomings of the local plan which were identified by the Inspector in his letter dated June 2015 which followed his examination dealing primarily with the numbers of houses to be provided in the new plan. That examination did not deal with many other aspects of the plan to which objections were submitted, and the new plan does nothing to address these shortcomings which alone may be considered significant enough to make the plan unsound. Therefore, the original objections still stand and must not be omitted from any further examination of the plan.
2. The unaffordable transport proposals on which the plan was based were subject to serious objections as they were unworkable. The impact of the new development areas (including those permitted under recent planning consents) on transport plans has not been satisfactorily explained or exposed to public scrutiny and, hence, must still be regarded as unsound.
3. The inspector into the appeal against the proposed development at the Asps agreed the importance of ensuring there should be no new development adjoining the Banbury Road on the southern approach to Warwick because of its potential impact on the settings of the Grade 1 listed Warwick Castle Park, the Grade 1 listed Warwick Castle and the Warwick Conservation Area. In the event, the development was permitted by the Secretary of State who, despite accepting the Inspector's view of the importance of these factors, agreed to the development on the basis, principally, that (in the absence of an adopted local plan) satisfying the predicted demand for housing should take precedence. Now, however, the anticipated demand for housing can be met within the new plan and there is the opportunity to plan to safeguard the remaining important open areas from development. For this reason we object to the allocation for housing of the land west of Banbury Road and at the northern end of Gallows Hill, known as "The Strawberry Field." - which would be even more damaging and much of which is, in any case, liable to flooding.
4. The photo below [SEE ORIGINAL E-MAIL] is just an indication of the potential flooding that is going to be a SERIOUS problem for the council if they do not take heed of the advice and warning given.
5. A prime example is the recent flooding which occurred at the Mallory Court traffic lights recently, which I have not seem before but is almost certainly due to the excavations of the housing being built and the flood plain being altered. There were tankers trying to pump out water, and this was only after an averagely bad period of rain. Imagine this scenario on the Gallows Hill with the water flooding down the Banbury Road - CHAOS - even more than it is EVERY day at peak hours.

My family and I wish to object to the planning proposals for Warwick based on the following points:

1. The proposed modifications may address the shortcomings of the local plan which were identified by the Inspector in his letter dated June 2015 which followed his examination dealing primarily with the numbers of houses to be provided in the new plan. That examination did not deal with many other aspects of the plan to which objections were submitted, and the new plan does nothing to address these shortcomings which alone may be considered significant enough to make the plan unsound. Therefore, the original objections still stand and must not be omitted from any further examination of the plan.
2. The unaffordable transport proposals on which the plan was based were subject to serious objections as they were unworkable. The impact of the new development areas (including those permitted under recent planning consents) on transport plans has not been satisfactorily explained or exposed to public scrutiny and, hence, must still be regarded as unsound.
3. The inspector into the appeal against the proposed development at the Asps agreed the importance of ensuring there should be no new development adjoining the Banbury Road on the southern approach to Warwick because of its potential impact on the settings of the Grade 1 listed Warwick Castle Park, the Grade 1 listed Warwick Castle and the Warwick Conservation Area. In the event, the development was permitted by the Secretary of State who, despite accepting the Inspector's view of the importance of these factors, agreed to the development on the basis, principally, that (in the absence of an adopted local plan) satisfying the predicted demand for housing should take precedence. Now, however, the anticipated demand for housing can be met within the new plan and there is the opportunity to plan to safeguard the remaining important open areas from development. For this reason we object to the allocation for housing of the land west of Banbury Road and at the northern end of Gallows Hill, known as "The Strawberry Field." - which would be even more damaging and much of which is, in any case, liable to flooding. This can be seen in the image below [SEE ORIGINAL E-MAIL].
As we wish to walk to school down the Banbury Road each day it is no longer safe to do so for my 8 year d and 5 year d daughters. The air quality is unacceptable and I, as an adult, find it difficult to breathe easily during busy periods. I would urge you to make the walk over the bridge yourselves when traffic is usually at a standstill. We have now decided it is safer for our children's health to drive the 200 yards from Bridge End to St. Nicholas Park car park! I travel throughout the cities of the U.K. And Warwick's air quality is already worse than London, Birmingham, Bristol, Cardiff, Manchester, Leeds, Newcastle and Edinburgh at rush hours!

We urge you to save this town for future generations. You will personally go down in Warwick's vast history as heroes or villains!

1. The proposed modifications may address the shortcomings of the local plan which were identified by the Inspector in his letter dated June 2015 which followed his examination dealing primarily with the numbers of houses to be provided in the new plan. That examination did not deal with many other aspects of the plan to which objections were submitted, and the new plan does nothing to address these shortcomings which alone may be considered significant enough to make the plan unsound. Therefore, the original objections still stand and must not be omitted from any further examination of the plan.
2. The unaffordable transport proposals on which the plan was based were subject to serious objections as they were unworkable. The impact of the new development areas (including those permitted under recent planning consents) on transport plans has not been satisfactorily explained or exposed to public scrutiny and, hence, must still be regarded as unsound.
The conclusions of the WDC - Strategic Transport Assessment, Final Phase STA of Feb 2016 hardly make a convincing case.
8.7 Performance of the WLWA RDA & NS model
* Journey times & speeds will worsen across the network as a result of the additional housing sites but despite these impacts it is likely that the additional mitigation measures will be able to, at least in part, accommodate the additional traffic volumes generated by the new sites. I would hardly call this an encouraging endorsement of these plans. As I have mentioned previously none of the mitigation measures addresses the biggest bottleneck in the area namely the listed single lane Warwick Briodge.
* The junctions on either end of Myton Road could potentially constrain traffic volumesin the area but further work is needed to determine an optimum solution in this area. It goes on to warn that the impacts of these ' mitigations' must take into account how they could affect the town centres of Warwick & Leamington.
* Queueing issues are observed accessing Warwick Town Centre and the M40 Junction 15 that merit further investigation. It then goes on to speculate that these issues are not likely to become severe until such time as the volume of housing approaches 100%.
* The introducing of signal proposals along the A452 to the north of Leamington may introduce additional delays despite a wider dualling strategy being proposed. Further work on these implications is recommended.
Not much of a convincing case here. What is all this going to do for airquality - surely this has to be a key factor in these plans.
3. The inspector into the appeal against the proposed development at the Asps agreed the importance of ensuring there should be no new development adjoining the Banbury Road on the southern approach to Warwick because of its potential impact on the settings of the Grade 1 listed Warwick Castle Park, the Grade 1 listed Warwick Castle and the Warwick Conservation Area. In the event, the development was permitted by the Secretary of State who, despite accepting the Inspector's view of the importance of these factors, agreed to the development on the basis, principally, that (in the absence of an adopted local plan) satisfying the predicted demand for housing should take precedence. Now, however, the anticipated demand for housing can be met within the new plan and there is the opportunity to plan to safeguard the remaining important open areas from development. For this reason we object to the allocation for housing of the land east of Banbury Road and at the northern end of Gallows Hill, known as "The Strawberry Field." - which would be even more damaging and which is, in any case, liable to flooding.
This photo [NOT INCLUDED HERE - SEE ORIGINAL E-MAIL] was taken of the land just south of the Banbury Road, Gallows Hill Road Junction.
At the Asps appeal the WDC opposed the building of housing on the Asps, & Gallows Hill South. The Inspector for that appeal found in favour of the WDC and the Rule 6 Save Warwick Group as far as the Asps was concerned. However, on looking at the Map 2 of Mod PM 2A Gallows Hill, Asps & Myton School, I see that the WDC have merged Gallows Hill South and Gallows Hill North (Strawberry Field ) into one area labelled H46A. Why have they done this, it is a complete ' volte face' and I am unaware of any consultation between WDC and the Save Warwick Group on this move. Strawberry Fields represents the last Green Field lung to this area of South Warwick, and does not need to be included for sufficient housing numbers to be reached. The Secretary of State has already seen to that, and furthermore as already shown above the bottom end is prone to flooding. Surely this last section of green field should be preserved.
Regarding the Local Plan I do not consider it Legally Compliant nor Sound.
I consider the Proposed Modification is unsound because it is neither effective nor consistent with National Policy.

Modification:Removal of land north of Milverton from the Green Belt

Mod Number: 16

Paragraph Number: 2.81

Mod. Policies Map Number: H44

Modification: Allocation of land north of Milverton for development
Modification: No 14-
Para: Policy DS15
Mod. Policies Map Number: H44

I have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.


I would like to register a formal objection to the removal of land from the Green Belt north of Milverton, and the proposed building of 250 houses and park-and-ride scheme, followed by a further 1100 houses, railway station and commercial property within 5 years.

I believe that we must provide additional housing in South Warwickshire, but It is preposterous that this green belt land should be used to support Coventry City's housing need, and I cannot believe that this is sustainable.

Traffic congestion in the Leamington/Warwick area is already an enormous problem and whilst the suggestion of Park and Ride facilities are put forward I do not believe that residents of the proposed area will want to use the facility to travel into Coventry, and will certainly not use it for trips into Leamington Spa. They will use their cars.

The "Exceptional Circumstances" needed to remove this land from the green belt do not exist. There are lesser value sites closer to Coventry which on the basis of planning precedent should be used in preference to the land in Old Milverton. It is very far fetched to suggest that people living and working in Coventry will be interested in buying houses and living in Old Milverton.

Modification: Removal of land north of Milverton from the Green Belt

Mod Number: 16

Paragraph Number: 2.81

Mod. Policies Map Number: H44

Modification: Allocation of land north of Milverton for development
Modification: No 14-
Para: Policy DS15
Mod. Policies Map Number: H44

I have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.


I would like to register a formal objection to the removal of land from the Green Belt north of Milverton, and the proposed building of 250 houses and park-and-ride scheme, followed by a further 1100 houses, railway station and commercial property within 5 years.

Whilst there may be need to provide additional housing in South Warwickshire in the future, it is not logical nor permissible to consider using this green belt land to support Coventry City's housing need. This proposal does not demonstrate removal of Green Belt Land in and around Old Milverton is a viable solution for that purpose nor does it have any merit in demonstrating Coventry folk both living and working in the City would contemplate buying houses in Old Milverton.

Traffic congestion in the Leamington/Warwick area is already a significant problem on both Southern and Northern entry/exit routes and whilst the suggestion of Park and Ride facilities are put forward it has not been demonstrated that residents of the proposed area will want to use the facility to travel into Coventry, and will certainly not use it for trips into Leamington Spa. They will use their cars.

The proposal for an additional railway station in the Milverton area again has no logic considering the existence of existing under-utilised facilities in inter alia, Leamington Spa, Warwick, Warwick Parkway and the Kenilworth facility under construction..

The "Exceptional Circumstances" needed to be demonstrated to allow a decision to remove this land from the green belt have not been demonstrated and do not, to my sight exist. To my understanding there are lesser value sites closer to Coventry which, on the basis of planning precedent, should be used in preference to the land in Old Milverton.

We understand that the National Planning Policy Framework requires that exceptional circumstances have to be established by Warwick District Council to remove the land North of Milverton from the Green Belt. This criteria has clearly not been established in a way that stands up to close examination.

The proposed development has been justified in order to support Coventry City Council's housing need. The foundation to these proposals is highly questionable. We understand that the Government stipulated that each local authority with planning powers had to make plans to build a certain number of homes. The number that each local authority had to plan for was prescribed by the Government. It is therefore surely reasonable to assume that the Government felt that the number of homes they expected to be planned, by each local authority, could be built within that council's boundaries. For a local authority to just pass on this requirement to a neighbouring authority, which also has its own Government target to reach, is unfair in the extreme.

Even if this passing on of some of Coventry's target for new homes to Warwick District Council is deemed the only way forward, then it can only make sense if these houses are built on the edge of Coventry and not on the edge of Leamington Spa. If these homes are destined for people currently living and working in Coventry, then it is only rational if they are as close to Coventry as possible to reduce unnecessary commuting, inevitable congestion and further road construction with the resulting environmental damage.

What kind of logic is it that says we have to provide for Coventry's housing needs by building those houses on the edge of Leamington Spa? It is a well-known fact that commuting is bad for the individual concerned and bad for the environment. This 'plan' would force people into making long commutes across the remaining green belt to their place of work,

When considering releasing land from the Green Belt, it has been established that the value of potential sites to the Green Belt must be taken into account and those with the least value prioritised for removal from the Green Belt. We understand that WDC and Coventry City Council have assessed sites on the edge of Coventry as being of lower Green Belt value than the Old Milverton site. It is therefore perverse, when there are sustainable sites closer to Coventry, that land north of Milverton should be first choice.

The whole rationale for the Green Belt was to protect "green lungs" between conurbations. The green lung between Leamington and Kenilworth would be reduced to less than 11/2 miles if this development was allowed, seriously undermining its value. The attractive and pleasant northern entry to the historic regency town of Royal Leamington Spa will be irretrievably damaged. Highly beneficial and productive land will be destroyed together with a well-established wild life habitat. The green belt also exists to protect the character of towns and cities and the character of Leamington Spa, with its Regency centre, is based on its being the size it is now and not to become a dormitory area for Coventry.

The residents of the wider Warwick District area will be deprived of an area which is highly valued and sustainable for all manner of pursuits, such as rambling, jogging, cycling, riding and bird watching. This proposal will be a disaster for Leamington Spa.

The park-and-ride scheme as proposed, is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable and face not being able to board buses which may be full at peak times.
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 is destined for the south of Leamington where the major employers are situated.
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington.
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

In summary, we believe the land north of Milverton should remain in the Green Belt.
The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.

As a long-standing resident of Bridge End it has been with a rising sense of despair that I have viewed the way in which the local population's legitimate concerns have been steam-rollered - putting the rubber stamp on plans which sadly will blight this historic approach to the county town of Warwick for ever more. Nevertheless, I would like the council to take into account my views even at this late stage.

1. The proposed modifications may address the shortcomings of the local plan which were identified by the Inspector in his letter dated June 2015 which followed his examination dealing primarily with the numbers of houses to be provided in the new plan. That examination did not deal with many other aspects of the plan to which objections were submitted, and the new plan does nothing to address these shortcomings which alone may be considered significant enough to make the plan unsound. Therefore, the original objections still stand and must not be omitted from any further examination of the plan.
2. The unaffordable transport proposals on which the plan was based were subject to serious objections as they were unworkable. The impact of the new development areas (including those permitted under recent planning consents) on transport plans has not been satisfactorily explained or exposed to public scrutiny and, hence, must still be regarded as unsound.
3. The inspector into the appeal against the proposed development at the Asps agreed the importance of ensuring there should be no new development adjoining the Banbury Road on the southern approach to Warwick because of its potential impact on the settings of the Grade 1 listed Warwick Castle Park, the Grade 1 listed Warwick Castle and the Warwick Conservation Area. In the event, the development was permitted by the Secretary of State who, despite accepting the Inspector's view of the importance of these factors, agreed to the development on the basis, principally, that (in the absence of an adopted local plan) satisfying the predicted demand for housing should take precedence. Now, however, the anticipated demand for housing can be met within the new plan and there is the opportunity to plan to safeguard the remaining important open areas from development. For this reason we object to the allocation for housing of the land west of Banbury Road and at the northern end of Gallows Hill, known as "The Strawberry Field." - which would be even more damaging and much of which is, in any case, liable to flooding.

1. The proposed modifications may address the shortcomings of the local plan which were identified by the Inspector in his letter dated June 2015 which followed his examination dealing primarily with the numbers of houses to be provided in the new plan. THat examination did not deal with many other aspects of the plan to which objections were submitted, and the new plan does nothing to address these shortcomings which alone may be considered significant enough to make the plan unsound. Therefore , the original objections still stand and must not be omitted from any further examination of the plan.

2. The unaffordable transport proposals on which the plan was based were subject to serious objections as they were unworkable. The impact of the new development areas (Including those permitted under recent planning consents) on transport plans has not been satisfactorily explained or exposed to public scrutiny and, hence, must still be regarded as unsound.

3. The inspector into the appeal against the proposed develop at the Asps agreed the importance of ensuring there should be no new development adjoining the Banbury Road on the southern approach to Warwick because of its potential impact on the settings of the Grade 1 listed Warwick Castle Park, the Grade 1 listed Warwick Castle and the Warwick Conservation Area. In the event, the development was permitted by the Secretary of State who, despite accepting the Inspector's view of the importance of these factors , agreed to the development on the basis, principally, that (in the absence of an adopted local plan) satisfying the predicted demand for housing should take precedence. Now, however, the anticipated demand for housing can be met within the new plan and there is an opportunity to plan to safeguard the remaining important open areas from development. For this reason we object to the allocation for housing of the land west of Banbury Road and at the northern end of Gallows Hill, know as "The Strawberry Field" which would be even more damaging and much of which is, in any case, liable to flooding.

As a resident of Coventry who has lived on the border of Warwick District Council for 40 years I am writing to place on record my objection to the plan to build on the area known as site ref H43 (Kings Hill).
I have listened to all the arguments both "for" and "against" and I can see no justification for building within this area. I request that these plans are reviewed and turned down on the basis that Coventry has more than enough of its own "brown field" sites to accommodate this house building plan.

I want to object to 2 modifications:
Allocation of land North ofMilverton for development
Mod number 14
Paragraph policy DS15
Mod policies map number H44

And

Modification: removal of land north of Milverton from the green belt
Mod number 16
Paragraph number 2.81
Mod policies map number H44

Please register my objections
This is because there has been little/no consultation on what is planned to be built where.
Your web site is terrible to use and lodge objection.
What proviso have you made to consult residents whose first language is not English?

I wish to object to the new local plan on the following basis
1. The proposed modifications may address the shortcomings of the local plan which were identified by the Inspector in his letter dated June 2015 which followed his examination dealing primarily with the numbers of houses to be provided in the new plan. That examination did not deal with many other aspects of the plan to which objections were submitted, and the new plan does nothing to address these shortcomings which alone may be considered significant enough to make the plan unsound. Therefore, the original objections still stand and must not be omitted from any further examination of the plan.
2. The unaffordable transport proposals on which the plan was based were subject to serious objections as they were unworkable. The impact of the new development areas (including those permitted under recent planning consents) on transport plans has not been satisfactorily explained or exposed to public scrutiny and, hence, must still be regarded as unsound.
3. The inspector into the appeal against the proposed development at the Asps agreed the importance of ensuring there should be no new development adjoining the Banbury Road on the southern approach to Warwick because of its potential impact on the settings of the Grade 1 listed Warwick Castle Park, the Grade 1 listed Warwick Castle and the Warwick Conservation Area. In the event, the development was permitted by the Secretary of State who, despite accepting the Inspector's view of the importance of these factors, agreed to the development on the basis, principally, that (in the absence of an adopted local plan) satisfying the predicted demand for housing should take precedence. Now, however, the anticipated demand for housing can be met within the new plan and there is the opportunity to plan to safeguard the remaining important open areas from development. For this reason we object to the allocation for housing of the land west of Banbury Road and at the northern end of Gallows Hill, known as "The Strawberry Field." - which would be even more damaging and much of which is, in any case, liable to flooding.

Ref. Modification: Removal of land North of Milverton from the Green Belt.
Mod. No.16. Paragraph No 2.81 Mod Policies Map No. H44

Ref. Modification: Allocation of land North of Milverton for Development.
Mod No.14 Paragraph No. Policy DS15 Mod.Policies Map No H44

We agree in every particular with the objections submitted by The Old Milverton and Blackdown Joint Parish Council.

It was with dismay that I read in the Courier that the council is again targeting Green Belt land North of Leamington for development, it felt worse that it seems that it is being used as a Coventry overspill.
Is Bill Gifford the only councillor that can see the obvious fact that a Coventry overspill should be sited by Coventry?
If the proposed park and ride in Blackdown proves to be a failure, is there provision to return the land to Green Belt and ensure there is no development on this land?
Old Milverton and Blackdown parish council were excellent last time the council tried to use this precious Green Belt which keeps our local identity separate from Kenilworth and as a proud Leamingtonian, I will fully support them in their efforts to have this attempt refused.

I write to object to the inclusion of Strawberry Fields in the modified plan. There are many familiar issues - a heritage location close to the Warwick Conservation Area, a worsening of the traffic problem on the Banbury Road with no mitigation in relation to the bridge, the further loss of green fields near the town, etc. The point I would like to stress is the the area of Strawberry Fields nearest the town is liable to flooding, as shown by the water lying in recent weeks. This arises naturally from the lie of the land, which is therefore unsuitable for the housing development that is proposed.

I should like to request that this proposed development be reviewed with a view to finding an alternative site for Coventry overspill housing.
I do not live in this part of Leamington Spa but nonetheless appreciate the "Green Lung" between Leamington and Kenilworth and consider it important to maintain for the well-being of urban dwellers. The green fields and countryside, the allotments and village communities around the town contribute to the quality of life of its inhabitants. The countryside is also an important natural habitat for wild life. People like to and need to be able to go walking, dog walking, running, cycling and/or riding to relax in their free time - the environs of Leamington as they are still permit this - even without a car.
There is evidently a shortage of housing but for some twenty years we have mostly seen developments of luxury housing and buy-to-lets. This does not address the needs of most ordinary people. It may be that it is time to consider the development of a new town rather than endless brown fill and green site development projects. The density of the town's population and accompanying traffic pollution must be a consideration.
It is arguable that if this housing proposal is to alleviate the Coventry housing crisis, that it would be preferable to make the development nearer Coventry.
More houses around this part of Leamington will add volumes of traffic to an already busy commuter part of town.
Please think again.
Only the builders will benefit from this and they are rich enough.

I have read the proposals in the WDC Draft Local Plan and would like to express my concerns and objections.

Whilst agreeing to the need for additional housing to be provided in Warwickshire I firmly object to the withdrawal of the green belt land to the north of Milverton to provide for this new housing.

The green belt is a very valuable green lung and provides an area of great benefit for the residents of Leamington Spa and Kenilworth healthy activities including walking, running, cycling of etc

It is important as a positive break between the two conurbations and as a necessary wild life habitat.

Whilst agreeing to the need for sustainable development I cannot agree that exceptional circumstances can be demonstrated for the land to be released for this proposed invasion of the green belt at this time.

There is a suggestion of the provision of a Park & Ride facility. To what benefit? I do not believe that residents of the suggested development will use this facility when it is so close to the centre of Leamington Spa. If they have cars they will always prefer using them unless they only have very lightweight shopping to carry. Also the existing roads into Leamington Spa and Warwick are already terribly congested, and even if they are widened there will still be bottleneck at the entrance and exit from the towns without the addition of a possible 1350 plus cars for the residents proposed over the next 5 years.

The proposed development in Old Milverton to provide housing for Coventry is absurd. This is not sustainable. It should be close to Coventry where there is plenty of available space, both to the North. South and West which have already been identified as of much lower green belt value. Coventry's need for additional housing should be met by development closer to Coventry to be more sustainable, and I do not believe that there are exceptional circumstances for removing the Green Belt land to the north of Milverton.

I am very worried about the proposed massive development of 4000 houses to be built on King's Hill. This is low-lying green belt land and the major concern for me is the fact that, as the lowest part of Coventry, it is already susceptible to flooding around Finham Brook. So many houses on that land, will cover the earth where drainage would occur, and water draining off houses, paved drives and roads will have nowhere to go. With climate change and increased rainfall, this can only get worse.

Finham Sewage Works treats sewage from Kenilworth and Stoneleigh, as well as the whole of Coventry. As someone who lives in the area, I can tell you that it is not dealing adequately with it now. Certainly, when you walk past, the smell is quite overpowering, and on hot Summer days, the smell reaches the houses in Finham. How is it going to cope with another community of so many extra houses?

There is no convenient access to King's Hill, unless the enclosing roads are widened dramatically. This would destroy ancient protected hedgerows and oak trees. The old Leamington Road already carries a lot of traffic and is completely congested if any of the surrounding trunk roads and motorways are closed, and they frequently are!

The development will take years to be carried out, involving bulldozers and lorries driving up and down narrow roads - a danger to children - while the extra sewage, gas, electricity, telephone, and water services are installed. Then the bricks, slates, insulation etc. necessary to build the houses themselves will need to be ferried in.

A lot of research has been done by the Finham Resident's Association, which I know you have received - in depth, careful research. Can you honestly say that your modifications cover all their objections adequately? I don't want Finham sinking under sea of flood water and sewage in ten years time, when it is too late to do anything about it.

see attached

See attached

See attached

See attached

See attached

1) The Exceptional Circumstances required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.

2) The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land north of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.

3) In practice it is unlikely that people who want to live and work in Coventry will buy houses on land north of Milverton and therefore this development proposal will not support Coventry's housing need.

4) Precedence for releasing land from the Green Belt requires the "value" of potential sites in the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in co-operation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

5) The rural gap between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

6) The attractive northern approach to Leamington Spa will be adversely affected.

7) Good farming land will be lost together with long established wild life habitat.

8) The residents of local towns will be deprived of an area which is highly valued and regularly used for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.



9) The proposed park-and-ride scheme is impractical because:-

a) There will be no dedicated buses, so users will have to time arrivals to coincide with the bus timetable.

b) The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.

c) Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers

d) Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington

e) A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical



As a solution the development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing in a more convenient location for the residents.

Modification: Removal of land north of Milverton from the green belt
Mod Number: 16
Paragraph Number: 2.81
Mod. Policies Map Number: H44

Modification: Allocation of land north of Milverton for development
Mod Number: 14
Paragraph Number: Policy DS15
Mod. Policies Map Number: H44

In my opinion the Local Plan is unsound because it is not justified, effective nor is it consistent with National policy.

Warwick District Council ("WDC") has failed to demonstrate the EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt and to permit the proposed development.

Initially 250 houses are proposed to support Coventry City Council's housing need. In practice people who want to live and work in Coventry will not buy houses on land North of Milverton and, therefore, this development will not support Coventry's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton so as to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable. In addition this is a very small development, which equates to an annual additional build of only 19.2 houses over the remaining 13 years of the Plan period. These houses could be accommodated on other sites and, therefore, the harm caused to the green belt by this development by reason of inappropriateness outweighs any potential benefit.

The proposed park-and-ride scheme is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* The proposal is predicated on a significant increase in car parking charges as an attempt to change behaviour and will have a detrimental effect on the Leamington as a Town Centre.

Additional land north of Milverton is to be "safeguarded" for development beyond the Plan period, to provide a further 1100 homes for Coventry. This will not support Coventry's hosing need because in practice people who want to live and work in Coventry will not buy houses on land North of Milverton. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to prevent unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

WDC has also said that the "safeguarded land" north of Milverton could be used in the future to support Leamington's housing need. There are other green field sites that are available, and deliverable which should be used in preference. Therefore, WDC has previously accepted that the Exceptional Circumstances necessary to remove this land from the Green Belt to support Leamington's housing need do not exist. Nothing has changed which could alter this acceptance.

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

The proposed railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

The land North of Milverton is used by many people for recreation. If developed the residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.

The land North of Milverton has performed the requirements of the Green Belt and it should continue to do so:

* It has stopped Kenilworth, Coventry and Leamington merging. If this land is removed from the green belt the "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

* It has stopped Leamington "sprawling". Development stops at the green belt boundary

* It protects the historic setting for regency town of Royal Leamington Spa which will be destroyed if development is allowed.

* It has encouraged urban regeneration in the neighbouring towns

* It has safeguarded the countryside. If this land is removed from the green belt, highly productive farming land will be lost together with long established wild life habitat.

In order for the modifications to the Local Plan to become sound the land North of Milverton should remain in the Green Belt.

In total Warwick District Council has agreed to provide land for 6000 houses to meet Coventry's housing need. However the modifications to the Local Plan propose that only 2245 of these houses will be close to Coventry. The remaining houses will be located in Kenilworth, Warwick and Leamington. WDC's proposal to encourage commuting (most of which will be by road) on this scale is irresponsible and bad planning.

See attached

I am writing to you on behalf of the Burton Green Parish Council in response to the Amended Local Plan and in particular to the proposed development of 425 houses at Westwood Heath.
INTRODUCTION
I begin with a description of the main features of Burton Green and some of the problems we face, especially that of increased traffic on our roads.
I will endeavour to ascertain whether the proposal is legally compliant and whether it is in accord with the present Government's policy towards Green Belt and the National Planning Policy Framework. (NPPF) The subject of legal compliance is not always clear cut and is often a matter for the courts to determine but it does seem that the development at Westwood Heath rests uneasily with national policy and is at odds with the principles enshrined in the NPPF.
Thirdly, and perhaps more importantly, I question whether the development is sound and whether all the infrastructure implications have been addressed, especially in relation to sustainable transport. I will argue that the figure of 425 houses is not properly evidence based and that other information is needed for this proposal to go forward.
Finally I will examine other concerns we have about this proposal and the changes made to the original development at Burrow Hill Nursery.

BURTON GREEN
The village of Burton Green is a ribbon development which covers a wide area, including parts of Crackley but the parish boundaries have now been extended to include the ward of the University. Burton Green is a community of 387 houses, lying in a semi-rural, elevated position between Coventry and Kenilworth. Surrounded by Green Belt, the village benefits from open views across the countryside including ancient woods and hedgerows. Westwood Heath is an essential part of the landscape. It sits in the Crackley Gap and separates Burton Green from Coventry. Environmentally it is of a very high value. It is perhaps the most important open space in Burton Green with fantastic views towards the university. It is enjoyed by residents, walkers and even motorists and it provokes a feeling of well-being which will be lost forever if this proposal is accepted. Already Burton Green has been severely impacted by HS2 which goes straight through the heart of the village. Many residents have left because of the proximity to the route and their houses are now rented out by HS2 Ltd. A considerable amount of land has been set aside for the route while our special amenity, the Greenway, is irreparably damaged. Despite these setbacks, the sense of community remains very strong. We have taken on board the projected 30 mobile homes in Red Lane and have supported the development of 80 houses at Burrow Hill Nursery. However we believe that the Westwood development, which is far in excess of our present housing stock, is a step too far and threatens our community sustainability.
In our Parish Plan, Planning for the Future, April 2014, the aspirations and the concerns of our residents were noted. The respondents (at least 75% of households)" rated the openness/views, rural nature, village environment, trees, fields, verges, wildlife and Greenway as the most important aspects of the village" and it was considered essential that "people's views on what is really important to them about BG are reflected in the Neighbourhood Plan." (Page 8) Sadly this hope has been extinguished by the Revised Local Plan and certainly residents would be shocked and disappointed by the comments in Appendix 6, on the Site Appraisal Matrix, that "Burton Green has been identified as a growth village with a range of services and facilities."
In the Parish Plan, there were concerns about traffic, mainly on speeding and parking, but there was little mention of the volume of traffic on our roads. The situation is very different in 2016 from the time the Steering Group came together in 2012 and produced their report in 2014. Traffic levels are much higher as motorists drive along Cromwell Lane towards Westwood Heath Rd. on the way to the A45 or to the Science Park or to the University etc. I know from personal observation. I live in Cromwell Lane, opposite the water tower about 350 yards from Westwood Heath Rd. Today, Monday, April 11th, I did a simple survey of traffic between the hours of 8-25 and 9-25 travelling in the Coventry direction. Between 8-25 and 9-05, there were 361 motorists at an average of 45 motorists every 5 minutes with over 50 motorists in the time slots, 8-25 to 8-30, 8-30 to 8-35 and 9-00 to 9-05. Between 9-05 and 9-25, there were 101 vehicles at an average of 25. During the whole time, only 4 intrepid cyclists braved the traffic.
It may well be that the number of motorists is not that different from previous years but the problem has been compounded by the much higher levels coming from Tile Hill village, many from the new Bannerbrook Estate. Motorists coming from the opposite direction cannot turn right and consequently you can get a huge congestion of cars, very often outside my house. Burton Green residents are acutely aware of this problem. They have difficulty in getting off their drives and more seriously, pupils experience danger when they cross the road for the school bus to the Heart of England Comprehensive School in Balsall Common. I have spent some time looking at road transport in Burton Green at the present time but I will return to this subject when we look at the impact of the Westwood development of a further 425houses on transport links.
COMPLIANCE WITH THE LAW, GOVERNMENT POLICY AND THE NPPF.
As I intimated in the introduction, it is not always easy to interpret the law and I have not the legal expertise to tackle this subject. However it is the task of governments to determine policy and shape the law. In the Coalition Government, Eric Pickles, the Communities Secretary, and Brandon Lewis, the Housing and Planning Minister issued guidance to Councils on how to use their Local Plan. They were to draw on "protections in the National Planning Policy Framework to safeguard the local area against urban sprawl and protect the green lungs around towns and cities." Of course the Coalition is no longer with us but it would seem that the present Conservative Government is still intent on safeguarding Green Belt. In their Manifesto, there was a strong commitment to the Green Belt; "We will ensure local people have more control over planning and protect the Green Belt" and were ready to publish "planning guidance which reaffirms the importance of the Green Belt during Local Plan preparation." Of course, promises in manifestos may be ignored but to be fair to the present Conservative Government, ministers have shown a relish to implement Manifesto proposals.
But what about the guidance of the NPPF and what light does this show on the development at Westwood Heath? The answer is simple. This proposal to build 425 houses is in complete contradiction to the principles of the NPPF as is absolutely evident in Appendix 8 of the Green Belt and Green Field Review of November 2013. A series of questions are posed on a possible development at Westwood Heath which show conclusively that this development is not fit for purpose and here are a few of them.
Question 3. Would development in this area impact negatively on the visual amenity of the Green Belt?
Question 6. Would the loss of this Green Belt parcel lead to or constitute ribbon development?
Question 11. Would the loss of this Green Belt parcel result in a small settlement being absorbed into a large built up area?
Question 16. Would the loss of this Green Belt parcel reduce the defensible boundary between the existing urban area and open countryside?
Question 25. Would the loss of this Green Belt parcel reduce the character, identity or setting of a village or hamlet?
The answers are obvious and it would have been a massive shock if the District had supported an earlier development at Westwood Heath but are circumstances so exceptional to allow such an environmentally damaging proposal now? Does the duty to cooperate with Coventry mean that all environmental considerations are discarded? Moreover it is likely that this development will lead to changes in our boundary with Coventry and it would be no surprise if Coventry were to extend to the HS2 line. Burton Green has always been a target for Coventry and in the 1960s, an attempt was made to include it in Coventry's boundaries. The attempt failed but it now seems that the District is acquiescing in their demands. In their recommendations, they seem to suggest that the integrity of Burton Green has been protected by maintaining space between the development and the back gardens of properties in Cromwell Lane. But this development is in Burton Green but for how much longer? Of course, such a situation would be really attractive to Coventry as it seeks to extend its finances. With 70% of all Coventry homes within Council Tax bands A and B, (Coventry Local Plan, p45), the building of aspirational homes would be a great triumph for Coventry.
IS THE WESTWOOD HEATH PROPOSAL SOUND?
Warwick District seems to have absolute confidence that 425 houses can be built without any adverse impacts on road transport. It follows a "Do Nothing Option Scenario". It does recognise that there would have to be significant improvements to the strategic highway network, including the construction of a new link road between the A46 junction and Kirby Corner and onwards towards the A452 or the A45 if, for example, the safeguarded land lower down Westwood Heath were developed. But how can the Planners be so confident and how can they be so sure that 425 houses can be built without adverse impacts? Despite all the magic formulae, such as the Geoffrey E. Havers statistic, or all the advanced computer technology, predicting transport patterns is surely not an exact science. In Appendix 1 of the Sustainability Appraisal Addendum Report, it states that "there is an element of uncertainty for all the options as the precise nature and level of the provision or improvements to associated facilities/services and sustainable transport modes is not known at this stage." Likewise in the Strategic Transport Assessment by Vectors Microsim in Appendix A, 4-53, Crackley Lane would come under significant pressure at this time but it was not possible to identify what additional impacts may occur or what an appropriate mitigation strategy could be. Indeed the situation on the Crackley route appears precarious and in the Supplementary Analysis of the W.D.C.Strategic Assessment Phase 5, it concluded that with 425 dwellings, this route "is likely to be nearly over capacity." Yet despite these reservations, Warwick District have complete faith that 425 houses could be built without having any impact on existing transport links. Perhaps councillors and planners should consult the Warwick District Phase 5 Supplementary Analysis by Vectos Microsim. In the introduction, it notes "that some of the area of network which may be affected by the allocation of these sites is missing from the existing microsimulation models meaning it is not currently possible to fully assess impacts of these sites." On the other hand, it may be prudent to ignore the technical language of the planning fraternity and concentrate on more simple issues.
Warwick District focusses on housing within their area but seem oblivious of developments across their borders. The development at Westwood Heath is closely linked to that at Kings Hill but what about the possible housing developments in Coventry? Within a stone's throw of Westwood Heath Rd., Coventry could build 236 houses. If this proposal goes ahead, many motorists will head towards the University and will join up with the residents from the 425 houses in Westwood Heath. At the same time, Berkswell and Balsall Common will also need to build more houses under a revised Solihull Local Plan, and motorists from those areas will head for the already congested Cromwell Lane route and will join forces with motorists from the 90 houses at Burrow Hill Nursery. Faced with these pressures on our transport infrastructure, would it not be prudent for Warwick District to consider more carefully their proposal to build 425 houses at Westwood Heath? Perhaps understandably, Warwick District has rushed to find a solution without proper consideration in an attempt to secure a Local Plan which will stop property developers riding roughshod in the Leamington and Warwick area where there are ample opportunities to build on land which is not Green Belt. But it seems that there are sufficient grounds for rejecting the Westwood Heath proposal as unsound and surely if this consultation is to be meaningful, all interested parties should know what additional roads will be needed and where they will be located if Kirby Corner is to be joined up with the A46 and subsequently to the A45 or the A452.
In deciding on a figure of 425 houses, I am not sure what weight has been given to improvements in public transport. Obviously planners want to optimise public transport, but it is still doubtful, even with bus shelters at key stops, that residents will forsake their cars to join car clubs or participate in car sharing. (Appendices. Sustainable Transport Strategy Overview). It is perhaps a similar situation with cyclists. Burton Green would support improved cycle paths but how achievable is this objective? At this moment in time, if I were a parent, I would make sure that my children kept well away from Cromwell Lane and Westwood Heath Rd during week days. We also recognise that pedestrians should have access to green corridors but the reality is that pavements in Burton Green are in a very poor state and there is no money to repair them. It may be that some residents from the Westwood Development would walk to Tile Hill railway station, especially as it is increasingly difficult to park there, but it is doubtful whether improvements in public transport, cycle paths or in green corridors will have any real effect on the number of motorists going to work or dropping their children at school, thus increasing the numbers on Westwood Heath Rd. and Bockenden Road.
OTHER ISSUES AT WESTWOOD HEATH AND CHANGES TO THE BURROW HILL PROPOSAL
If the development at Westwood Heath does goes ahead, we would welcome a Health Centre and a retail facility but we do have serious concerns about educational provision in Burton Green. At first, we were alarmed to see that significant changes were made to the original Burrow Hill proposal. We were concerned that provision for parking had been removed and no mention was made of a playing field for the Burton Green Primary School but it now seems that the concessions to the School remain. However we are concerned that the increase to 90 houses is excessive and may have a negative impact on the development. The acquisition of the playing field does give the school some scope to expand but it is highly unlikely that the school can cope with the increased demand from a development of 425 houses at Westwood Heath.
In the Table of Proposed Modifications to the Publication of the Draft Local Plan, emphasis was placed on the need for educational capacity in a coordinated manner. But that is easier said than done. There is a shortage of places in Coventry's Primary Schools while the merging of Woodland Boys with Tile Hill Girls reduces the number of places in Secondary Schools, despite the emergence of Finham 2 at Torrington Avenue. It seems that there may be 2 Primary Schools at King's Hill but does that mean children from Westwood Heath will attend these schools? If they do, of course, it means that even more cars will be travelling on Westwood Heath Rd. than hitherto considered, making it imperative that additional roads will be required. Surely, if this consultation is meant to be transparent, knowledge of these roads should already be in the public domain.
CONCLUSIONS
1) The Westwood Heath development will have a massive impact on our community, already beleaguered by HS2. The projected houses, both at Burrow Hill Nursery and Westwood Heath, will be far in excess of our present housing stock and the openness of our village, which residents value so much, will be severely compromised. Burton Green's genuine concerns about the volume of our traffic will even more be exacerbated by this new development.
2) It is probable that the proposal is compliant with the law, (it is a matter for lawyers) but it certainly runs counter to supposed government policy and contradicts the guidance of the NPPF. The duty to cooperate with Coventry is a binding commitment but should it be at the complete expense of the environment?
3) It is doubtful if the proposal is sound and it would be a really interesting experience if planners were called to justify its soundness. Predicting transport patterns is not a precise science as some of their own literature makes clear. There are serious doubts about their research, especially on the Crackley route, and at times the Revised Local Plan seems rushed and incomplete.
4) The statement that 425 houses can be built without additional roads does not stand up to scrutiny and the failure to identify routes of possible roads to Kirby Corner and beyond is a serious failure and puts at risk the democratic process.
5) The Local Plan ignores the housing developments of our neighbours, whether in Coventry, Berkswell or Balsall Common which will impact considerably on Cromwell Lane and Westwood Heath Rd. All Authorities are under pressure to build more houses and it is likely that the pace will be unyielding in the years to come.
6) It is almost certain that improvements in public transport and in cycle and pedestrian pathways will have little effect in reducing the volume of traffic along Westwood Heath Rd., making it even more likely that the existing transport infrastructure will be unable to cope.
7) The development at Westwood Heath will have serious implications for educational provision in Burton Green. It could well be that the solution to these problems, especially in the primary sector, will result in further traffic on our roads.

See attached

Concerning the process, WDC has obviously done a huge amount of work in coming up with the New Plan - congratulations to you and the team. I understand the background to the revisions, most of which are understandable, supportable and rational.
May I make a couple of suggestions to improve the consultation process which would better demonstrate WDC's commitment to consult? Your online response form is unwieldy, un-user friendly and complex. The downloadable PDF form, being a PDF, cannot easily be used by most to work up a draft response before finalising it. It would then have to be scanned to be sent in electronically. Many of the local electorate to whom you are addressing the consultation cannot cope with this process. I have converted the PDF to a Word document (to help you have my views in your preferred format) but it would be so much easier if the form was available in Word in the first place.

See attached

See attached

See attached
Question 7

1. The LPA is fully aware that the McDaide family, the Hibbert family and KFRC, who hold the controlling land interests for Allocation H06, have from the commencement of the Local Plan preparation promoted the release of the site and its development for residential-led mixed use development on a comprehensive basis. In response to the Inspector's interim conclusions, the LPA has identified as a separate policy allocation - Policy H40 - a further substantial release of land from the Green Belt - for a similarly residential - led mixed use development. Policy DS15 applies to the development of Strategic Sites and states at c):

'Thickthorn and sites allocated to the east of Kenilworth.'

2. One of the key purposes of a development plan is to provide guidance as to how development allocations are to be brought forward. The submissions of proposals for sites H06 and H40 are of a scale that the applicants for planning permission will need to demonstrate a comprehensive approach to a wide range of planning requirements, through the Design and Access Statement, parameters plan and possible Environmental Assessment. Such submissions reasonably can have regard to the principles of development that are identified in the Local Plan for the adjoining allocation, and the impacts upon infrastructure, for example through a Transport Assessment. However, as noted at Explanation paragraph 2.66, the land holdings are in 'multiple ownerships.' There is an agreed understanding between the parties of how the land allocation under H06 can be brought forward promptly, following the adoption of the Local Plan, releasing the land from the Green Belt.

3. The intimation at paragraph 2.66 is that all landowners should set up some form of 'consortia or other formal means of co-ordinating joint-working.' Experience demonstrates that such an arrangement for an extensive parcel of land - across two mixed-use allocations may lead to avoidable delays in bringing the two land allocations forward within the development management process. The landowners for Thickthorn (H06) can bring forward the landholding promptly in response to the release of the site from the Green Belt. The landowners have received many interests from housebuilders to take forward the allocation through the development management process and deliver new homes on this site.

4. Clearly, as two committed allocations, the bringing forward of either allocation would have to have regard to the development of others, most likely through environmental assessment. The Transport Assessment and other technical assessments would ordinarily have regard to the implications of intended development on adjoining land.

5. Paragraph 2.68 of the Explanation provides sufficient guidance to the developers of strategic sites - in this particular case - H06 and H20, that development of either needs to take account of the other. Comprehensive development can be achieved for each site, having regard to the development implications of adjoining allocation, without requiring a 'formal means of co-ordinated joint working.' Informal joint working, including full participation of the LPA can achieve a high quality and integrated development across the two allocations east of Kenilworth.

Question 8

6. Identify land at Thickthorn (H06) and land at Crewe Lane, Southcrest Farm, Woodside Training Centre (H40) separately under the list of strategic sites under Policy DS15.
Question 7

1. The representation on behalf of the McDaide Family; The Hibbert Family and KRFC is that Policy DSNEW 4 is sound and consistent with national planning policy in allocating land for a change of use in the Green Belt for the provision for outdoor sport.

2. There is a substantial requirement for the provision of enhanced sporting facilities to meet the needs of KRFC, as has been demonstrated in the past submissions to the LPA within the emerging local plan process. These enhancements are sought now, and are increased by the proposals for an enlarged resident population within Kenilworth. The allocations in the Local Plan effectively establish the principle of a change of use of land in the Green Belt for the purposes of providing an opportunity for the enhancement and potential relocation of sports pitches, on land that is primarily allocated for residential development to meet the wider public interest. Properly, the provision of 'appropriate facilities' is a matter that can be addressed within the development management function, pursuant to national planning policy set out in the Framework (89).