Information not substantiated by any clear evidence

The SHMA makes assumptions not based upon surveying the public directly. This contravenes the principle of the Localities Bill. Rather, it relies upon statistical theory and projections. Such models are not based upon the plans and wishes of real people and can be manipluated to fit whatever outcome is required by an authority.

No mention of the current number of unemployed in the district who could take advantage of any new employment in the district without needing new home to be built to house them.

It has been stated that the preferred number of homes to be built was arived at because this was the least number that the Council felt would be acceptable to National government. (Cllr Doody - Old Milverton Meeting July16th). This is not scientific or fair to the residents. The fear is that developers will move in and get what they want. Who will approve these requests? This would be the responsibility of the Warwick Planning committee who can actually say no - as they would to me if I errected an unsuitable extention to my home.

I do find the SHMA hard to follow. I don't see how employment growth is linked to the need for a growth in housing. Also in the SHMA it states that the increased level of unemployment over the past few years has seen an increase in the need for social housing which makes sense, but how is building more social housing going to help build the local economy? Also, the problem with using these models is that the assumptions they make mean that none of the outcomes are likely.

Your trend-based assumption has been questioned at recent public meetings, on the basis that data from recent years shows a downward trend. It seems advisable to be more conservative/realistic in such a difficult economic climate.

Where is the evidence to support the chosen level of employment growth? The Strategic Housing Market Assessment doesn't provide any factual arguments. It merely matches employment growth and new housing figures to an increase in population (including inward migration) that is assumed to be desirable.

There does not seem to be detailed data on where population growth figures are from. The Prime-minister has already said the country will be in recession for the next 10 years.

What about the impact of the Gateway?

General trends for growth etc are used, but the council do not appear to have looked at what is actually happening within their district. New developments such as Portobello Riverside are struggling to find buyers/occupants and future plans for that site have been put on hold due to lack of demand. How can the council be sure that the demand will be there if they allow thousands of new homes to be built?

This is not based on any degree of certainty, or even clear evidence. To destroy green belt land based on these assumptions you must demonstrate the overrriding factors (and facts!) which force this irreversable decision. Once its built on, green belt is lost forever. You must better show precisely where you have got projections from. You have worked out how many homes CAN be built on feasible sites , including greenbelt sites, and then constructed growth projections around that, rather than looking at what is actually required to meet the genuine housing needs of local people.

There is not solid evidence to support the chosen level of employment growth? The Strategic Housing Market Assessment doesn't provide factual arguments. It matches employment growth and new housing figures to an increase in population (including inward migration) that is assumed to be desirable.

The proposed growth in employment does not take into account the changing nature of the automotive industry and its likely impact on the localised economy and hence employment levels

CORRECTION to information in para 5.18
The Preferred Options consultation document incorrectly states that 11,410 potentially suitable housing sites have been identified by the Council in the latest SHLAA (May 2012). The correct figure is, in fact, 13,385 dwellings (refer SHLAA, page 11, Table 2).

We have been advised to write to you re new objections to the Core Strategy Plan. Having studied the documentation we wish to object to the overall plan to build a further 8100 new homes in the Warwick district area and in particular the 2700 planned in the south of Warwick (P04 Distribution for Sites for Housing: Location 2 and 3).

The whole basis for the homes is population growth nationally. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people. Warwick District has already seen much development recently, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands. (PO1 Level of Growth).

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion of which is in South Warwick where the majority of further development is now proposed. (PO1 Level of Growth).

As it stands, we wish to object specifically about the development zone 2 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry (PO3 Broad Location of Growth), including up to 14,000 new jobs at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick. (PO14: Transport).

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic


calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times. (PO14: Transport).

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out onto the double roundabout system.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 1,500-2,000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc. (PO11 Historic environment, PO15 Green Infrastructure).

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road. (PO18 Flooding and Water).

The most disturbing consequence of the proposed development of sites 2 and 3 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remains in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf. (PO12 Climate Change; PO14 Transport).

It was pointed out at the public meeting in 2009 that the areas designated to phase 3 at that time may not be needed for development in the future so why is this area, the worst area for infrastructural needs and more importantly an area of restraint put into the first phase for building?

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the Myton proposed sites 2 and 3. (PO2 Community Infrastructure levy).

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton in whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

The hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run. There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Core Strategy?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. We know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and return the hundreds of dwellings (including Station House with over 200 student flats) in the South Town of Leamington to private affordable starter homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.


The original Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. The paper work shows that the whole of the 8,100 houses still required are to be built in the urban areas. This will take the figures to 95-96% living in urban areas compared to 3-4% in the rural areas as there appears to be no allocation of any of this building to take place in villages.

The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.

Although the Core Strategy points out that the development will be directed towards the south of the urban area to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry it is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

It has been said that Warwick District in 2026 will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands, that have developed and grown in a way which has protected their individual characteristics and identities, ..." If this building work is allowed to go ahead as it stands, it will be far from that.

We also urge Warwick District Council to consider the overwhelming number of objections received from Warwick residents at the last consultation 2-3 years ago.

I note that the IMF has lowered their estimate of Britain`s growth this year from 0.8% to 0.2%. Of course when Cambridge Econometrics provided you with their model the IMF`s prediction for this year was 2.5%. Paul Hunt mentioned that changing any parameter in the statistical package made a big difference to outcomes. I was wondering if you could provide me with the exact difference this factor makes.

Please note my objections to the stated "Preferred Options" for the new Local Plan. How can the options be considered "preferred" when the document has only just gone out for public consultation?

I am extremely concerned that the options include development in the green belt land and that the Council have not demonstrated the "exceptional circumstances" required by national guidelines to permit such development.

The projected growth figures are based on modelling from the past. This has not been, or can ever be, a study in the true scientific sense. In the end it is largely a matter of opinion and herein lies an opportunity to re-work the figures. This is crucial because the whole plan could be based on flawed reasoning and methodology.

The Council appears to be "playing safe" and too mindful of the potential for challenge from those with vested interests. Why, for example, has the Council gone for the higher option when a lower option is available.

Providing new calculations and hence lower projected growth figures are at least as soundly based as the current study then there cannot be any greater fear of rejection at Ministry level. Objections to the preferred options are unlikely to be assuaged by anything less.

In the "Strategic Plan" which was abandoned due to the Government change and the changing requirements of the new Government, your Council were able to find land for such development without incursion into green belt land. Can you demonstrate why, despite the fact that it is deemed that fewer homes would be required in this new Local Plan, you now wish to build nearly 2,000 homes in the green belt and, in addition, provide employment opportunities and, possibly, a new major relief road.

Not enough credence has been placed on the fact that the green belt land required in North Leamington is highly valuable agricultural land and whilst, as I understand it, farm land was never included in the original Green Belt policy it should be recognised that the world has changed considerably and when taking into account climate change and the very real issue of a worldwide food shortage then this land should be protected for agricultural use. In addition to the land required for the proposed development, additional land would also be required for infrastructure thus further eroding this land, and indeed blight the remaining agricultural land.

As Developers have been involved in the drawing up of the new Local Plan their views will obviously be biased. The Council will undoubtedly have considered "trade-offs" with such developers in order to fulfil the requirements of the plan if it is to be approved and there is no doubt that developers will be much more interested in this highly desirable green belt land.

As we are living in a democratic country then democracy should be seen to be working and the local residents should be at the forefront of any decisions relating to this new Local Plan.

In conclusion, these plans are seriously flawed and I strongly object to the desecration of one of England's most beautiful areas. The Government National Policy Planning Framework should put powers to protect the local countryside and green spaces, which are so valuable and fast disappearing, in the hands of the local people and I urge Warwick District Council to listen to local residents who are united in their objection to the Council's "Preferred Options" in this new Local Plan.

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

Thank you for consulting with the Home Builders Federation (HBF) on Warwick's local plan preferred option.

The HBF is the principle representative body of the housebuilding industry in England and Wales and our representations reflect the views of our membership of multinational PLCs, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year including a large proportion of the new affordable housing stock.

We would like to submit the following representations on the draft Local Plan.

Plan period

It would be helpful if the local plan clearly stated the period of time over which it is intended to operate. This should be stated on the front cover and in the first paragraph of the introduction, as well as elsewhere in the document, including the section that addresses the housing need over the plan period. We assume that the plan period proposed is 2011 to 2029 although this is not altogether clear.

Section 5: Preferred Level of Growth

It is encouraging to see the Council taking the correct approach to establishing a housing requirement that is in conformity with the NPPF (hereafter referred to as the Framework). It is the function of the SHMA to assess the full housing needs of the district over the proposed plan period.

We note the three scenarios for setting a future housing requirement. Inevitably, given the uncertainties regarding the economy, relying on any one employment-based scenario as the basis for setting a housing requirement could prove too inflexible in the event that the district (or adjoining districts) experience higher levels of employment growth than projected by a particular scenario. We note that option 1 allows for 600 homes a year, while option 2 allows for 700 homes a year. Option 3 has been discounted because the projected increase in jobs would not be matched by the increase in homes (paragraph 5.19).

We do have some qualms about assuming that there is a direct relationship between new jobs in the district and the demand for new homes. The relationship may not be as strong as the Council thinks, and to some extent, the demand for housing in the district will come from people who work elsewhere, typically in the larger employment centres of Solihull, Coventry, Birmingham etc.

We note that the Council's preferred level of housing growth is for 10,800 homes over the plan (PO1: preferred level of growth). This is inadequate since it is lower than the most recent household projections and the evidence from the most recent SHMA (2012). It also fails to take into account the decisions of adjacent local authorities.

SHMA (2012)

The SHMA indicates that the annual need for affordable housing will be 698 homes per year (paragraph 7.50). This exceeds the proposed option, and, significantly, only addresses the affordable housing need, not the demand for market housing. The report does not appear to have assessed what the market need will be in the district in addition to this affordable need. As such, the SHMA does not satisfy the requirements of the Framework, paragraph 159.

It is unclear how the three modelled housing scenarios relate to the requirement of the Framework for the SHMA to identify the scale of housing needed over the range of tenures, including housing demand (paragraphs 47 and 159). It is unclear whether the figure of 698 affordable homes per year relates to the three scenarios since it exceeds two of them and is almost comparable to the third. The SHMA needs to set out what the quantity of need is for market housing and affordable housing over the plan period.

The Council has not explained in its Preferred Option why it is choosing to discount the evidence of need identified by the SHMA. It would appear that the Council is relying upon the argument that because the SHLAA can only identify land for 11,410 homes (paragraph 5.18). This, however, would be to pursue an capacity-based approach to determining the future housing requirement of the district, rather than using the new plan as an opportunity to review the efficacy of existing policies and constraints and consider the possibility of removing these in order to meet the level of housing need identified in the SHMA. A capacity-based approach would be contrary to the Framework, as the expectation is that the Council will do all it can to meet objectively assessed needs (see paragraphs 14, 17, 47, 179 and 182).

Household projections

The 2008 based household projections indicate an increase of 13,000 households over the period from 64,000 in 2013 to 77,000 in 2028 - a period that is approximately comparable to the proposed plan period of 2011 to 2029. This is a figure that approximates to option 2 - the projected employment rate scenario of 12,888 homes. The Council suggests that this employment projection is likely to be optimistic (paragraph 5.22) owing to the most recent ONS GDP forecasts. Nevertheless, the Council may be surprised, and economic growth, and consequently housing demand, may be stronger than it expects. If this is the case the plan will need to have the capacity to respond to rising demand. This would be in accordance with the Framework which expects local plans to meet objectively assessed needs and have sufficient flexibility to adapt to rapid change.

Furthermore, while we would not dispute the Council's current pessimistic economic prognosis, it is important to remember that housing demand is not solely related to employment. Warwick will continue to experience many more affluent households moving into the district who may work elsewhere and non-economically actives households will continue to consume housing in the more desirable locations. The Council will need to cater for these tastes, but also increase the overall level of supply in order that those on low to medium incomes are not priced out of the district by affluent incomers. Citing the recession as a reason to scale-back plans to accommodate more housing would also be contrary to the Government's new, more positive, planning agenda, as set out in the Ministerial Statement Planning for Growth which sees planning has playing a pivotal role in facilitating greater levels of growth.

Duty to cooperate

There is also the matter of the duty to cooperate to consider and how Warwick's plan will provide for its own unmet needs that cannot be addressed through the plan (paragraph 179 of the Framework) as well as potentially the unmet needs of adjoining councils (paragraph 182). If the council is unable to meet its objectively assessed housing need through its plan (once it has properly identified this, and once it has reviewed existing policy constraints) it will need to plan to ensure that these needs can be met elsewhere without the district. To do so, it will need to plan in concert with adjoining councils.

The draft plan appears to be silent on this question. We note that at least two of Warwick's neighbours - Solihull and Stratford Upon Avon - are advancing plans that will not meet their own 'objectively' assessed housing needs (although there is an issue with the soundness of their own SHMA assessments when judged against the NPPF). Solihull is proposing only 525 homes per year when its SHMA indicates a need for 904 affordable homes. Stratford is proposing a plan requirement of 7,500 homes yet its own housing requirements study recommends between 11 and 12,000 homes over the plan period. Clearly if Solihull and Stratford are not proposing to meet their own requirements then it is very unlikely that they will be willing to accommodate any of Warwick's unmet needs. This suggests that Warwick will need to fully accommodate it own housing requirement since it cannot rely on anyone else to pick up the tab.

The location of new housing

It is unclear why the Council feels it needs to phase the delivery of sites (paragraph 7.20). Surely, if all the sites have been assessed as being suitable for housing, and thus sustainable in terms of the Framework, it should be immaterial when these sites come forward for delivery.

PO5: Affordable housing

I am concerned that the Council is disregarding the evidence of its own viability study in setting an affordable housing target of 40% when the study would appear to indicate that a figure of 35% may be more appropriate. The Council maintains that it can ignore the evidence since it will be flexible in how it applies its policy to ensure viability. This would be contrary to the approach of the Framework which now requires that the cost of affordable housing policy and other policy requirements of the plan are deliverable and to ensure that these do not render developments unviable and thus the plan undeliverable.

This will require the Council to ensure that all its policies applied to be applied to sites, especially those earmarked to contribute in the first five years from the date of adoption of the plan are subject to a reasonable level of policy demands and planning obligations. The onus should not be placed on the developer to demonstrate viability but for the Council to ensure that the cumulative impact of all its policies and demands will ensure that the majority of sites, and especially all those earmarked for the first five years, are viable (see the footnote to paragraph 47 of the NPPF and pages 26 and 27 of the Viability Testing of Local Plans report).

We are also concerned that the study has not modelled-in properly the true costs of development, including those costs to be added to development by the proposed local plan. We note that the study has only factored-in the cost of building to Code 3 and Code 4, but building to the Part L Building Regulations (equivalent to Code 5) will be a requirement from 2016 onwards. This will represent a significant additional cost. The Council should refer to the most recent DCLG report: Cost of Building to the Code for Sustainable Homes: An update cost review, August 2011. This is a significant future but known cost that will impinge upon the viability of sites over the plan period but also in first five years, and must be factored into a new viability assessment (see page 26 of the Viability Testing of Local Plans report).

The viability assessment has also not taken into account the cost of building Lifetimes Homes which is a requirement of policy PO6. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of the requirement of policy PO12 for developments to provide on-site renewable energy plant to provide a 20% reduction in carbon emissions. A revised viability assessment will need to take account of the costs of doing so.

The viability assessment has not accounted for the cost of biodiversity offsetting which is a requirement of policy PO15. A revised viability assessment will need to take account of this.

The viability assessment has not accounted for the cost of flood mitigation measures as stipulated by policy PO18. A revised viability assessment will need to take account of this.

The report uses BCIS costs, but this is based on Gross Internal Area and does not account for external and landscaping costs and local site works (see page 34 of the Viability Testing of Local Plans). A revised viability assessment will need to take account of this.

The figure for site acquisition costs is rather low at 5.75%. This is more likely to be between 6.5 to 7.5%. We would refer the Council to page 35 of the Viability Testing of Local Plans report.

The viability assessment also assumes a total planning gain package (S106 and/or CIL) of £6,650 per unit. This seems modest. I have commented previously on this in my letter to the council dated 20 September 2010 in which I recommended an average of £15k per dwelling is applied as a more realistic figure. Ideally the Council should prepare a CIL Charging Schedule alongside the Local Plan to ensure an integrated viability assessment and avoids the risk of the CIL setting an unrealistically high charge that has not been reflected in the viability assessment for the local plan. Under the current arrangement, if the plan was adopted, then the Council would need to ensure the levy of any CIL introduced after the plan, in combination with S106, exceeded no more than £6,650 per dwelling otherwise the plan would immediately be rendered undeliverable.

We are also unconvinced by the interpretation of the evidence. We do not feel that the council's conclusions are legitimate ones to reach since the evidence does not support the assertion that either 35% or 40% affordable housing is viable. However, this is really a matter of secondary importance compared to the need for the Council to undertake a Framework compliant viability assessment that takes into account the costs of development, local policies and plan requirements.

In responding to the 2011 consultation, the Town Council indicated support for Scenario 1, which was to provide 3750 new homes on greenfield sites and to allocate 60 hectares of employment land.

This view was the preferred single option of those responding to the consultation, despite attempts to demonstrate evidence to the contrary, to allow for the District to put forward a much greater annual housing development figure.

In supporting Scenario 1 the Town Council accepted that the number of homes to be built would increase from 3750, to reflect the development of windfall and brownfield sites, but urged that the District Council should clearly identify the realistic population growth for the District and that an evaluation of housing and employment land needs, should be dictated by that appraisal.

Regrettably that approach has not been adopted by the District Council and the population projection for the Local Plan period is very close to that put forward in the Core Strategy. A figure of some 40,000 additional population, which was deemed to be unrealistic by the District Council.

Indeed, it was the Town Council's understanding that the District welcomed the government's decision, supported by our MP, to abandon the Core Strategy to allow for a Local Plan which would produce a blend of housing that would meet local needs, and especially the provision of social and affordable family homes, and reflect the aspirations and housing needs of local people.

The Local Plan would also need to recognise the existing shortfall in the infrastructure in the District, which had failed to keep pace with the high levels of development and population growth in the last decade, in addition to provision the infrastructure including transport, educational & health needs, roads and sewers to meet proposals within the development in the plan period.

The Town Council had suggested that in particular, to address the reliance on the car, with resultant issues of traffic congestion and pollution, consideration should be given to development in proximity to railway stations at Warwick Parkway, Hatton and Lapworth and given the planned new station, that Kenilworth should also be considered, including sites at Glass House Lane and Crewe Lane.

To avoid the creation of urban sprawl the Town Council also recommended that the greenfield areas between the towns should also be retained and such action would also retain the historic and natural boundaries between towns, thus preserving and distinguishing identities of the Districts communities.

Such a policy would meet local need, and equally importantly, avoid a disproportionate impact, on particular residents and communities. The policy would also serve to reduce the levels of infrastructure required to support large scale development, and avoid coalescence and the creation of urban sprawl.

The proposals now put forward by the District Council are not based upon a realistic population growth, and considerably exceed the population estimate forecasts put forward by Warwickshire County Council. Rather the figures are assumptions, adopted by the District Council to justify a level of housing development, which are as great as those put forward by the 'Core Strategy'. The proposed population figures, resulting from the assumptions, are dependent upon high levels of inward migration, based upon previous peaks, without any qualified analysis, and which at the same time accept that the past level of high migration, reflected and were dependent, upon the high number of houses being built in the District.

The sites chosen for development in Warwick were substantially rejected within the Core Strategy consultation and it is both disappointing and surprising that the District Council should have so little regard for community opinion that almost 37% of all development proposed in the District, during the plan period, should be allocated to Warwick and also on those sites rejected in the Core Strategy consultation. Such development, it is accepted will generate high levels of infrastructural needs, in respect of transport, including a new river bridge, education and health needs and roads & sewers. The development which will of itself further increase traffic congestion, creating even higher levels of nitrogen dioxide in the Town Centre, which currently exceed the levels approved in the Air Quality Regulation 2008. Thus, the Local Plan Option will increase traffic and create even higher levels of NO2 emissions, and in doing so will be contrary government policy with regard to air pollution.

The Town Council therefore seek to object to the Local Plan proposals on the grounds that:

1) The projected housing development over the planned period are based upon
assumptions of population growth, which are not supported by population estimates and which reflect the Core Strategy population figures, which the District Council have previously considered unrealistic.

2) The development sites are not spread throughout the District in order to meet local need, and concentrate development on sites previously rejected by local communities and very much reflect developer preference.

3) The Plan does not accept that the quality of life and the environment should be guiding factors of the Local Plan and not levels of growth which cannot be absorbed by communities.

4) The Plan does not allocate development to sites which have local support or distribute development proportionally throughout the District to recognise local need, thereby avoiding any single community or locality being subject to the disproportionate impact of development.

5) The proposals do not clearly identify infrastructure needed to support proposed development or avoid detrimental impact of large scale development
upon existing communities and areas of the District, and fail to recognise the existing infrastructure problems.

6) The proposals should reduce the development to levels which can be justified by local population increase and local needs, rather than seeking to maximise development to generate income levels and developer aspirations.

7) The Local Plan proposals do not seek to promote the development of brownfield sites to meet local need for social and affordable housing, but seeks to promote development to generate higher levels of inward migration.

8) The recommendations place a disproportionate level of development in Warwick, whilst not exploring sites elsewhere in the District.

9) The proposals ignore how properties yet to be built, within existing planning permissions, will contribute to housing provision in the period of the Local Plan.

Scanned letter

See Attachments

INTRODUCTION
As Mayor of Warwick, I am supposed to be apolitical during my year of office; however, I am assured by the Town Clerk that I am entitled to submit my objections, on behalf of the people of Warwick.
AIR QUALITY
I think the people of Warwick worry about the air quality in its town centre. There are laws about Air Quality in town centres. I have already been on the Environmental Health dept to enquire whether the fumes in High St/Jury St are lessening because of the traffic calming and I am assured that it is too early to monitor yet. Therefore, these plans are unacceptable to put an extra 27% of traffic on to our crowded streets.
OUR OBJECTIONS DISMISSED
The dismissal by WDC of all the multiple objections which were submitted when the recent Core Strategy was in public consultation was a poorly judged decision. All areas of Warwick District are dismayed at this and having to re-submit our objections.
FUTURE GROWTH FORECAST
Your population numbers are flawed and are, therefore, incorrect. Your numbers are highly inflated at 40,000, whereas in reality it is forecast at only 13,000 in Warwick Observatory's research.
INFRASTRUCTURE
Warwick residents feel you are forcing this huge number of future dwellings on our fragile infrastructure. There has already been massive development in Warwick. When the 1994 plans for Chase Meadow were passed it was for 1,100 dwellings but 1,600 are built or have planning permission passed for them. £1M Section 106 money was set aside for traffic calming in Warwick Town Centre from this development. Ditto when Warwick Gates was on the drawing board I questioned a Severn-Trent Water official at a presentation as to whether Warwick's Sewage Works and pumping station could cope with so many more people in these houses, using dishwashers, baths, showers and washing machines. I was assured there was sufficient capacity in both the sewage works and the water pumping station. So Warwick Gates was built. Immediately, it became apparent the water pumping was inadequate and an extra pump unit had to be built. Likewise with electricity National Grid have inadequate powers supplies and a new sub-station had to be built. These two plants were built AFTER Warwick Gates was built. Therefore I argue your infrastructure plan is flawed because infrastructure must be BUILT IN ADVANCE.
There are plans for both a Primary School and Secondary School in or near Warwick Gates. Neither have been built so where are they?
Electricity
We have the news casting this week of India's infrastructure failure this week with 6M people without electricity due to power failure. This is because of the increasingly wealthy middle-class in India demanding air-conditioning which has defeated the ancient power plants. A similar problem will occur in the 2020s in the UK unless more power stations are designed, built and come into use. This is relevant to Warwick District with its pylons and sub-stations.
Rural
Villages to the west of Warwick have marvellous infrastructure with a main rail line (Chiltern Line) to get to and fro work in big cities. Warwick Parkway station car park increases in size every 2 years and is full every weekday. The demand for quick access to major centres of population, Birmingham & London is unquenchable. Why cannot these 10,800 houses be built 100 in each and every village in Warwickshire? Then the shop, school and bus service would be viable.
TRAFFIC
No way can Warwick's fragile infrastructure of roads and bridges cope with 27% more traffic as is forecast in your plan.
I was instrumental in stopping a new traffic scheme in Warwick Town Centre in 2004 when we defeated the then Labour WCC's plans on 8/11/2004 with the promise of a new bus station (built on time and under budget), a cycle track to the Tech Park and VMS. The Traffic Forum (£30,000 set aside for it - about £10,000 spent to date) rumbles on with constant consultation and causes irritation to the commercial section, who sometimes refuse to get involved, then grumble (as they are now) with the remedial work being done on High St/Jury St. Warwick's narrow streets (some under 7.6 metres the national standard for a two-way road) and complicated junctions which cannot cope with 27% more traffic.
One hot day in June, when the bricked humps were being built, Warwick ground to a halt for 7 hours, because of a car/truck accident when a driver pulled out of Westgate car park - didn't realise it was a one-way road (as most are in the town centre) and a truck had right of way and the car driver piled into it. It took that long for a tow truck/emergency services to arrive. Children arrived at school 2 hours late with wet knickers/shorts, medical staff arrived hours late to run clinics, appointments for out-patients and impatient people arriving at WCC (whom I witnessed) really angry with the traffic hold up. The town literally ground to a halt. One shop only sold 6 postcards. With the extra 27% of traffic you forecast Warwick will become moribund with no commercial activity.
BRIDGES
The Earl of Warwick built the bridge across the Avon in 1797 and WCC renewed its pavement, the utility supplies which are trunked under the pavements in July 1998. It is a wide (yes widened) two way bridge with two narrow York stone pavements. It is widely used by tourists to photo Warwick Castle. Tourists try to cross on the apex of the bridge. A man in a TR3 killed a pedestrian doing that in the 1980s. The car was low and the tourist didn't see it.
BRIDGES/JUNCTIONS/SAINSBURYS
Every day (except Xmas Day and Easter Day though I have noticed that law being infringed in the last three years) there are 6 HGV movements delivering goods to Sainsbury's on Saltisford. Planning permission was passed for that store before the 7.5 tonne bylaw came in. The rail bridge being 13 ft 5 in (what is that in metres?) precludes the HGV truck coming off the by-pass and entering Birmingham Rd direct into the loading bay of Sainsbury's.
So the route has to be from the Hams Hall depot, A46 by-pass, exit Warwick Stanks Island, over a flattened Canal bridge, left at Lone Tree Island, right into Upper Cape, over another Canal bridge, up a congested Cape Road, over some speed humps (narrow ones) over a narrow 19C rail bridge with very narrow pavements, around Northgate, around another island down North Rock, around another roundabout and into the loading bay. 20 minutes later it returns via the same route in reverse.
I have investigated the cost of heightening the offending bridge (£5M) or lowering the land under the bridge which would have the effect of heightening the bridge. That is impossible because of a culverted stream. With the projection of flooding and this summer's monsoon it impossible to widen and deepen that culvert because water does not flow uphill.
The actual gate at Northgate vanished in the 14C because of "press of traffic" (according to the archives) and there are no drawings of it. Therefore, the foot, horse, animal traffic of those days made it a complicated junction at the top of hill for the past 8 centuries. The HGVs, on occasion, demolish the 1698 sundial and it is replaced by their insurance.
This is just one instance of the congestion of Warwick, already, with its weak links which are the bridges. It only needs one of these to fail, Network Rail to replace a bridge or the new Canal charity is perhaps unable to replace a canal bridge and there are no supplies at Sainsbury's Saltiford.
HEALTH FACILITIES
Warwick Hospital is built on the former 19C workhouse site and is totally inadequate for the needs of the four towns in Warwick District and the rural population. It is so busy. This is the 21stC and most out of Warwick visitors, out-patients, staff, cleaners etc drive. The parking is totally inadequate. I deal with angry residents who resent shift workers parking on their residential streets. Now the Rehabilitation Hospital is going to charge for parking so the same thing will happen in Warwick South.
I spent March to June 2011 visiting my dieing husband in Warwick Hospital. The care and attention he received was magnificent, however, I had time to observe the staff, which are overworked, overstressed and thanks to Harold Shipman light on the morphine, prolonging the deaths of the elderly. My husband had prostate cancer in the skeleton and there was no hope of recovery. With an increasingly elderly population this problem is going to get worst (it is masqueraded as "bed blocking") and it going to escalate in this litigious society.
There are no signs when exiting Lakin Rd car park to Warwick Town Centre (right) and M40 M42 Birmingham and the North (left). I am actively trying to get this sign put in place. Drivers are stressed visiting a hospital for a blood test, an X-ray, visiting the sick, collecting samples, prescriptions etc. When the driver has fathomed out how to exit the car park then the thought comes: Did I drive left or right into this car park? There are no signs at all. Mr Glen Burley (NHS head of the hospital) says it would cost WCC £5000 to put up suitable signs.
The answer is to demolish some of the 19C streets around and rebuild the 19C part of the hospital with a multi-storey car park for staff. Plans have been passed for another private hospital on Tournament Fields, but due to the Banking crisis no funds are forthcoming to build it. Along with the Nuffield Hospital (who has had an MRI scanner delivered this week) this would have relieved the pressure on Warwick Hospital out-patients dept. The initiative by WDC, Pete Cuts and St John's Ambulance Service to curtail the visits by the drunks bleeding from "Payday" incidents in Leamington's pubs has helped tremendously.
CONCLUSION
No way can these plans be accepted. There are far too many in your forecast of future population for Warwick and its fragile infrastructure will break down. Your population forecasts are incorrect. There must be no pressure to build on farmland food is needed, only brown field sites are acceptable. 4 1-bed apartments are to be built on Vine Lane, the Vine pub will be converted into 2 flats, why cannot these (only 6) dwellings be counted within the number required for the future? The residents of Woodloes are angry about the 180 houses along by the Saxon Mill, North Leamington is angry about the proposal to build in their green belt to the north of the allotments.
Ford Foundry site has Morrison's supermarket going up with a large truck and car park. The rest of that huge brownfield site should be housing, some 2/300 could be built there. Behind Leamington Spa rail station there is a temporary car park, another 80 could be accommodated there. Down Cape Rd, Warwick, planning permission could be rescinded on the Benford site for another 25 (P/P was refused) so that would be another 400 off the total. I'm sure other Cllrs could think of other brownfield sites which could be made available.
Finally, Warwick suffers from empty buildings (mostly owned by WCC) 2-22 Northgate St is currently for sale for £3M. Why does not a developer not refurbish those huge houses into two dwellings each, making 20 more. Riverside House would convert into magnificent duplexes.
Warwick's fragile infrastructure will break down if you approve this plan, please do not.