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1.1 In its Local Plan Revised Development Strategy, May 2012, the Council [in para 2.2] invites comments on the proposals. Here are the comments of The Warwick Society.
While the Society's main concern is that a better Plan must and can be proposed, these comments are necessarily framed as objections, to make it clear that the present proposals are unacceptable to many residents of Warwick and its neighbourhood as well as to the Society.
Just as the Revised Development Strategy [its para 1.4] focusses on the main changes since the Preferred Options proposals, so this response is to be read alongside the Society's letter of 27 July 2012 commenting on the Preferred Options, of which a copy is annexed, pages 6-10.
1.2 The Warwick Society, the town's civic society, was founded in 1951. It has as its first aim
to conserve, for the benefit of the public, or to encourage the conservation of,
the natural, artistic and cultural amenities of Warwick and its neighbourhood.
It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people. The history and the architectural character of Warwick, which make it one of the most distinctive towns of its size in Britain, were summarised in the Society's letter of 27 July 2012 .
1.3 The Plan and its Development Strategy give an opportunity to make the town and the district around it a finer place, and a better place to live in, to be educated in, to work in, and to visit. It is well-placed at the south-eastern corner of the West Midlands for sustainable development, prosperity and continuing attractiveness. The requirements for a Plan pursuing these ends were summarised in the Society's letter of 27 July 2012 . That letter continued :
The Preferred Options fail by a long way to achieve this. The Issues identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.4 We greatly regret that, in the face not just of the Society's objections but also of strong criticism from the overwhelming majority of respondents to that consultation, the Council proposes an RDS which would do even greater damage to Warwick and its neighbourhood.
97.5% of respondents objected to development of the land south of Warwick. The Council's retort has been to increase substantially the number of houses proposed for that area, postulating that public opinion carries little weight in such decisions.
The arrogant disregard of the Council for the views of residents and other interested parties is itself cause for objection to the RDS.
1.5 The RDS has many accompanying documents. It is a further sign of the attitude of the Council to public involvement that all have been issued simultaneously, giving residents and other interested parties only six weeks during the summer holiday period to understand, discuss and respond to material which has taken well over a year for many council staff and consultants to produce.
As well as much more material in the 'evidence base', these accompanying documents include:
Sites for Gypsies and Travellers, raising concerns for residents adversely affected by the RDS by proposing a majority of the twenty potential locations for the three sites needed throughout the District in the same concentrated area close to Warwick;
The Community Infrastructure Levy Preliminary Draft Charging Schedule, which is not referred to on the Council's webpage notifying us of the consultation on the RDS and G&T sites but only on a later, subsidiary page;
The Final Interim SA Report, which disguises its purpose - Sustainability Appraisal - behind its acronymous title, is neither notified on the webpage outlining the two 'main' consultations, nor referred to at any point in the RDS which it purportedly supports; and
The Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3, which proposes the reversal of existing policies to reduce the impact of traffic in Warwick Town Centre but is not itself the subject of 'consultation'. The County Council unilaterally abolished the Town Centre Forum late in 2012 and has done nothing in the intervening eight months to implement the new but less effective process of discussion with which it proposed to replace it.
1.6 We explain hereafter as briefly as we can our main objections to the Revised Development Strategy. We do not comment on the Final Interim SA Report nor the Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3 or the other accompanying documents, but have many observations on their assumptions, analysis and conclusions which we will make separately.

2 Housing Need
2.1 The criticism of the methodology and the outcome of the housing need projections made in our objection to the Preferred Options , stands. The proposed figure of 12,300 new homes to be built is much too high. We note that it is a provisional figure, pending completion of the joint assessment being carried out with councils in Coventry, Rugby and Nuneaton & Bedworth. It must also be dependent on co-operation with Stratford District Council over its proposal for a new settlement at Gaydon, which might be superior to much of the proposed development south of Warwick in meeting housing needs for employment there.
2.2 You have yourself stated, at the Community Forum meeting held at Warwick Gates on 13 June, that half of those new houses would meet local needs and half would be for incomers . In our view, even less than half of 12,300, under 6,000, will be sufficient to meet local needs, and we refer to the analysis carried out and discussed with you by Ray Bullen for Bishop's Tachbrook Parish Council which supports our conclusion.
2.3 Forecasting as far into the future as 2029 is clearly very uncertain. By fixing now a single end figure, based on assumptions and trends and 'compound interest' - incurred by repeating small percentage differences over many years - the RDS projections can only have one certainty - that they will be wrong. Worse, by taking this single long-distant future figure and giving it short-term weight, in allocating greenfield land for development now, the damage of error will be immediate. This approach is akin to having no plan at all, allowing uncontrolled growth, leaving developers to decide what to build when, with our towns, villages and countryside blighted by the effects of false certainty and a National Planning Policy Framework which seeks development at all costs.
2.4 While the NPPF requires 'sustainable development' which meets an 'established housing need' to be approved , planning applications already made or imminent for much of the land south of Warwick meet neither of these criteria. A realistic forecast of housing need is that the District already has the required five-year +5% supply of sites. Using the exaggerated and uncertain RDS projections in support of short-term, expedient planning applications - which could over-ride the Plan process before it reaches Examination in Public - would open the Council to legal challenge.

3 Prudent use of Land and Natural Resources and
Protection of the Natural Environment and Landscape
3.1 The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint', designated at the time of the construction of the Warwick Technology Park, and intended to give permanent protection to this vital green gap. The Society has repeatedly suggested that it should be designated as Green Belt, but the Council has refused to implement this.
3.2 Building on it would merge the built-up areas, turning them into a single suburban sprawl. This would conflict directly with one of the principles of the Local Plan Strategy, 'avoiding coalescence' .The green space between the built-up areas to the south is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded as strongly.
3.3 Once developed, this green land could not be reclaimed. Its development would conflict with the basic principle of sustainability, 'meeting the needs of the present without compromising the ability of future generations to meet their own needs'

We use the term incomers as being less ugly than the technical term in-migrants, regretting that there seems to be no expression which is not pejoratively confused with the word immigrants; we refer to people moving into Warwick District from other areas, noting that encouraging the movement of better-off people from the West Midlands conurbation and Coventry may be one of the objectives of developers in Warwick District, and perhaps of the Plan.
Your word not ours; Revised Development Strategy, page 8, third point from bottom
Report of the World Commission on Environment and Development to the General Assembly of the United Nations, 11 December 1987
4 Sustainable Transport and Reducing the Need to Travel
4.1 Sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network. While the Local Transport Plan gives priority to sustainable means of transport in the hierarchy - walking, cycling, public transport - the Transport Strategy assumes that these developments would have the same ratio of peak hour car use to housing numbers as every other development of recent decades.
4.2 Development at relatively low density cannot effectively be served by public transport. The low concentration of the population does not provide sufficient volume for a bus service to run viably at a frequency which makes it an attractive competitor with car use. The limited influence which the County Council has over operators of unsubsidised commercial routes make it unlikely that a bus service would survive after the first few years of developer subsidy, as has been seen at other sites including the Hatton hospital redevelopment.
4.3 Whatever the fine words about walking and cycling routes within the suburban developments, these sustainable modes will not make a significant contribution to meeting transport needs. Distances will be too long for walking, for example from the areas south of Warwick to the town centres or railway stations; and cycling will be very unattractive as soon as cyclists reach the road network on which the use of cars has been intensified. The putative designs of new junctions in the Transport Strategy make it clear that the design priority would be to maximise the flow of vehicles, with people on foot and cyclists diverted to circuitous routes, with secondary priority at traffic light controlled crossings.
4.4 The Transport Strategy concludes that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. The infrastructure plan proposes spending almost all of the potential developers' funding contributions on intensifying the use of the existing road network. The schemes that it labels 'junction improvements' and 'mitigation' would be improvements only in maximising the flow of vehicles; and mitigation only in reducing the increase in congestion, while increasing not reducing the impact of traffic on town centre streets. They would both make sustainable modes less usable and damage the historic and natural environment with the intrusive impedimenta of the highway engineer.

5 Air Quality and Climate Change
5.1 The already illegally dangerous pollution in streets in centres of Warwick and Leamington would be made worse by the increase in traffic. Noise and vibration would be constant and business and residential amenity would be damaged.
5.2 No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, and in particular to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings, all require air quality to be given absolute priority.
5.3 It has been suggested by the Council's Chief Executive that the air quality requirement could be met after development has been approved by then considering ways in which traffic through Warwick town centre could be reduced. This approach would invalidate the Transport Strategy, as the only way to reduce the volume of traffic would be transfer to other modes or other routes, neither of which has been assessed in the Strategy. A transport plan which meets all the objectives, including protecting the historic environment and assuring air quality, must be agreed before development is allocated.


6 The Historic Environment and the existing built environment
6.1 Warwick's historic environment is vital both to the social goals of the plan, to give people a sense of place and belonging, and to the economic goals as the basis of its visitor economy. It would be directly damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's.
6.2 Development on the land between Europa Way and the Banbury Road would extend sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would directly damage the Castle Park, Grade 1 registered landscape; and the 'junction improvements' on the Banbury Road would damage its rôle as part of the Castle Park planned landscape.
6.2 The historic environment would also be indirectly damaged by the effect on the economy of the town centre streets being primarily a conduit for through traffic, constantly full of fumes and noise, and with their commercial premises split from each other by queues of vehicles. The damage to the commercial success of the town would lead to a longer term indirect effect of reducing the demand for such premises, residential and commercial, and a fall in their maintenance funding. There is a real risk of the town centre hollowing out, in a miniature echo of the great American cities, becoming a poor quality zone in a car-based suburban sprawl.

7 Other Infrastructure
7.1 While in theory development would be conditional on it funding schools, and healthcare facilities, strong concerns remain that the funding and provision would be inadequate, and that there would be risks to water supply, sewage and drainage.

8 Alternatives to this Plan and Development Strategy
8.1 Lower housing numbers which meet local needs, especially for affordable housing, instead of encouraging in-migration; the gradual release of land for development as demand grows; giving absolute priority to using brownfield and infill sites; building homes close to jobs and not mainly within 20% of Warwick District ... many options exist but have not been given proper consideration in the preparation of the RDS.
8.2 Absolute priority should be given to brownfield sites, with greenfield sites only being allocated when there is a proven immediate need. This will ensure that more brownfield sites become available, their value increased by the non-availability of easy, profitable alternatives for the mass housebuilders.
8.3 While a year ago the IBM/Opus 40 site on the north-west edge of Warwick was to be used for office development, it is now likely to be proposed for housing. It provides a good example of the way in which long-term plans are by their nature crude, and that housing sites can be found on brownfield sites well-connected to the transport network.

9 Conclusion
9.1 In objecting on these strong and numerous grounds to the Revised Development Strategy, the Society offers its assistance to the Council in the necessary task of devising a better alternative, with the full involvement of a wide range of residents and business interests.
1.1 In its document Local Plan Preferred Options, May 2012, at para 3.3, the Council invites the views of all interested parties to help shape a draft Local Plan.
1.2 Here are the views of The Warwick Society. They refer to the Full Version of the Preferred Options and in some cases to some of the supporting documents made available on the Council's website. The Response Form, which we have not found effective for structuring our comments, uses the words 'support or object' rather than the Preferred Options' 'the Council is keen to hear the views'. While we have phrased our comments as views, it will be clear that many would be objections to firmer proposals, and will become formal objections if the next stage of the plan-making process does not respond satisfactorily to them.
1.3 The Warwick Society, the town's civic society, was founded in 1951, and has as its first aim to conserve, for the benefit of the public, or to encourage the conservation of, the natural, artistic and cultural amenities of Warwick and its neighbourhood. It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people.
1.4 Warwick is no stranger to development. The mediæval town was largely destroyed by fire in 1694, though many timber-framed buildings at its fringes survived. Rebuilding followed a plan to widen the streets and to improve fire-resistance with stone and brick walls. It took place at the start of the Georgian era. So the High Street, the Cross, Church Street, St Mary's Church and Northgate Street form an elegant and coherent architectural ensemble. It is the juxtaposition of the mediæval with the Georgian which makes Warwick distinctive. More recently, C19 industrial development based on the canal and then the railway has been followed by more extensive C20 sprawl based on the car and the road network. In the decade 2001-2011, the population of Warwick grew from 23,000 to 30,000, a rate of increase of 30%, among the very fastest rates of any town in the UK. Assimilating this growth and building new communities takes a generation.
1.5 The new Local Plan gives a new opportunity to make the town, and the district around it, a finer place, and a better place to live, be educated, and to work in. Its population may grow, because it is attractive, and well-located at the south-eastern corner of the West Midlands. Its future residents, and those who work here or visit, need a vision which ensures that it continues to be attractive, and to function well.
1.6 This means:
1 Developing the local economy sustainably, both facilitating growth in jobs and income and reducing the impact of climate change;
2 A pattern of development which reduces dependence on the car, congestion and pollution;
3 Transport and social infrastructure which enables people to live sustainably and economically;
4 Walking routes, cycle routes, schools, health centres and shops which allow people of all ages and capabilities easy and healthy access to them;
5 A mix of housing which meets local needs, especially affordable housing for families;
6 A rate of development which allows the towns and their communities to absorb change and make each a socially and personally contenting place to be; and
7 Protecting the natural and historic environment, especially the green hinterland of towns, green spaces within them, and the historic buildings which make them special places.
1.7 The Preferred Options fail by a long way to achieve this. The Issues [para 4.8] identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.8 In the following sections, we consider the three main ways in which the preferred options fail to meet the expectation of those who live in the District, and suggest changes which, if introduced to the draft Local Plan, could make it a very much better direction for the District to follow.

2 Population Growth and the Demand for Housing
2.1 The Preferred Options' emphasis on growth in jobs and housing, each matching the other [para 4.10], is founded on a circular argument and on mere assumptions.
2.2 The Strategic Housing Market Assessment [para 5.13] 'projects' (not forecasts) future growth in the District's population. It explains [SHMA figs 2.13 and A2.4] that 'in-migration' has been much the most important cause of population growth in the fifteen years 1996-2010. Of a total population increase of 18.9k (from 119.8k to 138.7k), 16.5k has been net in-migration, and only 2.4k the natural change. The report notes [para 2.33] that 'past migration trends will have been influenced in part by past levels of housing delivery.'
2.3 The SHMA assumes the average rate of in-migration of the last five of those fifteen years, 2006-2010, and projects it for the next twenty. There is no quantified analysis of the causes of the in-migration, nor any quantified forecast of its future level. It is simply an assumption.
2.4 The SHMA goes on to assume an age profile for the in-migrants, again basing its projection on neither evidence nor analysis, but on assumptions, in this case those of the ONS [SHMA para 2.17]. The projection of net in-migration is the difference between two much larger numbers, gross in-migration and gross out-migration, and the in-migration figure is produced only by adding that assumed net projection to the ONS assumption of out-migration. The projection is not a forecast, just an arithmetical exercise, and its predicted growth in population is no more solid than the assumptions and extrapolations on which it is based.
2.5 The extrapolations have as their base the after-effect of rapid housebuilding in the years before the market collapsed in 2008. All that they show - as described at the end of para 2.2 above - is that if houses are built, people will move into them; in a second circularity, if the mass housebuilders do not believe that their output will be sold, they build little. A third circular argument then enters the Plan as it stands: if the population rises, employment will rise, as those who buy and occupy the new houses are very likely to have jobs - without which they do not have the means to buy the houses.
2.6 We conclude that the preferred level of 'growth' is simply a bid for growth, rather than a forecast for which there is either evidence or action plan, other than almost free-for-all development with all of the negative impacts on existing residents and the environment that that will bring. The alternatives of more modest levels of growth, in both housing and employment, with much lower damaging impacts, would be equally valid for the Council to choose. We urge that it should reconsider its preference in the light of the absence of evidence in support of it, and take a broader view of both growth and all its consequences.

3 Infrastructure
3.1 The infrastructure proposals do not provide for sustainable development. The modelling of the existing network against possible locations for development consists only of modelling vehicle flows. It does not reflect the national polices and Local Transport Plan which require priority to be given to reducing the demand for transport, and to walking cycling, and public transport.
3.2 Except for the possibility of Kenilworth station (which would have a negligible impact on demand for road use in the peaks) all of the significant infrastructure proposals are for increases in the road network. They have been selected to deal with some of the local congestion created by increase in demand of the various housing site options. They do not provide a coherent transport network for Leamington, Warwick and Kenilworth, rather a continuation of the existing mismatch between traffic and the capacity available to accommodate it.
3.3 Good railway services are already provided at Leamington and Warwick Parkway stations. The level of service at Warwick station is significantly inferior to that of Warwick Parkway, even though it serves a much more substantial population within walking distance. Conversely, almost all access journeys to Warwick Parkway are by car. For journeys to and from work, Birmingham and London are significant destinations and there is some commuting in to Warwick and Leamington which is badly served by Warwick Parkway. The basis of a sustainable infrastructure plan should be to improve train services at all three of these stations, and especially at Warwick station, and to concentrate development close to them, minimising car use. This possibility does not appear to have been considered.
3.4 The conclusion of the modelling is that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, in particular to meet the Air Quality Management Area requirement to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings all require that the legal requirement to restore air quality should be given absolute priority.
3.5 Instead, the infrastructure plan proposes spending almost all of the potential developers' funding contributions on major expansion and 'improvement' of the road network. The lesson was learned decades ago that changes of this kind, increasing capacity on some congested sections, simply increases congestion on adjacent parts of the network, through the traffic that the improvements generate.
3.6 We are disappointed and concerned that the preferred options do almost nothing to allow transport demand to be met more sustainably, rather simply try to accommodate it at the expense of the environment and of existing residents and road users. We consider that the whole emphasis of the plan should be above all on sustainability of transport, not just for its environmental impact but also because the prosperity of residents of the district depends on accessibility to services without having to meet the increasing costs of car use.

4 Locations for Development
4.1 Much of the criticism of the Preferred Options has been directed towards the allocation of particular areas of greenfield land at the fringes of the urban area on which large-scale house building is proposed. These sites represent a major misdirection of development. We consider that, rather than the strategy of the Preferred Options, the pattern of development in the district should be dramatically different.
4.2 The total level of development should be substantially lower, of the order of 250 dwellings per annum, Option 1, which is sufficient to meet local needs and not to encourage in-migration.
4.3 Unbuilt existing permissions themselves provide nearly five years' supply to meet this level of requirement.
4.4 Beyond these absolute priority should be given to brownfield sites, as provided for by the NPPF. The Preferred Options propose only that brownfield sites should be used at the end of the plan period, the effect of which would be to consume greenfield sites rather than to bring forward brownfield sites by increasing their value. Some brownfield sites may provide for small numbers of dwellings, but these should not be dismissed: there are potentially many of them.
4.5 Brownfield development should include the intensification of existing development within the urban areas. We do not rule out 'garden development', which can often be in locations close to existing facilities and employment and easily served sustainably. There are extensive areas of development carried out mainly in the second half of the twentieth century where more intensive use of existing housing and employment land would be entirely feasible - were the market signals to encourage it. The proposals for much more intensive office use of the IBM/Opus 40 site on the north-west edge of Warwick go too far in this direction, but demonstrate that intensifying development on a site well connected to the transport network can be attractive to developers.
4.6 Only as a last resort should greenfield land be allocated. The suggestion that it can produce high-quality environments by applying the principles of the garden cities is spurious. The garden cities were planned around local employment and services (in the era before the car, competing supermarkets, choice of school admissions, and two-income households became the societal norm): that is not how we live now. All of the greenfield sites at the urban fringe would be largely car-dependent. As well as their damaging impact on infrastructure and on existing settlements, they would not produce stable, happy communities of their own. The rapid growth in population of Warwick in the last decade requires a period of much gentler growth while the new communities gel.
4.7 The allocation of land south-east of Warwick between the Banbury Road and Europa Way does exactly what the Preferred Options say that they wish to avoid, merging the built-up areas to their east and west. The northern part, north of Gallows Hill, would make Warwick, Leamington and Whitnash into a continuous, sprawling urban area. The southern part, between Europa Way and the Banbury Road would extend this sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would have a directly damaging effect on Castle Park, Grade 1 registered landscape.
4.8 The Green Belt was established to end the outward sprawl of the major conurbations. Circumstances change and there may be exceptional reasons for declassifying Green Belt land: the expansion of Warwick University may be a virtuous case of this. But it is essential that its edges should not be eaten into by extending urban sprawl, for example at Loes Farm and north of Leamington, in the opposite direction from that which it was originally intended to prevent. Similarly, when the Green Belt was designated land south of Warwick and Leamington was not seen as threatened by sprawl from the conurbation simply because the towns stood in the way. Now, that land requires the same level of protection as the post-war Green Belt gave to the edge of the Birmingham and Coventry built-up areas.
4.9 Instead, the Green Belt has become the guarantor of favourable surroundings for the few residents in and outside villages scattered across it. Given the severe damage to the existing urban areas that would follow from their outward extension, an entirely different approach is required to find acceptable greenfield sites. The possible 'Gateway' development around Coventry Airport is an example of this approach: it must concentrate employment and housing close to good transport links without creating undue pressure on the existing urban areas. Planned new or enlarged settlements outside Warwick, Leamington and Kenilworth, and in some cases outside the district - delivered through cooperation with neighbouring authorities - should also be preferred. The substantial employment at Gaydon is not matched by housing provision in the locality, rather met by car-borne commuting to it. Warwick Parkway station and the nearby A46 provide an opportunity not for an urban extension but for a new settlement outside the existing urban boundary, which would not damage what lies within it. Hatton and Lapworth, with existing railway stations, could also be the focus of much more extensive development than is proposed.

5 Conclusion
5.1 We have concentrated on the three main ways in which the preferred options would both worsen the quality of life of the district's residents and damage the historic environment.
5.2 In the copious supporting documentation, there are many more details of the proposed policies which we cannot support.
5.3 But we have limited our comments to these three main issues to try to persuade the Council that the eventual draft Local Plan must be very different from the Preferred Options now proposed.
5.4 We urge the Council to reconsider its preferences and to recognise its long-term responsibility to both the environment and the quality of life of Warwick district.