5.1 Housing and development

Fully support the aims of this overall policy for the good of the town, save for my technical objection on a small part of policy RLS2.

These are the Comments from Members of Kenilworth Town Council:


Response to Royal Leamington Spa Town Council, on Submission version of the Neighbourhood Development Plan.

Members of Kenilworth Town Council have read and considered your plan and documentation and are impressed by its ambition and thoroughness. We wish you the best of luck with the remaining steps in the process of completing your Neighbourhood Plan.

With reference to Policy RLS2 – Housing Design:-
Kenilworth Town Council (KTC) would like to share their experience of the way that KP15 in the Kenilworth Neighbourhood Plan (KNP) has been observed by developers.
“Policy KP15 Environmental Standards of New Buildings
Development proposals are encouraged to adopt higher environmental standards of building design and energy performance such as the Passivhaus or similar approach.
This policy seeks to encourage applicants to incorporate the highest standards of building design ad performance. The public sector has an important role to play in demonstrating the practicalities and long term benefits of adopting high environmental building standards.”
The KNP was written under the NPPF 2012 and the Inspector required that the policy was amended as we could not require building standards above the national building regulations at the time.
Hence the word ‘encouraged’ is used.
The result of this, from the viewpoint of the KTC, is that this policy has been effectively ignored by developers whether that be for private developments or public sector builds.
KTC would recommend that policy RLS2 is reviewed to consider whether a clear requirement can be specified without words such as ‘encouraged’, ‘where possible’, ‘not reasonably practicable’ all which may provide developers leeway to not meet the desired intention of this policy.

With reference to Policy RLS15 – Cycling:-
KTC would like to positively state their support for the cycleway to connect Leamington to Kenilworth for active travel (K2L) that is referred to in this policy statement.

Climate Emergency.

I can find no reference to the Climate Emergency Motion and action plan that has been developed by Warwick District Council.


5.1 Housing Development.

Housing Design

Paragraph 5.1.9 states quote …….”There is also a need to ensure that new housing achieves the highest possible standards in terms of environmental performance, thereby reducing impact on the environment and climate change”

The highest possible standard would be to build to net zero carbon and Policy RLS2 certainly will not deliver this. Setting a net zero carbon standard such as Passivhaus Plus or equivalent would certainly fit with the second commitment of the WDC Climate Emergency strategy namely quote:


2.Facilitating decarbonisation by local businesses, other organisations and residents so that total carbon emissions within Warwick District are as close to zero as possible by 2030.

Retrofitting to net zero carbon is a lot more expensive than setting out with that standard at the start.

The Committee on Climate Change have calculated that the extra cost of building to a 15kWh/m2/yr standard (e.g Passivhaus standard or equivalent.) as opposed to the current building regs level would be around £4,800 per dwelling, while the cost of retrofitting to this standard would be £26,300. So taking into account the WDC Climate Emergency strategy why would the Neighbourhood Plan not mandate a 15kWh/m2/yr standard to fit with the Climate Emergency ambition?


The statement within Policy RSL2 – quote “Applicants are encouraged to go beyond prevailing sustainable development standards particularly with regard to environmental performance of buildings……….” is probably worthless and developers will just say that they are ‘policy compliant with the Local Plan and build to the out-dated 2013 building regulations.

I use as evidence of this Kenilworth Neighbourhood Plan Policy KP15 which has similar wording.

Policy KP15 Environmental Standards of New Buildings

Development proposals are encouraged to adopt higher environmental standards of building design and energy performance such as the Passivhaus or similar approach.

5.69 This policy seeks to encourage applicants to incorporate the highest
environmental standards of building design and performance. The public sector has an important role to play in demonstrating the practicalities and long term benefits of adopting high environmental building standards.

To date in every planning application submitted to the WDC Planning Committee developers have completely ignored this policy.

Could I suggest that the LSNP uses words similar to those included in WDC Local Plan Policy CC3 when highlighting decentralised heating networks. I would suggest replacing the words “Applicants and encouraged to go beyond ……” by “The Council will expect the applicants to consider going beyond……….”

I would further suggest adding the following paragraphs:

Development within the scope of the policy will be required for higher environmental standards to incorporate the assessment into the Sustainable Building Statement submitted with the planning application.

Promoting higher environmental standards forms an important part of central government’s decarbonisation strategy and in addition the Council’s Climate Emergency strategy.

Policy RLS2 goes on to state developers should aim to achieve Level 4 of the Code for Sustainable Homes. I have two comments to say about this:

1. The Code for Sustainable Homes was abolished by the Conservative administration in 2015.
2. The Code for Sustainable Homes is (or rather was) approximately a 20% improvement above the current building regulations. Why would you ask for a 20% improvement when the current consultation on building regulations was recommending the option for a 31% improvement?

Fabric First

It is important to include a Policy that developers must adopt a Fabric First approach to the design of new buildings


Performance Gap.

It is vitally important to have a policy that addresses the ‘performance gap’.

Within the UK, buildings are required to comply with a design standard set by building regulations currently the out dated 2013 regulations. In mainland Europe and elsewhere internationally, buildings are required to comply with a performance-in-use standard. The so called ‘performance gap’ is the difference in performance between the design intent and what is actually achieved post construction, and this ‘performance gap’ is of critical importance to the user………and the planet!

As evidence of the importance of mitigating the performance gap I would refer to an intensive study into new domestic and non-domestic buildings carried out under the Technology Strategy Board/Innovate UK’s Building Performance programme which revealed a typical performance gap of between 2.5 and 4 times for energy use. A secondary school that was reviewed recently by a colleague from the Passivhaus Trust found that the building was using 5 times more energy than was predicted.
I would recommend that a policy be added to the Leamington Neighbourhood Plan along the lines as has been develop by Milton Keynes Council.

The Developer must implement a recognised quality regime that ensures the ’as built’ performance (energy use, carbon emissions, indoor air quality, and overheating risk) matches the calculated design performance of dwellings. The Developer must put in place a recognised monitoring regime to allow the assessment of energy use, indoor air quality, and overheating risk for 10% of the proposed dwellings for the first five years of their occupancy, and ensure that the information recovered is provided to the applicable occupiers and the planning authority.

Sustainable Urban Drainage Systems (SUDS)

No development scheme should take place without a detailed SUDS strategy. This will help with many items of resilience, for example improving flood prevention.

Development Plan Documents. (DPD)

I can see no reference to the DPD currently being developed by Warwick District Council.

See attachment

See attachment

The Leamington Society is very happy to write in support of the Royal Leamington Spa Neighbourhood Plan, which we regard as crucial to the future of Royal Leamington Spa as a place in which to live, work and enjoy. The majority of our comments, perhaps not surprisingly, refer to the housing and development theme.


1. Housing and Development Theme

Policy RLS1– Housing Development Within the Royal Leamington Spa Urban Area

We fully support promoting of high quality, sustainable housing, particularly where it does not lead to the loss of residential gardens, except in the specific circumstances listed.

The Society has been concerned about the provision of so much purpose-built student accommodation within the town, and notes that the Neighbourhood Plan only supports this when positively assessed against Local Plan and any relevant supplementary planning document. We are concerned that any block of student housing should also be of an architecture particularly sympathetic to the surrounding buildings to enhance the area they are situated in.


Policy RLS2 – Housing Design

Government Policy and Building regulations are a changing landscape which makes Local Authority requirements a nightmare to impose but the Society fully supports the aims which should ensure that we encourage/impose as high a standard as possible for new buildings to combat climate change, fuel poverty, resource consumption and recycling. In view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 we think a requirement for access to electric charging points should be added to any car parking requirements. The Society supports sympathetic design that retains local distinctiveness; which does not preclude innovative designs.

Policy RLS3 – Conservation Areas
The Leamington Society is fully supportive of all 15 of the criteria listed, requiring those applying to develop within these areas to consider, prepare and describe how their proposed development meets each relevant one.

Policy RLS4 – Housing Character Outside the Conservation Areas
We fully support this policy and particularly welcome the requirement that development should seek to maintain views of higher slopes, skylines and the wider landscape.

Policy RLS5 – Royal Leamington Spa Housing Mix and Tenure
The Leamington Society fully supports your desire that in any housing development the proposed housing mix has taken in to account the following:
“(a) The relatively high levels of social and private renting in South Leamington and the need to support affordable owner occupation in this area; and
(b) The relatively high-level of flats and apartments in the neighbourhood area and the potential, in appropriate locations, to provide detached and semi-detached family homes.”



2. Community and Culture Theme

Policy RLS7 – Public Art.
As commented in our previous consultation response, the Society would like to see the artists chosen having local connections.



3. Green Spaces and Parks Theme

The Society notes that there is no mention of a tree-planting policy.

Policy RLS11 – Allotments
The Society fully supports the protection of the allotments listed, and the hope of creating new ones, and the innovation of support being offered to residents who wish to use their lawns for shared allotment gardens.

Policy RLS12 – Leisure, Sport and Recreation Facilities
The Society supports the protection of all the facilities listed especially the Tennis courts, Christchurch Gardens, Beauchamp Avenue which provided a very valuable recreational facility for those living in nearby flats.

4. Roads and Transport Theme

Policy RLS13 – Air Quality
The Leamington Society regards air pollution as a significant problem in parts of Leamington, and welcomes all proposals to help improve the situation.

Policy RLS14 – Traffic and Transport
The Leamington Society support these measures which will, we hope, help improve the air quality of Royal Leamington Spa, particularly the measures to prioritise the movement of pedestrians, cyclists and public transport within the Town Centre whilst still allowing for through traffic. Improved footpath and cycle links with good signposting, alone might significantly reduce car use.

Policy RLS15 – Cycling
The Society supports these proposals, as the provision of safe cycleways within Leamington might greatly contribute to a reduction in car use. In our opinion there is an immediate need for more cycle racks in the town centre.

Policy RLS16 – Canal and Riverside Development
We support these proposals particularly the requirement that development respects the heritage and setting of the canal, Canal Conservation Area, or riverside area, as these are important elements of Leamington’s history and setting. We also particularly support the aim of providing facilities to support the growth and development of recreation and tourism; and supports the wider regeneration aspirations of the Creative Quarter.

Town Council Supporting Action – Community Infrastructure Levy (CIL)
We support the listed proposals particularly cycling infrastructure, especially the provision of safe cycleways to schools.

5. Business Support/Town Centre Theme

Policy RLS17 – Royal Leamington Spa Town Centre
The Leamington Society supports improving the appearance of gateway entrances to the town, especially the entrance to the Town Centre from the railway.

Policy RLS18 – Royal Leamington Spa Creative Quarter
We support the particular policies relating to the development within the Royal Leamington Spa Creative Quarter, identified on the Policies Map, expressing our concern for the appropriate future use of both the Town Hall and the old Post Office in Priory Terrace.

Policy RLS19 – Old Town Retail Area
Old Town has special qualities, particularly the independent, artisanal quality of the area which if possible should be developed further to link with the creative quarter.


Policy RLS20 – Royal Leamington Spa Town Centre Shopfronts
This is an important policy to retain the distinctiveness of Royal Leamington Spa’s retail areas.

Policy RLS21 – Protected Car Parks
Adequate car parking in Leamington is vital for workers, residents and visitors from further afield. With possible changing transport solutions it is possible that demand will change, and the proposal wisely allows for this.

Policy RLS22 – Local Shopping Centres
Local shopping centres provide a useful community resource, particularly for the elderly, and save on journeys, which is why the Society supports the addition of the 3 more at Brunswick Street, Binswood Street and Lansdowne Street. Recycling provision is useful, but is currently causing flytipping problems at some local shopping centre locations.

The Leamington Society is very happy to write in support of the Royal Leamington Spa Neighbourhood Plan, which we regard as crucial to the future of Royal Leamington Spa as a place in which to live, work and enjoy. The majority of our comments, perhaps not surprisingly, refer to the housing and development theme.


1. Housing and Development Theme

Policy RLS1– Housing Development Within the Royal Leamington Spa Urban Area

We fully support promoting of high quality, sustainable housing, particularly where it does not lead to the loss of residential gardens, except in the specific circumstances listed.

The Society has been concerned about the provision of so much purpose-built student accommodation within the town, and notes that the Neighbourhood Plan only supports this when positively assessed against Local Plan and any relevant supplementary planning document. We are concerned that any block of student housing should also be of an architecture particularly sympathetic to the surrounding buildings to enhance the area they are situated in.


Policy RLS2 – Housing Design

Government Policy and Building regulations are a changing landscape which makes Local Authority requirements a nightmare to impose but the Society fully supports the aims which should ensure that we encourage/impose as high a standard as possible for new buildings to combat climate change, fuel poverty, resource consumption and recycling. In view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 we think a requirement for access to electric charging points should be added to any car parking requirements. The Society supports sympathetic design that retains local distinctiveness; which does not preclude innovative designs.

Policy RLS3 – Conservation Areas
The Leamington Society is fully supportive of all 15 of the criteria listed, requiring those applying to develop within these areas to consider, prepare and describe how their proposed development meets each relevant one.

Policy RLS4 – Housing Character Outside the Conservation Areas
We fully support this policy and particularly welcome the requirement that development should seek to maintain views of higher slopes, skylines and the wider landscape.

Policy RLS5 – Royal Leamington Spa Housing Mix and Tenure
The Leamington Society fully supports your desire that in any housing development the proposed housing mix has taken in to account the following:
“(a) The relatively high levels of social and private renting in South Leamington and the need to support affordable owner occupation in this area; and
(b) The relatively high-level of flats and apartments in the neighbourhood area and the potential, in appropriate locations, to provide detached and semi-detached family homes.”



2. Community and Culture Theme

Policy RLS7 – Public Art.
As commented in our previous consultation response, the Society would like to see the artists chosen having local connections.



3. Green Spaces and Parks Theme

The Society notes that there is no mention of a tree-planting policy.

Policy RLS11 – Allotments
The Society fully supports the protection of the allotments listed, and the hope of creating new ones, and the innovation of support being offered to residents who wish to use their lawns for shared allotment gardens.

Policy RLS12 – Leisure, Sport and Recreation Facilities
The Society supports the protection of all the facilities listed especially the Tennis courts, Christchurch Gardens, Beauchamp Avenue which provided a very valuable recreational facility for those living in nearby flats.

4. Roads and Transport Theme

Policy RLS13 – Air Quality
The Leamington Society regards air pollution as a significant problem in parts of Leamington, and welcomes all proposals to help improve the situation.

Policy RLS14 – Traffic and Transport
The Leamington Society support these measures which will, we hope, help improve the air quality of Royal Leamington Spa, particularly the measures to prioritise the movement of pedestrians, cyclists and public transport within the Town Centre whilst still allowing for through traffic. Improved footpath and cycle links with good signposting, alone might significantly reduce car use.

Policy RLS15 – Cycling
The Society supports these proposals, as the provision of safe cycleways within Leamington might greatly contribute to a reduction in car use. In our opinion there is an immediate need for more cycle racks in the town centre.

Policy RLS16 – Canal and Riverside Development
We support these proposals particularly the requirement that development respects the heritage and setting of the canal, Canal Conservation Area, or riverside area, as these are important elements of Leamington’s history and setting. We also particularly support the aim of providing facilities to support the growth and development of recreation and tourism; and supports the wider regeneration aspirations of the Creative Quarter.

Town Council Supporting Action – Community Infrastructure Levy (CIL)
We support the listed proposals particularly cycling infrastructure, especially the provision of safe cycleways to schools.

5. Business Support/Town Centre Theme

Policy RLS17 – Royal Leamington Spa Town Centre
The Leamington Society supports improving the appearance of gateway entrances to the town, especially the entrance to the Town Centre from the railway.

Policy RLS18 – Royal Leamington Spa Creative Quarter
We support the particular policies relating to the development within the Royal Leamington Spa Creative Quarter, identified on the Policies Map, expressing our concern for the appropriate future use of both the Town Hall and the old Post Office in Priory Terrace.

Policy RLS19 – Old Town Retail Area
Old Town has special qualities, particularly the independent, artisanal quality of the area which if possible should be developed further to link with the creative quarter.


Policy RLS20 – Royal Leamington Spa Town Centre Shopfronts
This is an important policy to retain the distinctiveness of Royal Leamington Spa’s retail areas.

Policy RLS21 – Protected Car Parks
Adequate car parking in Leamington is vital for workers, residents and visitors from further afield. With possible changing transport solutions it is possible that demand will change, and the proposal wisely allows for this.

Policy RLS22 – Local Shopping Centres
Local shopping centres provide a useful community resource, particularly for the elderly, and save on journeys, which is why the Society supports the addition of the 3 more at Brunswick Street, Binswood Street and Lansdowne Street. Recycling provision is useful, but is currently causing flytipping problems at some local shopping centre locations.

The Leamington Society is very happy to write in support of the Royal Leamington Spa Neighbourhood Plan, which we regard as crucial to the future of Royal Leamington Spa as a place in which to live, work and enjoy. The majority of our comments, perhaps not surprisingly, refer to the housing and development theme.


1. Housing and Development Theme

Policy RLS1– Housing Development Within the Royal Leamington Spa Urban Area

We fully support promoting of high quality, sustainable housing, particularly where it does not lead to the loss of residential gardens, except in the specific circumstances listed.

The Society has been concerned about the provision of so much purpose-built student accommodation within the town, and notes that the Neighbourhood Plan only supports this when positively assessed against Local Plan and any relevant supplementary planning document. We are concerned that any block of student housing should also be of an architecture particularly sympathetic to the surrounding buildings to enhance the area they are situated in.


Policy RLS2 – Housing Design

Government Policy and Building regulations are a changing landscape which makes Local Authority requirements a nightmare to impose but the Society fully supports the aims which should ensure that we encourage/impose as high a standard as possible for new buildings to combat climate change, fuel poverty, resource consumption and recycling. In view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 we think a requirement for access to electric charging points should be added to any car parking requirements. The Society supports sympathetic design that retains local distinctiveness; which does not preclude innovative designs.

Policy RLS3 – Conservation Areas
The Leamington Society is fully supportive of all 15 of the criteria listed, requiring those applying to develop within these areas to consider, prepare and describe how their proposed development meets each relevant one.

Policy RLS4 – Housing Character Outside the Conservation Areas
We fully support this policy and particularly welcome the requirement that development should seek to maintain views of higher slopes, skylines and the wider landscape.

Policy RLS5 – Royal Leamington Spa Housing Mix and Tenure
The Leamington Society fully supports your desire that in any housing development the proposed housing mix has taken in to account the following:
“(a) The relatively high levels of social and private renting in South Leamington and the need to support affordable owner occupation in this area; and
(b) The relatively high-level of flats and apartments in the neighbourhood area and the potential, in appropriate locations, to provide detached and semi-detached family homes.”



2. Community and Culture Theme

Policy RLS7 – Public Art.
As commented in our previous consultation response, the Society would like to see the artists chosen having local connections.



3. Green Spaces and Parks Theme

The Society notes that there is no mention of a tree-planting policy.

Policy RLS11 – Allotments
The Society fully supports the protection of the allotments listed, and the hope of creating new ones, and the innovation of support being offered to residents who wish to use their lawns for shared allotment gardens.

Policy RLS12 – Leisure, Sport and Recreation Facilities
The Society supports the protection of all the facilities listed especially the Tennis courts, Christchurch Gardens, Beauchamp Avenue which provided a very valuable recreational facility for those living in nearby flats.

4. Roads and Transport Theme

Policy RLS13 – Air Quality
The Leamington Society regards air pollution as a significant problem in parts of Leamington, and welcomes all proposals to help improve the situation.

Policy RLS14 – Traffic and Transport
The Leamington Society support these measures which will, we hope, help improve the air quality of Royal Leamington Spa, particularly the measures to prioritise the movement of pedestrians, cyclists and public transport within the Town Centre whilst still allowing for through traffic. Improved footpath and cycle links with good signposting, alone might significantly reduce car use.

Policy RLS15 – Cycling
The Society supports these proposals, as the provision of safe cycleways within Leamington might greatly contribute to a reduction in car use. In our opinion there is an immediate need for more cycle racks in the town centre.

Policy RLS16 – Canal and Riverside Development
We support these proposals particularly the requirement that development respects the heritage and setting of the canal, Canal Conservation Area, or riverside area, as these are important elements of Leamington’s history and setting. We also particularly support the aim of providing facilities to support the growth and development of recreation and tourism; and supports the wider regeneration aspirations of the Creative Quarter.

Town Council Supporting Action – Community Infrastructure Levy (CIL)
We support the listed proposals particularly cycling infrastructure, especially the provision of safe cycleways to schools.

5. Business Support/Town Centre Theme

Policy RLS17 – Royal Leamington Spa Town Centre
The Leamington Society supports improving the appearance of gateway entrances to the town, especially the entrance to the Town Centre from the railway.

Policy RLS18 – Royal Leamington Spa Creative Quarter
We support the particular policies relating to the development within the Royal Leamington Spa Creative Quarter, identified on the Policies Map, expressing our concern for the appropriate future use of both the Town Hall and the old Post Office in Priory Terrace.

Policy RLS19 – Old Town Retail Area
Old Town has special qualities, particularly the independent, artisanal quality of the area which if possible should be developed further to link with the creative quarter.


Policy RLS20 – Royal Leamington Spa Town Centre Shopfronts
This is an important policy to retain the distinctiveness of Royal Leamington Spa’s retail areas.

Policy RLS21 – Protected Car Parks
Adequate car parking in Leamington is vital for workers, residents and visitors from further afield. With possible changing transport solutions it is possible that demand will change, and the proposal wisely allows for this.

Policy RLS22 – Local Shopping Centres
Local shopping centres provide a useful community resource, particularly for the elderly, and save on journeys, which is why the Society supports the addition of the 3 more at Brunswick Street, Binswood Street and Lansdowne Street. Recycling provision is useful, but is currently causing flytipping problems at some local shopping centre locations.

The Leamington Society is very happy to write in support of the Royal Leamington Spa Neighbourhood Plan, which we regard as crucial to the future of Royal Leamington Spa as a place in which to live, work and enjoy. The majority of our comments, perhaps not surprisingly, refer to the housing and development theme.


1. Housing and Development Theme

Policy RLS1– Housing Development Within the Royal Leamington Spa Urban Area

We fully support promoting of high quality, sustainable housing, particularly where it does not lead to the loss of residential gardens, except in the specific circumstances listed.

The Society has been concerned about the provision of so much purpose-built student accommodation within the town, and notes that the Neighbourhood Plan only supports this when positively assessed against Local Plan and any relevant supplementary planning document. We are concerned that any block of student housing should also be of an architecture particularly sympathetic to the surrounding buildings to enhance the area they are situated in.


Policy RLS2 – Housing Design

Government Policy and Building regulations are a changing landscape which makes Local Authority requirements a nightmare to impose but the Society fully supports the aims which should ensure that we encourage/impose as high a standard as possible for new buildings to combat climate change, fuel poverty, resource consumption and recycling. In view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 we think a requirement for access to electric charging points should be added to any car parking requirements. The Society supports sympathetic design that retains local distinctiveness; which does not preclude innovative designs.

Policy RLS3 – Conservation Areas
The Leamington Society is fully supportive of all 15 of the criteria listed, requiring those applying to develop within these areas to consider, prepare and describe how their proposed development meets each relevant one.

Policy RLS4 – Housing Character Outside the Conservation Areas
We fully support this policy and particularly welcome the requirement that development should seek to maintain views of higher slopes, skylines and the wider landscape.

Policy RLS5 – Royal Leamington Spa Housing Mix and Tenure
The Leamington Society fully supports your desire that in any housing development the proposed housing mix has taken in to account the following:
“(a) The relatively high levels of social and private renting in South Leamington and the need to support affordable owner occupation in this area; and
(b) The relatively high-level of flats and apartments in the neighbourhood area and the potential, in appropriate locations, to provide detached and semi-detached family homes.”



2. Community and Culture Theme

Policy RLS7 – Public Art.
As commented in our previous consultation response, the Society would like to see the artists chosen having local connections.



3. Green Spaces and Parks Theme

The Society notes that there is no mention of a tree-planting policy.

Policy RLS11 – Allotments
The Society fully supports the protection of the allotments listed, and the hope of creating new ones, and the innovation of support being offered to residents who wish to use their lawns for shared allotment gardens.

Policy RLS12 – Leisure, Sport and Recreation Facilities
The Society supports the protection of all the facilities listed especially the Tennis courts, Christchurch Gardens, Beauchamp Avenue which provided a very valuable recreational facility for those living in nearby flats.

4. Roads and Transport Theme

Policy RLS13 – Air Quality
The Leamington Society regards air pollution as a significant problem in parts of Leamington, and welcomes all proposals to help improve the situation.

Policy RLS14 – Traffic and Transport
The Leamington Society support these measures which will, we hope, help improve the air quality of Royal Leamington Spa, particularly the measures to prioritise the movement of pedestrians, cyclists and public transport within the Town Centre whilst still allowing for through traffic. Improved footpath and cycle links with good signposting, alone might significantly reduce car use.

Policy RLS15 – Cycling
The Society supports these proposals, as the provision of safe cycleways within Leamington might greatly contribute to a reduction in car use. In our opinion there is an immediate need for more cycle racks in the town centre.

Policy RLS16 – Canal and Riverside Development
We support these proposals particularly the requirement that development respects the heritage and setting of the canal, Canal Conservation Area, or riverside area, as these are important elements of Leamington’s history and setting. We also particularly support the aim of providing facilities to support the growth and development of recreation and tourism; and supports the wider regeneration aspirations of the Creative Quarter.

Town Council Supporting Action – Community Infrastructure Levy (CIL)
We support the listed proposals particularly cycling infrastructure, especially the provision of safe cycleways to schools.

5. Business Support/Town Centre Theme

Policy RLS17 – Royal Leamington Spa Town Centre
The Leamington Society supports improving the appearance of gateway entrances to the town, especially the entrance to the Town Centre from the railway.

Policy RLS18 – Royal Leamington Spa Creative Quarter
We support the particular policies relating to the development within the Royal Leamington Spa Creative Quarter, identified on the Policies Map, expressing our concern for the appropriate future use of both the Town Hall and the old Post Office in Priory Terrace.

Policy RLS19 – Old Town Retail Area
Old Town has special qualities, particularly the independent, artisanal quality of the area which if possible should be developed further to link with the creative quarter.


Policy RLS20 – Royal Leamington Spa Town Centre Shopfronts
This is an important policy to retain the distinctiveness of Royal Leamington Spa’s retail areas.

Policy RLS21 – Protected Car Parks
Adequate car parking in Leamington is vital for workers, residents and visitors from further afield. With possible changing transport solutions it is possible that demand will change, and the proposal wisely allows for this.

Policy RLS22 – Local Shopping Centres
Local shopping centres provide a useful community resource, particularly for the elderly, and save on journeys, which is why the Society supports the addition of the 3 more at Brunswick Street, Binswood Street and Lansdowne Street. Recycling provision is useful, but is currently causing flytipping problems at some local shopping centre locations.

The Leamington Society is very happy to write in support of the Royal Leamington Spa Neighbourhood Plan, which we regard as crucial to the future of Royal Leamington Spa as a place in which to live, work and enjoy. The majority of our comments, perhaps not surprisingly, refer to the housing and development theme.


1. Housing and Development Theme

Policy RLS1– Housing Development Within the Royal Leamington Spa Urban Area

We fully support promoting of high quality, sustainable housing, particularly where it does not lead to the loss of residential gardens, except in the specific circumstances listed.

The Society has been concerned about the provision of so much purpose-built student accommodation within the town, and notes that the Neighbourhood Plan only supports this when positively assessed against Local Plan and any relevant supplementary planning document. We are concerned that any block of student housing should also be of an architecture particularly sympathetic to the surrounding buildings to enhance the area they are situated in.


Policy RLS2 – Housing Design

Government Policy and Building regulations are a changing landscape which makes Local Authority requirements a nightmare to impose but the Society fully supports the aims which should ensure that we encourage/impose as high a standard as possible for new buildings to combat climate change, fuel poverty, resource consumption and recycling. In view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 we think a requirement for access to electric charging points should be added to any car parking requirements. The Society supports sympathetic design that retains local distinctiveness; which does not preclude innovative designs.

Policy RLS3 – Conservation Areas
The Leamington Society is fully supportive of all 15 of the criteria listed, requiring those applying to develop within these areas to consider, prepare and describe how their proposed development meets each relevant one.

Policy RLS4 – Housing Character Outside the Conservation Areas
We fully support this policy and particularly welcome the requirement that development should seek to maintain views of higher slopes, skylines and the wider landscape.

Policy RLS5 – Royal Leamington Spa Housing Mix and Tenure
The Leamington Society fully supports your desire that in any housing development the proposed housing mix has taken in to account the following:
“(a) The relatively high levels of social and private renting in South Leamington and the need to support affordable owner occupation in this area; and
(b) The relatively high-level of flats and apartments in the neighbourhood area and the potential, in appropriate locations, to provide detached and semi-detached family homes.”



2. Community and Culture Theme

Policy RLS7 – Public Art.
As commented in our previous consultation response, the Society would like to see the artists chosen having local connections.



3. Green Spaces and Parks Theme

The Society notes that there is no mention of a tree-planting policy.

Policy RLS11 – Allotments
The Society fully supports the protection of the allotments listed, and the hope of creating new ones, and the innovation of support being offered to residents who wish to use their lawns for shared allotment gardens.

Policy RLS12 – Leisure, Sport and Recreation Facilities
The Society supports the protection of all the facilities listed especially the Tennis courts, Christchurch Gardens, Beauchamp Avenue which provided a very valuable recreational facility for those living in nearby flats.

4. Roads and Transport Theme

Policy RLS13 – Air Quality
The Leamington Society regards air pollution as a significant problem in parts of Leamington, and welcomes all proposals to help improve the situation.

Policy RLS14 – Traffic and Transport
The Leamington Society support these measures which will, we hope, help improve the air quality of Royal Leamington Spa, particularly the measures to prioritise the movement of pedestrians, cyclists and public transport within the Town Centre whilst still allowing for through traffic. Improved footpath and cycle links with good signposting, alone might significantly reduce car use.

Policy RLS15 – Cycling
The Society supports these proposals, as the provision of safe cycleways within Leamington might greatly contribute to a reduction in car use. In our opinion there is an immediate need for more cycle racks in the town centre.

Policy RLS16 – Canal and Riverside Development
We support these proposals particularly the requirement that development respects the heritage and setting of the canal, Canal Conservation Area, or riverside area, as these are important elements of Leamington’s history and setting. We also particularly support the aim of providing facilities to support the growth and development of recreation and tourism; and supports the wider regeneration aspirations of the Creative Quarter.

Town Council Supporting Action – Community Infrastructure Levy (CIL)
We support the listed proposals particularly cycling infrastructure, especially the provision of safe cycleways to schools.

5. Business Support/Town Centre Theme

Policy RLS17 – Royal Leamington Spa Town Centre
The Leamington Society supports improving the appearance of gateway entrances to the town, especially the entrance to the Town Centre from the railway.

Policy RLS18 – Royal Leamington Spa Creative Quarter
We support the particular policies relating to the development within the Royal Leamington Spa Creative Quarter, identified on the Policies Map, expressing our concern for the appropriate future use of both the Town Hall and the old Post Office in Priory Terrace.

Policy RLS19 – Old Town Retail Area
Old Town has special qualities, particularly the independent, artisanal quality of the area which if possible should be developed further to link with the creative quarter.


Policy RLS20 – Royal Leamington Spa Town Centre Shopfronts
This is an important policy to retain the distinctiveness of Royal Leamington Spa’s retail areas.

Policy RLS21 – Protected Car Parks
Adequate car parking in Leamington is vital for workers, residents and visitors from further afield. With possible changing transport solutions it is possible that demand will change, and the proposal wisely allows for this.

Policy RLS22 – Local Shopping Centres
Local shopping centres provide a useful community resource, particularly for the elderly, and save on journeys, which is why the Society supports the addition of the 3 more at Brunswick Street, Binswood Street and Lansdowne Street. Recycling provision is useful, but is currently causing flytipping problems at some local shopping centre locations.