Mod 24 - DS NEW3

Why are WDC suggesting up to 120 new dwellings in Leek Wootton on the site of the former Police Headquarters and nearby greenbelt?
In the Publication Local Plan (Jan 2015), a total of 26 dwellings were proposed. The modifications to DS10 since then increased the growth villages allocation by 50% so applying this increase the village should be allocated circa 40 dwellings only to Leek Wootton.
Now that Place Partnership have put forward the Police HQ as a brownfield development site in DSNEW3 there must be more than enough opportunity for dwellings without including greenfield sites referred to as the paddock, tennis courts and east lodge land.
Place partnership on behalf of the police will argue that just developing the HQ and some new dwellings on the site will not be financially viable due to perceived high costs of demolition, contamination surveys, listed building problems, ect. With a low average plot per dwelling value of say 200k for 88 units that would produce £17.6M, surely even enough for them to make it work.
In the WDC Leek Wootton SA objectives addendum, SA5, prudent use of land and natural resources, it was suggested that a "long term negative effect of building on greenfield land located within the green belt" was identified and red flagged at Woodcote.
You are aware that the last application to build on the Paddock had numbers reduced down from 30 to 11 because of strong objections from conservation at WDC and Heritage England. Nothing has changed.
The small area between Broome House and East Lodge abuts the conservation area and has a driveway servicing East Lodge that is very close to mature trees with TPO protection. The driveway is made of chippings to protect the tree roots and is not really suitable for additional use. This land would be better suited to additional sympathetic planting of trees and shrubs to become a natural habitat for wildlife.
Broome House (BH) was included by WDC during the creation of Tree Preservation Order 448 with the whole of the Woodcote Estate. I made representations to have BH excluded from the TPO but WDC Tree preservation order subcommittee at a meeting on 31st January 2012 decided it must be included. Their assessment was:
* The TPO had been made to protect all the trees which form a part of the landscape setting of Woodcote, a grade II listed building.
* Woodcote stands in extensive grounds which are largely landscaped parkland.
* The grounds are a Locally Listed Garden.
* The grounds of Broome House originally formed part of the Woodcote Estate
* The grounds of Broome House clearly connect visually and historically with Woodcote and continue to form a part of the landscape setting of Woodcote.
* The TPO is intended to protect all areas that form part of the setting of Woodcote, irrespective of current ownership. It is appropriate to include Broome House within the TPO.

From this it is clear that if WDC consider that BH has a visual impact on Woodcote any building on the paddock would have an even greater impact. The eleven dwellings previously suggested should be allocated elsewhere, preferably in the Woodcote House development leaving the green belt intact.
Access to proposed development.
The main access to Woodcote is via Woodcote Drive with a tree lined secondary single track service entrance by North Lodge. Both are part of the estate and un-adopted. The only other access, possibly via a new entrance off Woodcote Lane, is not possible as adequate visibility splays are not available (as set out in site appraisal preferred option 1 appendix 6). It would also have a high landscape impact as would the whole development.
The development would therefore have to be accessed via Woodcote Drive and with 120 new dwellings and the existing 14 residential properties based on 7 movements per dwelling per day movements of 900+ could occur, many concentrated around rush hour.
This is clearly not possible or acceptable for reasons listed here:
* Woodcote Drive is barely wide enough for two cars to pass (4.5m wide at most) and has no footpath. Assuming new residents would have children wishing to walk to the village school a footpath would have to be provided which is not possible due to the proximity of mature trees with a TPO. This would also have a major impact on the main entrance to Woodcote and the Manor House.
* Several concealed driveways already exist.
* The existing main decorative gate on Woodcote Lane is 3.1m wide. Is in the village conservation area and probably listed being within the curtilage of a Grade 2 listed building.

Impact on surrounding area and Woodcote Lane.
The junction of Woodcote Lane and Warwick Road is considered by Leek Wootton residents as very dangerous. By some, the site of a fatal accident waiting to happen. Even with the recent introduction of improved speed restriction signage vehicles still speed through the village and near misses happen on a regular basis. A serious 2 vehicle collision happened on November 23rd 2014 resulting in a casualty being cut from a car by attending fire crews and then taken to Warwick Hospital. Any development that increases traffic at the junction will increase the possibility of more accidents occurring.
Woodcote Lane narrows by the Anchor pub and it is difficult for cars to pass safely and impossible if commercial vehicles meet requiring them to mount the narrow footpath to pass. It is impossible for any widening of the road or footpaths to take place at this point due to the proximity of buildings, most of which are listed.
Woodcote Lane heading towards Rouncil Lane is in a poor state of repair and has been for many years. The narrow bridge is also a cause for concern as is again, the lack of footpaths and lighting.

Warwickshire Police HQ DSNEW3.

A possible solution.
This would be conditional on a satisfactory master plan for site DSNEW3 and should not be allowed until completion of the HQ development.

Dwellings
At a recent meeting with Colin Smith from the PC, I showed him my thoughts on a compromise for some development possibilities on site DSNEW3: Between East lodge and Broome House, two detached bungalows, along Woodcote Drive from Broome House towards HQ, six detached bungalows and on the tennis court a further six bungalows or detached two story houses. These later two areas should try to replicate/compliment the layout of 11-14 Woodcote Drive. A total of 14 dwellings, similar to the quantity suggested in the last local plan.
Bungalows are suggested in the main to reduce the impact on the setting and important views of Woodcote House and the listed gardens. A small carpark could also be achieved for walkers of the golf course and the new path through the gardens of Woodcote to the Lunch Woods within the tennis court site.
It may also be possible to fit in two dwellings where numbers 1 and 2 Woodcote drive should be (between number 3 Woodcote Drive and the Tinker Tank path). I believe the police own this land and it is an obvious infill.
Site Access
It has been suggested that the main entrance to the development at HQ will be past North lodge with a new drive running parallel to the existing single drive and a new footpath. This additional drive will be unavoidable due to the originals width and the avenue of listed trees running both sides of it. From North Lodge a footpath could be built on the south west side of Woodcote Lane that would eventually, by crossing Woodcote Lane, (perhaps an opportunity for a zebra crossing) join the existing path by Waller Close.
This new North Lodge main entrance will create an opportunity to solve several issues with Woodcote Drive:
* Volume of traffic
* Speeding
* The width of the listed gates.
* the width of the drive which makes it difficult for cars to pass and impossible for commercial vehicles to pass.
* The lack of a footpath and difficulty in achieving one.

When the police put forward a plan for additional office space at Woodcote some years ago it was intended to split the site in two with a division between Woodcote House and the buildings to the north.
If this now happened Woodcote Drive would only service Woodcote Drive properties, the suggested apartments in Woodcote House itself and be blocked to any vehicles from the development north of Woodcote House. This would mean only residents and visitors vehicles would use Woodcote Drive, hopefully with more care than being shown by present users, and with enhanced speed bumps create a safer environment for pedestrians/cyclists. It may also satisfy heritage and conservation concerns by providing an opportunity to reinstate a more appropriate entrance and visual setting for the listed House and Gardens.
Pedestrians from the HQ development could walk/ride across the new purposed pathway in front of Woodcote house onto a safer Woodcote drive to continue into the village centre and school.
The proposed entrance into the paddock off Woodcote Lane, roughly opposite Waller Close, would not be required. No issues regarding vision splays, damage to the hedgerow or trees as a result.

Conclusion.
Now that the Police HQ brownfield site is included for development a sensible number of dwellings can be achieved without ingress into the Paddock area other than suggested along Woodcote Drive.
The PC Woodcote site preferred "sensitive" option achieved 53 dwellings so potentially with my suggestions somewhere around 70 dwellings could be achieved. This would be a far more appropriate increase for Leek Wootton and leave a large area of open space greenbelt mainly untouched.
The setting of the listed house would be dramatically improved and site access issues would be resolved.
Having discussed this suggestion with neighbours in Woodcote Drive the general consensus is that this is a sensible, achievable and most importantly satisfactory way forward.

See attached

* The decision by the Warwickshire Police Force to vacate the Woodcote HQ site has brought a new dimension to the planning proposals for the Parish. The additional availability of potential housing land at Woodcote has significantly changed the parameters for new development in the village of Leek Wootton and raises again many of the issues that surfaced during the consultation conducted in 2013.

* Of course the pressure on WDC to increase overall housing numbers, following the suspension of the Local Plan submission by the Inspector, is well recognised. But the Parish Council contends that it is essential that the scale and character of new development in the village should be commensurate and preserve the unique nature of Leek Wootton, even when surrounded by its much larger urban neighbours, Kenilworth, Warwick and now also Leamington.

* As a point of reference, the proposed numbers for new housing have progressed from 85 in the 'Village Housing Options and Settlement Boundaries Consultation' in November 2013 to 45 in the 'Local Plan Publication Draft' in April 2014, subsequently revised to 26 in the submission, and now back to 120. This represents an increase of more than a third in the current housing stock. As noted in our previous representation in 2013, we believe this is excessive and will bring other pressures to bear on the village, the Parish in general and the environment.

* It is therefore important to consider the mix of development between DS NEW3, Woodcote and the other site at H37 'Land at the entrance to the Warwickshire Golf Club' in terms of both scale and type of housing.

* For this reason the Parish Council proposes that the overall number of potential new properties should be lower in total at 103, but distributed as follows:

o The Warwickshire Car Park 15
o Woodcote 88

This is not significantly different from the District Council's proposal, but it is based upon detailed technical evaluation and conceptual layouts prepared for the Parish Council by AECOM as part of the Neighbourhood Plan preparation.
* Our Neighbourhood Development Plan is an important and defining document for our community and we have not arrived at these housing numbers lightly. Whilst we will continue to look at the allocation of dwellings between the different parts of the Woodcote site, our guiding principle is to ensure that the scale of future development is commensurate with the layout and character of the rest of the village. Within this we also have a one time opportunity and responsibility to create a proper setting for the Woodcote manor house that preserves and enhances its status both now and into the future.

* Even at these levels it would represent almost 30% increase in the housing stock. However, with suitable attention to mix of properties and design criteria, this could be acceptable in the circumstances of the required increases across the District.

* In addition to a reduction in the scale of the overall development, the Parish Council also believes that the proposed revision to the inset boundary, in order to take in the majority of the Police HQ site, is inappropriate. We believe that to remove such a large tract of land from the Green Belt is not necessary and the inset boundary should follow the earlier proposal made in the 2013 'Settlement Boundary' which leaves the playing fields and registered park and garden areas of the Woodcote site under Green Belt protection. Close attention also needs to be paid to the number of protected trees and hedgerows as a fundamental part of the Master planning exercise.

* The increase in dwellings at Woodcote will present issues for future traffic management, particularly at 'The Anchor' junction. These will also need to be addressed as part of a Master plan for the development of the site.

* An increase in the population of the village by a minimum of 300 - and potentially more than double that figure - will require substantial improvements to footpaths and cycle-ways to the north and south of Leek Wootton. The current footpaths are inadequate and potentially dangerous, especially at the northern exit along Warwick Road. Improvements will require the purchase of additional land, which must also feature in any master planning exercise for the redevelopment of Woodcote.

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Appendix 1

Ancient Woodland

As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved. We own over 1,250 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.

Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost. As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.

The Trust is concerned about a number of site allocations included in the Warwickshire Local Plan as they could lead to the damage and loss of ancient woodland.

Planning policy

National Planning Policy Framework (NPPF) paragraph 118 states that "planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss."
Emerging national policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The Communities and Local Government (CLG) Select Committee published its report following its June 2014 inquiry into the 'Operation of the National Planning Policy Framework (NPPF)', in which it has specifically recognised the need for better protection for ancient woodland (Tues 16th Dec 2014). The CLG Select Committee report states: 'We agree that ancient woodland should be protected by the planning system. Woodland that is over 400 years old cannot be replaced and should be awarded the same level of protection as our built heritage. We recommend that the Government amend paragraph 118 of the NPPF to state that any loss of ancient woodland should be "wholly exceptional". We further recommend that the Government initiate work with Natural England and the Woodland Trust to establish whether more ancient woodland could be designated as sites of special scientific interest and to consider what the barriers to designation might be.' http://www.publications.parliament.uk/pa/cm201415/cmselect/cmcomloc/190/190.pdf.
This shows a clear direction of travel, recognising that the NPPF does not currently provide sufficient protection for ancient woodland. Until the NPPF is amended there is a clear role for Local Plans and associated documents to provide this improved level of protection and to ensure that irreplaceable habitats get the same level of protection as heritage assets enjoy under the NPPF.
This recommendation should also be considered in conjunction with other - stronger - national policies on ancient woodland and ancient trees-
* The Government's policy document 'Keepers of Time - A statement of Policy for England's Ancient & Native Woodland' (Defra/Forestry Commission, 2005, p.10) states: 'The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland'. 'Keepers of Time' (Defra, 2005) - now re-affirmed in the Government's Forestry Policy Statement - also requires that: 'Ancient and native woodland and trees should make an increasing contribution to our quality of life....Take steps to avoid losses of ancient woodland and of ancient and veteran trees' (P.10/11).
* The Government's Independent Panel on Forestry states: 'Government should reconfirm the policy approach set out in the Open Habitats Policy and Ancient Woodland Policy (Keepers of Time - A statement of policy for England's ancient and native woodland).....Reflect the value of ancient woodlands, trees of special interest, for example veteran trees, and other priority habitats in Local Plans, and refuse planning permission for developments that would have an adverse impact on them.' (Defra, Final Report, July 2012). This has been endorsed by the response in the Government Forestry Policy Statement (Defra Jan 2013): 'We recognise the value of our native and ancient woodland and the importance of restoring open habitats as well as the need to restore plantations on ancient woodland sites. We, therefore, confirm our commitment to the policies set out in both the Open Habitats Policy and Keepers of Time, our statement of policy for England's ancient and native woodland'.
* The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, para 2.56) states that: 'The Government is committed to providing appropriate protection to ancient woodlands....'.

* The Biodiversity Strategy for England (Biodiversity 2020: A Strategy for England's Wildlife & Ecosystem Services, Defra 2011, see 'Forestry' para 2.16) states that - 'We are committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland site'.
There is increasing evidence of other local authorities supporting absolute protection of ancient woodland in their LDF planning documents -

North Somerset Council Core Strategy Adopted April 2012 -
'Policy CS4: Nature conservation
North Somerset contains outstanding wildlife habitats and species. These include limestone grasslands, traditional orchards, wetlands, rhynes, commons, hedgerows, ancient woodlands and the Severn Estuary. Key species include rare horseshoe bats, otters, wildfowl and wading birds, slow-worms and water voles.
The biodiversity of North Somerset will be maintained and enhanced by:...
3) seeking to protect, connect and enhance important habitats, particularly designated sites, ancient woodlands and veteran trees'.
South Ribble Borough Council Local Plan 2012 - 2026 (Adopted July 2015)
Policy G13-Trees, Woodlands and Development
a) Planning permission will not be permitted where the proposal adversely affects trees, woodlands and hedgerows which are:
i Protected by a Tree Preservation Order (TPO);
ii Ancient Woodlands including individual ancient and veteran trees and those defined in Natural England's inventory of ancient woodlands;
ii In a Conservation Area; or
iv Within a recognised Nature Conservation Site.
10.73 Ancient Woodlands (woodlands which have been continuously wooded since 1600AD) are particularly important for their flora, fauna and their undisturbed soil and drainage patterns. It is essential that Ancient Woodlands are protected from the adverse effects of development since they are an irreplaceable asset.
10.74 Trees in Conservation Areas also make a special contribution and enhance the environmental quality of these areas. Such trees are protected under the Planning (Listed Buildings and Conservation Areas) Act 1990. Six weeks prior written notice must be given to the local planning authority of any intended works to the trees. This will enable the Council to make a Tree Preservation Order if the proposed works are unacceptable and detrimental to the character of the Conservation Area. The Council wishes to encourage the planting of native tree and hedgerow species, where trees are characteristic of the landscape and are beneficial to wildlife
The Bristol City Council - Site Allocations and Development Management Policies (Adopted July 2014) [part of Local Plan) states that
Policy DM17: Development Involving Existing Green Infrastructure
"Trees
All new development should integrate important existing trees. Development which would result in the loss of Ancient Woodland, Aged trees or Veteran trees will not be permitted".
Torbay Local Plan (adopted December 2015) Policy C4 - Trees, hedgerows and natural landscape features
"Development will not be permitted when it would seriously harm, either directly or indirectly, protected or veteran trees, hedgerows, ancient woodlands or other natural features of significant landscape, historic or nature conservation value".


In addition Policy NE2 Protecting Designated Biodiversity and Geodiversity Assets of the Warwick DC Local Plan Submission version (sub para a) also provides protection for ancient woodland and veteran trees.


Natural England's standing advice for Ancient Woodland and Veteran Trees (published April 2014), paragraph 4.8.1 states: 'Ancient woodland is of prime ecological and landscape importance, providing a vital part of a rich and diverse countryside. In particular, ancient woodland:

* is exceptionally rich in wildlife, and supports many rare and threatened species;
* may contain surviving descendants and features from the original natural forests;
* acts as reservoirs from which wildlife can spread into new woodlands;
* has valuable soils due to their undisturbed nature;
* is an integral part of England's historic landscapes and the biological and visual functioning of a landscape;
* contains a wealth of features of historical and archaeological importance little altered by modern cultivation or disturbance;
* contributes to people's sense of place and imagination.'

Impacts on ancient woodland

Approximately one quarter of priority UK BAP species are associated with woodland habitats. Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.

Woodland wildlife populations are exposed to damaging external impacts from outside the woodland site. Intensity of land use adjacent to ancient woodland results in an increase in these external impacts, otherwise known as 'edge effects'. Detrimental edge effects have been shown to penetrate woodland causing changes in ancient woodland characteristics that extend up to three times the canopy height in from the forest edges.

Creation of new areas of woodland or buffer zones around semi-natural habitats, and more particularly ancient woodland, will help to reduce and ameliorate the impact of damaging edge effects, serving to improve their sustainability. The size of the buffer is dependent on the intensity of land use in the intervening matrix between ancient woods.

Natural England's standing advice for Ancient Woodland and Veteran Trees, paragraph 6.4, highlights the importance of keeping development away from ancient woodland and buffering it where necessary:

"Development must be kept as far as possible from ancient woodland, with a buffer area maintained between the ancient woodland and any development boundary. An appropriate buffer area will depend on the local circumstances and the type of development. In a planning case in West Sussex the Secretary of State supported the arguments for a 15m buffer around the affected ancient woodland, but larger buffers may be required."

The size of a number of the site allocations suggests that large scale development could potentially take place. The minimum 15m buffer recommendation to all development is not effective in ensuring that ancient woodland within and/or adjacent to site allocations is not affected by potential future development. Buffers should be constructed on a case-by-case basis rather than a 'one size fits all' approach.

The Woodland Trust is particularly concerned about the following:

* Disturbance by noise, light, trampling and other human activity;
* Fragmentation as a result of the destruction of adjacent semi-natural habitats;
* Development providing a source of non-native plants and aiding their colonisation;
* Where the wood edge overhangs gardens, branches and even whole trees can be indiscriminately lopped/felled, causing reduction of the woodland canopy;
* There will inevitably be safety issues in respect of trees adjoining public areas and buildings, which will be threatening to the longer-term retention of such trees;
* There can be changes to the hydrology altering ground water and surface water quantities. Also the introduction of water run offs from urban development will result in changes to the characteristics and quality of the surface water as a result of pollution/contamination etc.

The close proximity of a large development to ancient woodland and ancient trees could have numerous adverse impacts on the health of the site.

In order to protect the site's fauna and flora from exposure to edge effects it is necessary to implement a buffer zone. A buffer is a landscape feature used to protect sensitive areas from the impacts of development (or other harmful neighbouring land use). The buffer could be planted with trees or shrubs or it could be an area of land which the development is not allowed to encroach upon (e.g. a grassy strip).

Buffers should be designed on a case by case basis, and depend on a variety of factors, such as number of houses, alternative areas of green space available, layout of the development, etc. The Trust recommends that a buffer of at least 15m is implemented between the proposed development and ancient woodland. This buffer should consist of 50% planting of semi-natural vegetation.

The implementation of a buffer consisting of hawthorn would help to prevent edge effects and garden-related problems from arising by preventing encroachment on to our site. Alternatively a grassy strip would also serve an important purpose as it will help to separate the woodland from development and encourage a phased habitat to the woodland edge.

It should be noted that gardens of adjacent housing must not be included within buffer zones as there is limited control over how they may be used, or developed in the future; for example, they might be paved or decked without the need for planning permission or they may include inappropriate species which could integrate themselves into our site. Further to this the Trust recommends that gardens of houses are not backed on to our site as they result in the increase of garden-related problems for adjacent wooded areas, i.e. waste tipping, littering, spreading of invasive and non-native plants species, disturbance, pet intrusion, etc.

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We wish to submit our comments on the following modifications;
H64A. We wish to object to the inclusion of the land which does not currently hold a planning consent for development (i.e. land locally known as "the Strawberry Field"
For good reasons the Council did not include this site, together with the Asps and the land south of Gallows Hill in the previous draft of the Local Plan, and subsequently expended considerable effort and resources in defending two of those three at appeal. The inspector at the Asps inquiry recognised the importance of that site in terms of the impact of its development on Warwick Castle Park, and it is regrettable that the Secretary of State chose to over-rule her recommendation.
However, we do not consider that the loss of two of these three sites should automatically be considered a reason for abandoning the third to development also. The reasons for objection to the first two remain valid, in spite of the damage which will be caused by the now existing consents. The preservation of the openness of this piece of land would still enhance the setting of Warwick Castle Park and retain a little of the designed intent of the approach to and departure from Warwick. Added to this, the cumulative impact of additional traffic on the historic environment of the closer approach to Warwick and within the historic town should remain a reason for excluding this site. There should no longer be an argument of lack of housing land supply which was the reason for the Secretary of State ignoring the advice of the Asps inspector and we believe that exclusion of this site from the plan would be defensible.
DSNEW3.1 and 3.2. We welcome the stated intention of producing a masterplan to sensitively respect the locally listed park and garden at Woodcote when considering proposals for new development there.