Introduction

The Warwickshire Branch of the Campaign to Protect Rural England (CPRE) is a charity registered No 1092486 with over 700 members in Warwickshire. CPRE is very concerned about many aspects of the New Local Plan Preferred Options agreed by the Council on 21st May 2012 and now published for consultation.

Firstly we give our response to the main Preferred Options. We then examine key issues on the Vision, projected growth, population growth assumptions, the Green Belt, and the proposals for employment.


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

We strongly oppose the level of growth of 555 houses/year that PO1 proposes. The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and much of this is by windfall development within the urban areas.

The proposals to impose 100 houses on each of five villages would damage their rural character and unbalance their structure.


PO3 Broad Location of Growth

The proposal is 'growth across the District' including on Green Belt, and in villages. No direction of growth or focus on particular broad locations is proposed. This is contrary to the policy of previous Structure and Local Plans. Those plans protected Green Belt and identifed key locations while ensuring that urban land was re-used, and villages were only asked to accept limited new housing.

No clear reason for the change from past Local Plans has been offered. As those have been successful, the policies and patterns of development that they provided for should be maintained in the new Local Plan.
The extent of windfall development and use of brownfield land in Warwick and Leamington has been high for many years. There is no reason to depart from the practice of encouraging these forms of development.


PO4 Distribution of Sites for Housing

PO4 proposes a large number of greenfield housing sites which are currently Green Belt or greenfield. Most of these would not have been considered at all acceptable in past Local Plans, and we strong oppose the following sites, because they would require release of land from the Green Belt or would affect historic landscapes (such as the approach to Warwick around the east side of the Castle Park).

Sites:

3. South of Gallows Hill, west of Europa Way : harms setting of Castle Park and approach to Warwick from the south
4. West of A452 Kenilworth Road, between Northumberland Road and Old Milverton Lane - Green Belt, and essential part of the open countryside separating Kenilworth and Leamington
5. Blackdown - open countryside, which if developed reduces the separation between Kenilworth and Leamington by a quarter
8. Red House Farm, Lillington - Green Belt, visible land facing southeast
9. Loes Farm, Warwick - extends Woodloes Estate into Green Belt, and undermines tight planning control on north side of Warwick
13. 100 houses in each of 5 villages - this is an arbitrary imposition. Individual villages should be able to determine how much development they wish to accept.
14. 350 houses in smaller villages - there is no basis for such a figure, and most smaller villages should only accept 5-10 dwellings over 15 years if their rural character is to be ensured.

We also believe that Site 6 South of Sydenham, is too large an allocation and only a smaller development should be considered; that Site 2, Myton / West of Europa Way, is high-grade farmland protected from development under past Local Plans for its agricultural value, and its loss would be the end of the remaining green wedge left when employment land was developed east of Europa Way; and the scale of Green Belt release for Site 7, Kenilworth (Thickthorn) needs to be reduced. If these sites are released, this should be only after brownfield sites have been developed and windfall potential within the urban areas has been assessed.


PO5 Affordable Housing

CPRE supports the policy of 40% affordable housing which is carried forward from the 2007 Local Plan. It is strongly opposed to the part of the policy which would allow private sector developments in villages to fund affordable housing. If affordable (rented) housing is permitted in villages, this must be only following a sound assessment of local need, and should not bring with it housing for sale simply to provide funds for the affordable houses.


PO7 Gypsies and Travellers

CPRE supports finding an official site for gypsies. The numbers to be accommodated need reassessment against new policies: some gypsies have property elsewhere, and do not need to live in caravans. CPRE would propose that the gyspy site at Siskin Drive, just inside Coventry, be enlarged or re-sited in the Middlemarch employment area, so that part at least meets the needs of Warwick District.

PO10 Economy

CPRE opposes the provision of employment land north of Leamington on Green Belt. There is no need for major new employment land identification in the District. Surplus employment land and buildings in the towns come on the market continuously and can generally be re-used without any need to allocatec new greenfield land.

There is no shortage of employment land in Warwick District. In a recession, with economic difficulties meaning that land for employment becomes surplus, loss of existing sites to housing is more of a problem than any lack of new greenfield sites.

North of Leamington, proposed in PO8, would be an unsustainable location for employment development. It would be outside the town centres where the focus of employment is supposed to be; it would generate much car traffic; and the main transport routes through the District are south not northof Leamington.

The proposal for the Coventry Gateway around Coventry Airport has no economic justification: it would not be relevant as an employment site for most who live in Warwick and Leamington, is not easy to reach from Warwick District's urban areas, and would compete with the Ansty and Ryton employment locations nearby which are in Rugby District.

Established and new small businesses rarely need any planning permissions for their commercial activities.

Our conclusion is that no development of new employment land in the Green Belt is justified.


PO11 The Historic Environment

The existing (2007) Local Plan contains clear policies to guide conservation and decisions on developments that affect a Conservation Areas. This set of Policies should be generally carried forward, without any simplication (which can cause ambiguity).

A Policy to make the lengths of the Grand Union Canal and Stratford Canal in Warwick District into Conservation Areas is needed. Other Districts with extensive lengths of canal have created linear conservation areas.


PO14 Transport

The proposed new road links and road widenings in the Preferred Options would be harmful to the Green Belt and tend to encourage more car traffic. That would create unsustainable patterns of movement and increased car depenency. By contrast the proposals for the bus network are thin. They focus on Park & Ride provision which is not of importance to residents of the towns.


PO16 Green Belt

The Preferred Options would require major removal of land from the Green Belt for urban development. It would also require the removal of 'washed-over' status of some smaller villages which are currently covered by Green Belt designation. The very special circumstances required to be demonstrated if Green Belt land is to be released for building have not been shown to be justified.




The Key Issues


1. Vision and Growth

1.1 The key aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This reflects a current focus in national government thinking and speeches by Ministers. It fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years.

1.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

1.3 CPRE believes that there should be a much more careful balance between development and the environment than the Preferred Options would achieve. The proposed scale of development would risk being unsustainable and contrary to the NPPF policy that supports sustainable development.

1.4 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

1.5 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.


2. Sustainability

2.1 The National Planning Policy Framework (NPPF) at para 49 sets out the principles of sustainable development. The NPPF says that Sustainability has three aspects, environmental, economic and social. The Preferred Options pay little attention to the environmental aspects of sustainability.

2.2 The term 'sustainable' is used about 120 times in the full Preferred Options report, but this is mostly in relation to economic aspects of sustainability.

2.3 We do not believe that large-scale destruction of open countryside is sustainable development - it is unsustainable. Once lost it will never become available for future generations.

2.4 We acknowledge that a few mentions of sustainability in the proposal do relate to the social aspects such as providing sufficient of the right kinds of housing and facilities.


3. The Projected Housing Requirement

3.1 CPRE is strongly opposed to the proposed level of housebuilding advocated in the Preferred Options.

3.2 The justification for this level of housebuilding is weak, for the following reasons.


1. The ONS projections for Warwick District are arbitrary and probably overstated. They do not yet take account of likely reductions in net migration to the UK or the potential effects of the recession. They assume in-migration at recent levels although this is now reducing rapidly.

2. Projections for individual local authorities are notoriously unreliable because they do not take into account the implications of planning and other policies. Already the 2011 Census (issued in summer 2012) shows that the growth of population in the last decade given at para 4.2 of the preferred Options is nearly 50% too high. Population growth 2001-2011 was not 14,800. It was 10,000 from 2001 to 2011 (126,000 to 136,000).

3. House building rates in Warwick have been very low over the past five years and are likely to pick up only slowly. The rate of housebuilding proposed by Warwick DC in the Preferred Options is well above the rate achieved in the last 10 years and on current economic trends is unachievable.

4. The work by G L Hearn / JGC at Appendix 2 of the SHLAA does not lead clearly to any particular level of population, household or employment growth. Their projections are highly volatile, depending on a range of key assumptions.

5. From statements in the Preferred Options, and made at public meetings during consultation, it seems that Warwick District Council has decided to seek a relatively high level of housing development in the mistaken belief that it will help to boost economic growth. There is no overriding need for major new employment development. If population grows rapidly, it is more likely to result in a change in the balance of commuting, with more Warwick residents working outside the district.

6. The consultants' work on translating population growth into household growth is inadequate. It assumes too high a vacancy rate for new housing stock and fails to consider sharing and institutional population.

3.3 We have other major concerns about the population projections.

3.4 In its commentary on the projections, the Office for National Statistics says - 'Projections are not forecasts and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. They provide an indication of the impact that changes in demographic patterns might have on the size and age structure of the population in the future.' Therefore the projections should not be taken literally.

3.5 There are particular questions over two of the assumptions made in the national projections:
* Net international migration, which makes up roughly half the projected population increase, is likely to reduce in future, reflecting a tightening of government policy on this issue. This change will not yet have been picked up by the projections;
* Although there is little sign of this yet, birth rates may fall as a result of the recession and the slow recovery from it.

3.6 The Preferred Options forecast that Warwick District's population will grow by 21,600 between 2010 and 2026, and from this a requirement for about 9,390 extra dwellings is produced. (The average household size would stay at 2.3 persons.) This produces a rate of building of 587 dwellings per annum, not achieved in any past year for some decades

3.7 The suggested rate of building, at 550 dwellings per year, has not been achieved in the District for some decades, if ever. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The Government predicts only a slow recovery from the recession, with a gradual increase in house building rates. Therefore it could be many years before the Preferred Option's desired rate of house building can be achieved, and the past record suggests that it will not be achieved.

3.8 In an earlier consultation in September 2009 Warwick District Council asked for public views on three scenarios for numbers of houses. These were 200 per year, 500 per year and 800 per year. 51% of the public chose 200 per year. Despite this result the Preferred Options propose that over 500 houses be built annually.

3.9 The net in-migration element in the forecast housing requirement is large - 57% of the population growth forecast by the Council's consultants (in the SHMA) would be the result of net in-migration. However in-migration has fallen fast in the last 2 years and there is no clear reason why it should be provided for. If more houses are built, given the location of the District on the M40 and Chiltern Railway route, more inward migration will take place. There is not an objective need to provide for or seek inward migration.

3.10 We consider that the Preferred Options housing figures should be reduced substantially; the 2011 Census results and latest migration data be taken into account, and an objective need recalculated instead of assuming that in-migration should be planned for.


4. Proposed Locations for Housing


4.1 CPRE believes that a number of the major new housing locations proposed would be harmful. See response to PO4, Distribution of sites for housing.

4.2 The NPPF at para 109 states that "the planning system should contribute to and enhance the natural and local environment". This militates against development in the countryside and favours protection of landscapes, animal and plant life, public footpaths and Scenic Views. Further research would identify valued landscapes, geological conservation sites, soils ecosystems, impacts on biodiversity and ecological networks.

4.3 NPPF para 112 states that Local Planning Authorities should take into account the economic and other benefits of the best and most versatile agricultural land and should seek to use areas of poorer quality land in preference to that of a higher quality. Much of the land around Leamington is 'best and most versatile' agricultural land. This places a presumption against its loss to development.

4.4 Clearly any use of green land will require destruction of hedges, ponds and other habitats of animals and plants. It is likely to destroy public footpaths. It will certainly affect the views of countryside which are currently available to visitors, walkers and residents at the edge of the existing built-up area.

4.5 The area of the district which is not in the Green Belt is generally to the south and east of the built up area. While there are constraints here, and location (3) is wholly unacceptable, there is scope for some development at the locations previously considered in the 2009 Core Strategy.

4.6 Three pipelines run to the south-east of Offchurch, Radford Semele and Bishops Tachbrook, but not through the area of land adjacent to Europa Way or between Whitnash and Bistops Tachbrook, so do not appear to be a significant constraint.

4.7 There is some scope for more housing at Hatton Park which has been a successful development that maintains a 'washed-over' Green Belt status.


5. The Green Belt.


5.1 In para 79 of the NPPF, it is stated that "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."

5.2 Para 80 sets out five purposes of Green Belt. The West Midlands Green Belt to the north of Leamington and Warwick and the south of Kenilworth meets four of the five purposes:
* It prevents urban sprawl
* It prevents towns merging
* It is assisting in safeguarding the countryside from encroachment
* It assists urban regeneration by encouraging recycling of derelict and other urban land.

5.3 NPPF para 83 states that confirmed Green Belt boundaries should only be altered in exceptional circumstances. We are far from convinced by the arguments that the boundaries should be altered. The sole reason appears to be to spread the pain of development on greenfield sites across the District. This is not a planning justification which satisfies the need for exceptional circumstances.

5.4 NPPF 84 makes it clear that sustainable development to be channelled towards urban areas inside the Green Belt boundary and towards towns and villages inset within the Green Belt boundary or towards locations beyond the outer Green Belt boundary.

5.5 As in other parts of the report we see clear conflict with the Localism agenda of the coalition government. The Localism Act gives communities, including neighbourhoods, towns and villages, a procedure for determining for themselves what development should take place and where it should be located.

5.6 NPPF para 87 states "as with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".

5.7 NPPF para 88 states that "local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

5.8 Taking extensive Green Belt land out of the Green Belt and proposing it for housing is the opposite of a sustainable development policy.



6. Employment Land Proposals

6.1 CPRE supports a low-carbon economy; but it has a very long timescale, and must be developed but we are concerned that the proposed Preferred Options will not enable this. In particular, we question the proposal to "distribute development across the district". Established towns (and nearby cities) offer critical mass where homes and jobs can be developed in a balanced way supported by infrastructure such as public transport.

6.2 Substantial development in the countryside, such as the proposed major employment at the Coventry Gateway site, would increase the need to travel with the vast majority by private car. The Preferred Options recognise the importance of the need to reduce travel (e.g. in section 8.30) but do not seem to apply this principle consistently.

6.3 Major development in the countryside would make the principle of "developing an effective and sustainable transport package" very difficult to achieve and undermine the agreed principle of regeneration of urban areas. We support the preferred option (in PO3) to concentrate growth within urban areas but we are concerned about significant development in villages and rural areas.

6.4 We recognise the need to provide land for employment to meet proven local needs but are concerned about the proposed principle to provide land to "encourage the creation of jobs". Sustainable jobs are critically dependent on factors such as people, skills and finance, not just buildings or land. Increasingly, attracting skilled people and knowledge-based businesses to an area is dependent on the quality of the environment: somewhere people want to live as well as work. The social and environmental strands recognised in the NPPF are as important as the economic strand.

6.5 It is essential to keep employment balanced with housing: over-statement of housing numbers leads to over-statement of the need for employment land. We object to the over-allocation of housing (proposed in Section 7.22) to support the proposed Coventry Gateway, which has not been justified.

6.6 We note (from sections 8.21 and 8.22) that the Preferred Options propose some 66 hectares of employment land in the period from 2011 to 2026 and that 43 hectares have already been identified. For the remaining 23 hectares, we agree with the urban-brownfield-first priority and agree with the approach of locating employment with housing where new housing developments are really justified.

6.7 Compared to the remainder of 23 hectares of employment land over 15 years, the Coventry Gateway proposal amounts to over 97 hectares in one rural location in the early years of the strategy period. Such a volume of over-allocation would be indefensible and should not be considered as part of a balanced plan.

There is already a regional investment site at Ansty Park. It has fully developed infrastructure and yet currently vast tracts of empty land off blocked-up site roads. Empty buses frequently serve the mostly-empty site; it has excellent access to major highways but too few occupiers. The duty for local planning authorities to cooperate should mean that this site is supported by WDC rather than undermined with a competitive development in the Green Belt just 8km away.

6.9 Recent planning studies and processes have concluded that there is no need for more employment land in Green Belt. The Inspector's Report for the Examination in Public of the Coventry City Council Core Strategy (April 2010) concluded "There is no current need to allocate any additional employment land outside the city boundary, over and above that available at Ryton, to meet the overall economic objectives of the CS".

6.10 The Warwick District Employment Land Review of April 2009 concluded that "there is an oversupply of land suitable for the development of general industry/distribution that is already committed/allocated in the current Local Plan to accommodate demand in these sectors". The Addendum dated January 2011 noted a continuing decline in demand for B2 and B8 floorspace. While the 2009 Employment Land Review did identify a potential deficit of land suitable for office development, it identified "the area around south west Warwick and Leamington as most attractive both in market and planning terms". The 2011 Addendum noted decreased demand overall but also decreased completions, recommending further study. The earlier preferred development directions remained unchanged.

6.11 These plans and studies confirm there is no need for development of Green Belt land for employment. The plan numbers are backed up by experience on the ground, where for example the ex-Peugeot site at Ryton-on-Dunsmore has been vacant for 6 years and Ansty Park has struggled to find occupiers. We recognise that the Ryton site is in Rugby Borough but paragraphs 178 to 181 of the NPPF make it clear that local authorities must cooperate when drawing up Local Plans. The NPPF confirms that the Government attaches great importance to Green Belts, supports 'brownfield first' and reasserts that inappropriate development should not be approved except in very special circumstances. Need for development has not been proven and there is no evidence of valid special circumstances that would justify development in the Green Belt.

6.12 The Preferred Options consultation document picks up the claim that the Gateway "has the potential to provide in the region of 14,000 jobs" (section 8.33) even though this number is not justified and falls partly within Coventry. There are many examples of large, speculative developments where job creation assumptions are inflated and over-optimistic. New developments can remain half-finished for many years because demand proves to be far lower than anticipated. That would be a particularly damaging outcome for a large development with a devastating impact on the Green Belt to the south of Coventry. The number of jobs 'created', put forward by developers, cannot be relied upon as a measure of sustained economic benefit.

6.13 There are better ways of achieving more and better-quality employment. This is to put the emphasis on technological advance and the proposed "Emphasis on infrastructure": investment in communications technologies for rural areas in order to support small businesses and home offices. Broadband for rural communities continues to fall behind urban areas so rural businesses are increasingly uncompetitive. A well-wired rural community would help achieve both the low-carbon economy and the rural economy objectives. It would also make the district a better place to live and work for knowledge workers.

6.14 Finally, all the evidence indicates that in Warwick District no new development of employment land in the Green Belt is justified.

Thank you for providing English Heritage with the opportunity to further comment on this evolving strategic plan for the District. This correspondence will regrettably reiterate certain points made in previous letters dated 9 April 2010 and 5 July 2011; both are therefore attached for your information.
As the government's adviser for the historic environment, English Heritage broadly welcomes the positive strategy set out in section 11, and in particular Objectives 7 and 14 of the Plan.
I note a recognition in the Plan of the pressure for new development threatens the "highquality
built and natural environments in the district, particularly historic areas"1 but however goes on to reassure that 10,800 new homes (to 2029) will be founded on "best evidence"2 and located in the most suitable locations3 to help ensure the historic environment is then protected and enhanced4.
The National Planning Policy Framework (NPPF) provides the context and justification for doing so, requiring Local Plans to be prepared with the objective of contributing to the achievement of sustainable development in accordance with the principles and policies for the historic environment.5
The following comments on a number of the proposed allocations unfortunately highlight an inconsistency with the above:
1 WLP PO Paragraph 4.8 point 6
2 WLP PO Paragraph 5.1
3 WLP PO Paragraph 7.6 "In addressing the important housing issues, the Local Plan will aim to...provide well-designed new developments in the most suitable location".
4 WLP PO Paragraph 4.6
"To protect and maintain the character of the District, the Local Plan will have to balance the growth of the District with the protection and enhancement of these assets".
5 NPPF Paragraph 151
2
Site D Land south of Gallows Hill, Warwick
Key assets affected - Warwick Castle Park Grade I Registered Park and Garden; Warwick
Castle Grade I Listed Building; Warwick Conservation Area
In comparison to all the nine sites assessed in the Landscape Character Assessment for
Land South of Warwick (Richard Morrish Associates, 2009 - Referred to herein as the LCA Report), the site to the south of Gallows Hill is described as being the area of highest relative value to the setting of Warwick. It is the only site that is considered to be unacceptable in principle.
"This is generally an area of well maintained agricultural land that is important to the setting of Castle Park and prominent in approaches to Warwick. We feel it should be safeguarded from development". Paragraph 5.4 LCA Report
"Warwick and Leamington Spa have highly-valued historic cores and Warwick Castle and the associated Castle Park have national heritage significance. Protecting the setting of these features must be considered a principal goal of future development planning in the locality".
Paragraph 5.1 LCA Report
It is needless to say any proposal which harms heritage assets of such national significance to such a degree is contrary to the NPPF6 and the principles of sustainable development.
The harm is not outweighed by the public benefit associated with this housing development.
It should be noted that the LCA Report does not refer to either the Historic Environment Record or the Warwick CA Appraisal; and it preceded the publication of the NPPF (March 2012);The Setting of Heritage Assets - English Heritage Guidance (October 2010); The Warwickshire Historic Landscape Characterisation (HLC) Report (WCC 2011)7; and the Conservation Plan for the park. If applied these are likely to reaffirm the sensitivity of the site and the unsuitability of the allocation.
Site WL5a Loes Farm, Warwick (Guy's Cliffe)
The draft local plan fails to have adequately considered the impact on designated and undesignated heritage assets to determine the suitability of the allocation. The proposal would appear likely to cause substantial harm to undesignated heritage assets of significant value, and harm to the setting of designated assets that contribute to that assets significance. This would be contrary to the NPPF and the great weight that should be afforded the conservation of heritage assets.
I refer to my letter dated 10 April 2010.
"You should ensure that thorough evidence is applied to determine whether the proposal would adversely affect the significance of the designated historic landscape and its setting including key views in and out. The direct and indirect impacts of major new development on the individual components that determine the relative value of Guy's Cliffe in total should be understood.
English Heritage considers that the well preserved areas of ridge and furrow should certainly be regarded as of national importance and preserved as a consequence, see:-
http://www.english-heritage.org.uk/upload/pdf/turning_plough.pdf?1267377944 "
The NPPF is clear that a draft local plan may be considered unsound if there has been no proper assessment of the significance of heritage assets in the area, including their settings,
6 NPPF paragraph 132
7 NPPF paragraph 170
3
and of the potential for finding new sites of archaeological or historic interest8, or, there has been no proper assessment to identify land where development would be inappropriate because of its historic significance.9
The Joint Green Belt Review recommends that to determine site suitability "finer grained, more detailed analysis" should be undertaken including the consideration of "Archaeological Constraints; Character, Setting; and Historic Landscape Character Analysis"10. This appears not to have been undertaken.
Site K5 south east Kenilworth
Previous correspondence highlighted the need to consider the evident significance of the adjacent Stoneleigh Abbey and designated Glasshouse Roman settlement, and the potential for further archaeology. Has this evidence been addressed?
Any future development would certainly need to protect the scheduled archaeology and its setting and that of the Grade II* registered Stoneleigh Abbey Park.
Coventry and Warwickshire Gateway - Baginton
The scale and form of any future development here is currently unclear. However it should be noted that the area includes designated and undesignated heritage assets of great importance. In accordance with the national policy expectations referred to above, a specific historic environment assessment must be undertaken to fully understand the landscape's special historic interest, the locations of particular historic significance and sensitivity. This can in turn inform the areas capacity, where development may best take place and what form
it might take.
Section 11. The Historic Environment
One of the twelve principal objectives for planning in the NPPF is the conservation of heritage assets for the quality of life they bring to this and future generations11.
Conservation means maintaining what is important about a place and improving it where this is desirable. This is not a passive exercise. Consequently we welcome the proactive approach you intend to take.
To compliment these measures might I suggest the Plan also address and target specific environmental improvements; the assets within the area on the heritage at risk register and the opportunity afforded by CIL/S106 agreements.
I note paragraph 5.1 of the LCR Report. "In addition and particularly as the towns are important tourist destinations, the quality of approaches to the town should be considered in all development planning. A combination of protection of landscape assets and enhancement or removal of landscape detractors should be considered in strategic planning".
Might the enhancement of the public realm be linked to creating an attractive environment for businesses and visitors? I refer to paragraph 14.18. How will the Local Plan compliment and help deliver the Warwickshire LTPs intention to "improve the quality of transport integration into streetscapes and the urban environment"?
Are there specific opportunities to demonstrate how CIL/S106 agreements could contribute towards the enhancement of individual assets or specific historic places, particular streets, spaces and the public realm?
8 NPPF paragraph 169
9 NPPF paragraph 157, seventh bullet-point.
10 Joint Green Belt Review paragraph 5.4.2/3
11 NPPF paragraph 17
4
Might the Plan address the particular issues identified during the development of the evidence base, including the ten monuments, four buildings and two parks on the national heritage at risk register?
Section 15 -Green Infrastructure appears to provide the 'bench mark' for a thorough and proactive strategy. I would be welcome the opportunity to help support a further refinement of Section 11 to achieve a similar comprehensive iteration.

Thank you for providing English Heritage with the opportunity to further comment on this evolving strategic plan for the District. This correspondence will regrettably reiterate certain points made in previous letters dated 9 April 2010 and 5 July 2011; both are therefore attached for your information.
As the government's adviser for the historic environment, English Heritage broadly welcomes the positive strategy set out in section 11, and in particular Objectives 7 and 14 of the Plan.
I note a recognition in the Plan of the pressure for new development threatens the "highquality
built and natural environments in the district, particularly historic areas"1 but however goes on to reassure that 10,800 new homes (to 2029) will be founded on "best evidence"2 and located in the most suitable locations3 to help ensure the historic environment is then protected and enhanced4.
The National Planning Policy Framework (NPPF) provides the context and justification for doing so, requiring Local Plans to be prepared with the objective of contributing to the achievement of sustainable development in accordance with the principles and policies for the historic environment.5
The following comments on a number of the proposed allocations unfortunately highlight an inconsistency with the above:
1 WLP PO Paragraph 4.8 point 6
2 WLP PO Paragraph 5.1
3 WLP PO Paragraph 7.6 "In addressing the important housing issues, the Local Plan will aim to...provide well-designed new developments in the most suitable location".
4 WLP PO Paragraph 4.6
"To protect and maintain the character of the District, the Local Plan will have to balance the growth of the District with the protection and enhancement of these assets".
5 NPPF Paragraph 151
2
Site D Land south of Gallows Hill, Warwick
Key assets affected - Warwick Castle Park Grade I Registered Park and Garden; Warwick
Castle Grade I Listed Building; Warwick Conservation Area
In comparison to all the nine sites assessed in the Landscape Character Assessment for
Land South of Warwick (Richard Morrish Associates, 2009 - Referred to herein as the LCA Report), the site to the south of Gallows Hill is described as being the area of highest relative value to the setting of Warwick. It is the only site that is considered to be unacceptable in principle.
"This is generally an area of well maintained agricultural land that is important to the setting of Castle Park and prominent in approaches to Warwick. We feel it should be safeguarded from development". Paragraph 5.4 LCA Report
"Warwick and Leamington Spa have highly-valued historic cores and Warwick Castle and the associated Castle Park have national heritage significance. Protecting the setting of these features must be considered a principal goal of future development planning in the locality".
Paragraph 5.1 LCA Report
It is needless to say any proposal which harms heritage assets of such national significance to such a degree is contrary to the NPPF6 and the principles of sustainable development.
The harm is not outweighed by the public benefit associated with this housing development.
It should be noted that the LCA Report does not refer to either the Historic Environment Record or the Warwick CA Appraisal; and it preceded the publication of the NPPF (March 2012);The Setting of Heritage Assets - English Heritage Guidance (October 2010); The Warwickshire Historic Landscape Characterisation (HLC) Report (WCC 2011)7; and the Conservation Plan for the park. If applied these are likely to reaffirm the sensitivity of the site and the unsuitability of the allocation.
Site WL5a Loes Farm, Warwick (Guy's Cliffe)
The draft local plan fails to have adequately considered the impact on designated and undesignated heritage assets to determine the suitability of the allocation. The proposal would appear likely to cause substantial harm to undesignated heritage assets of significant value, and harm to the setting of designated assets that contribute to that assets significance. This would be contrary to the NPPF and the great weight that should be afforded the conservation of heritage assets.
I refer to my letter dated 10 April 2010.
"You should ensure that thorough evidence is applied to determine whether the proposal would adversely affect the significance of the designated historic landscape and its setting including key views in and out. The direct and indirect impacts of major new development on the individual components that determine the relative value of Guy's Cliffe in total should be understood.
English Heritage considers that the well preserved areas of ridge and furrow should certainly be regarded as of national importance and preserved as a consequence, see:-
http://www.english-heritage.org.uk/upload/pdf/turning_plough.pdf?1267377944 "
The NPPF is clear that a draft local plan may be considered unsound if there has been no proper assessment of the significance of heritage assets in the area, including their settings,
6 NPPF paragraph 132
7 NPPF paragraph 170
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and of the potential for finding new sites of archaeological or historic interest8, or, there has been no proper assessment to identify land where development would be inappropriate because of its historic significance.9
The Joint Green Belt Review recommends that to determine site suitability "finer grained, more detailed analysis" should be undertaken including the consideration of "Archaeological Constraints; Character, Setting; and Historic Landscape Character Analysis"10. This appears not to have been undertaken.
Site K5 south east Kenilworth
Previous correspondence highlighted the need to consider the evident significance of the adjacent Stoneleigh Abbey and designated Glasshouse Roman settlement, and the potential for further archaeology. Has this evidence been addressed?
Any future development would certainly need to protect the scheduled archaeology and its setting and that of the Grade II* registered Stoneleigh Abbey Park.
Coventry and Warwickshire Gateway - Baginton
The scale and form of any future development here is currently unclear. However it should be noted that the area includes designated and undesignated heritage assets of great importance. In accordance with the national policy expectations referred to above, a specific historic environment assessment must be undertaken to fully understand the landscape's special historic interest, the locations of particular historic significance and sensitivity. This can in turn inform the areas capacity, where development may best take place and what form
it might take.
Section 11. The Historic Environment
One of the twelve principal objectives for planning in the NPPF is the conservation of heritage assets for the quality of life they bring to this and future generations11.
Conservation means maintaining what is important about a place and improving it where this is desirable. This is not a passive exercise. Consequently we welcome the proactive approach you intend to take.
To compliment these measures might I suggest the Plan also address and target specific environmental improvements; the assets within the area on the heritage at risk register and the opportunity afforded by CIL/S106 agreements.
I note paragraph 5.1 of the LCR Report. "In addition and particularly as the towns are important tourist destinations, the quality of approaches to the town should be considered in all development planning. A combination of protection of landscape assets and enhancement or removal of landscape detractors should be considered in strategic planning".
Might the enhancement of the public realm be linked to creating an attractive environment for businesses and visitors? I refer to paragraph 14.18. How will the Local Plan compliment and help deliver the Warwickshire LTPs intention to "improve the quality of transport integration into streetscapes and the urban environment"?
Are there specific opportunities to demonstrate how CIL/S106 agreements could contribute towards the enhancement of individual assets or specific historic places, particular streets, spaces and the public realm?
8 NPPF paragraph 169
9 NPPF paragraph 157, seventh bullet-point.
10 Joint Green Belt Review paragraph 5.4.2/3
11 NPPF paragraph 17
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Might the Plan address the particular issues identified during the development of the evidence base, including the ten monuments, four buildings and two parks on the national heritage at risk register?
Section 15 -Green Infrastructure appears to provide the 'bench mark' for a thorough and proactive strategy. I would be welcome the opportunity to help support a further refinement of Section 11 to achieve a similar comprehensive iteration.

I have been reading the New Local Plan consultation document and I am in complete agreement with most of it.

1. Particularly important are that you have identified the need to protect Green Belt sites and historic areas, buildings etc.
2.My Preferred Growth Level would be Option 1.
3.Warwick & District should not become commuter overspill for the West Midlands Conurbation!
4.Strong resistance to out-of-town retail developments.
5.Inappropriate development will not be given planning permission.
6.The quality of the built environment is high but there are certain sites that would benefit from improvement.
7.Protect / enhance historic environment and ensure new development is in keeping with surroundings.
8.Some farm buildings could be converted for residential, employment & retail uses where appropriate as an alternative to greenfield development, as suggested.
9.Replace / enhance unattractive buildings and restore historic buildings to high standards.
10.Continue opposition to High Speed 2 rail link.
11.Agree with Green Infrastructure policies

Providing sustainable levels of growth :
The levels of growth envisioned are not sustainable- in that the level of infrastructure, its
distribution, housing location and jobs, do not match the population growth forecast.
A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause
immense damage to the the character of the County Town
Level of Population Growth and demand for housing assumptions:
These are flawed because:
Given that more than 50% of national population growth has been from immigration over the
last two decades, and the government has publicly stated it wishes to greatly reduce this
future net immigration, why is Warwick District planning for an even greater level of growth
over the next 15 years, than has been experienced in the recent past?
* Housing demand growth in England is from a combination of net immigration and
changes in household demographics towards smaller households.
* However the impact of a prolonged recession which the Prime Minister says could last
another decade, will impact on the ability of individuals to afford housing.
* This is manifest in the rapidly rising age of first time buyers and the profound
demographic change since 2008 in more young adults living at home with their parents
for much longer than in the past.
* So why is the plan still assuming a rapid increase in demand for single occupancy
households; when the actual demographic trend is away from this?
* Is the modelling based on current data, or is it simply looking at the demand during the
decade of rapid growth and easy availability of mortgage loans pre the 2008 crash?
* This in turn could mean that in fact far less individual units are required for the District
as a whole, but a greater emphasis should be given for multi generational living , with
semi independent adults?
Distribution of housing within the District
The plan talks about the need to distribute housing across the entire District , but then in fact does
not do this!
A starting point should be that EVERY ward has the same level of housing growth during the plan,
i.e. A 20% across the board increase.
* It appears that most housing will be again concentrated within Warwick and parts of
Leamington Spa, with very little in the large villages or in Kenilworth
* This is curious, as it also points out the lack of affordable rural housing but then basically
ignores any provision for it!
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* The inexplicable lack of housing growth in and around Kenilworth is most odd given that the
job growth is likely to be around the University and Coventry Airport, and the town already
has a lot of facilities.
* 830 houses over 15 years in the villages is clearly inadequate to meet their housing needs
or the lack of affordable housing, this is only 55 houses per year spread across a wide
geographical area.
* I suggest as a minimum 2500 of the 10800 houses in the plan be developed in the
village areas spread evenly across the district.
* This provision WOULD meet the need for affordable rural housing projected, at 55
per year if 33% was "affordable".
I suggest two areas which have been overlooked for large scale housing provision are Radford
Semile and Lapworth.
* Both are ripe for large scale "garden suburbs", supported by business parks. This would
support and make more viable their existing shops and schools.
* I suggest that at least an additional 1000 to 1500 houses are considered for each ward, and
therefore the significant benefits of population growth extolled by this plan are met, coupled
with local affordable housing and retail provision
* I note they both have existing primary schools, and good proximity to public transport and
roads, and Lapworth has a commuter railway station.
* There is also the opportunity in Lapworth to build a business park to tap into the proximity
to Solihull and at Radford Semile to build a business park dedicated to engineering to tap
into the expertise and supply chain associated with Ricardos.
* This in turn would mean much smaller developments around Milverton and Warwick would
therefore by required.
Transport
For the plan to be actually sustainable, there needs to be a lot more vision for integrated public
transport.
Cycle ways:
It would be a good objective to work with the County Council to ensure that EVERY community is
served by a dedicated cycle way, especially within the urban areas, where short lengths of cycle
way often just stop.
This should be funded by developers of the new housing as a priority via the Community
Infrastructure Levy
Commuter Rail and Bus Routes:
The plan envisions much new low cost housing, yet this is concentrated mainly around Warwick,
and the new job provision is in the north of the District.
HOW are those in low paid jobs who will presumably be the beneficiaries of the "low cost" housing,
be able to commute to where the jobs are if they cannot afford their own cars?
For the plan to be sustainable surely it would be better to have more smaller housing
developments within walking/ cycle distance of the new job provision; i.e. small estates near small
business parks?
* IF this is not possible a commitment to provide and subsidise long distance inter nodal
commuter bus routes is essential.
* Low paid workers will need to be able to commute quickly and cheaply to where the jobs
actually are!?
* This can be achieved, by developing inter town express bus routes to link together;
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Warwick, Leamington, Stratford, Coventry, The University, Nuneaton, Rugby, Kenilworth
and the larger villages; integrated with mini bus services which will THEN serve the local
housing areas. Funded by the Community Infrastructure Levy.
* NOT the farcical situation as now when it take between 90 and 120 minutes each way to
get between towns , which IF a direct town centre to town centre route could be achieved in
20 -30 minutes, (existing buses take very circular routes).
* This lack of effective public commuter transport compounds inequality and creates greater
dependency on state subsidies, as those able and willing to work cannot afford the
transport to get to the jobs, and the bus services are simply too slow and too infrequent to
be a viable alternative.
* Similarly regular local new commuter train services linking together ALL the major
Warwickshire Towns and Coventry should be a priority, funded by the Community
Infrastructure Levy,.
* The "virtual" park and ride scheme, seems like a lot of hot air political spin. Does it
effectively mean NO park and ride , but a slightly extended bus route?
Air Pollution
Parts of WDC already do not meet the Nox emissions EU Directive, including large parts of the
centre of Warwick.
This is likely to be tightened up in the near future with harder targets and lower permissible
emissions, possibly wit fines for non compliance.
It therefore seems curious that the large-scale housing developments on the edge of Warwick are
suggested with a likely 40% increase in the town's population, over 15 years.
This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?
Historic Distinctiveness
* I believe the plan should do more to promote good design in housing.
* It is should also seek to unambiguously protect the historic buildings in the area and their
settings, as this is one of the major "draw" factors for population growth and economic
vitality
* The plan has some very vague and bland statements, it needs a clearly articulated
"heritage vision", backed up with detailed planning guidance and then an appetite for
rigorous enforcement.
* Our towns are special, BUT only if the key historic and architectural elements and values
are protected, otherwise they risk becoming a sprawling new town reminiscent of Milton
Keynes.
* The existing open spaces, sports fields, allotments and parklands should unambigiously be
protected from development, including their settings.
Definitions of affordable Housing
I suggest that the definition of what is affordable housing needs broadening.
The plan highlights the need for housing for the elderly and the growth of the elderly as a % of the
population.
One solution to their needs and the obvious trends in semi independent adults living much longer
with their parents because they cannot afford to get on the housing ladder, would be to classify
"granny flats" or semi separated apartments within houses as going towards the "affordable
housing" targets.
Multigenerational living should be encouraged as it meets housing need, is sustainable and reflects
changing land-use patterns. There is the opportunity to boost this by incorporating it into the plan's
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housing targets and helps meet the need for "mixed" housing.
Gypsy Site:
I suggest the land adjacent to the Junc 15 of the M40 might be a suitable site.
There is little nearby existing housing, but a public bus service and good road access
Employment Land
I support the use of green belt land to expand employment opportunities on well designed business
parks at Stoneleigh and around the University. BUT there must be good public transport links to
allow potential workers to access these jobs from the existing WDC Urban areas.
HS2
HS2 could open up significant advantages for the West Midlands by improving links to London &
Heathrow, but more importantly Northern English cities and direct rail links with northern Europe.
I support HS2 and would suggest that rather than opposing a strategic transport plan which cannot
be blocked by WDC due to existing legislation, the Council concentrates in obtaining maximum
benefit for the District, by getting subsidies for improving the transport links to meet the HS2
stations.
Conservation Areas and Historic Environment
* WDC must commit to protecting the existing listed buildings, open public spaces and
conservation areas, from encroachment by development.
* Particularly as most development needs - as defined by this plan-will be met by building on
greenfield and brown field sites, there is therefore less pressure to damage the existing
historic town buildings?
* I suggest the English Heritage Guidance published in May 2011 in "Seeing History in the
View" should be incorporated into the plan.
Climate Change
Flooding and SUDS. Given the recent patterns of heavy rainfall and the long history of local
flooding, great care should be given to the sitting of all new developments.
Claims of 1000 year flood modelling should be treated with extreme scepticism as reliable data
only exists for the past 90 years.
Especially in existing urban areas a conservative approach should be given to any large new
buildings and their impact on surface water drainage.
Consideration should be given to more local flood defences and helping individuals to flood proof
their homes.
Fear of Crime
* No sex clubs or night clubs should be allowed near housing- they should only be built in
non residential areas.
* No new pubs, bars or hotels should be built or change of use in areas of predominately
residential nature, to protect existing residential amenity.
* There should be the presumption that in residential areas new businesses will not increase
the background ambient noise levels. If this cannot be achieved these businesses should
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be located in designated areas such as retail or business parks.
Good Design:
The plan highlights good design and sustainability, this should be supported but defined
All new housing should be built to Parker Morris standards
http://www.singleaspect.org.uk/pm/index.php
* These standards are based on ergonomics of the minimum space needed to meet "a
functional approach to determining space standards in the home by considering
what furniture was needed in rooms, the space needed to use the furniture and move
around it, and the space needed for normal, household activities."
As these were the minimum set for UK 1961 social housing it is not unreasonable that they should
be the very minimum acceptable in WDC for the next 15 years. OR we run the risk of creating
housing that CANNOT meet the needs of the occupants and risks becoming dysfunctional or
slums, which by definition is hardly "sustainable".
Public Space:
Existing open space, sports and recreational buildings and land, including playing fields, should
not be built on !
Any new developments should have additional public space.
Tourism
* Any new visitor accommodation -over a small number of bedrooms- should be examined to
see if it would have a negative impact on the existing providers locally as a material
planning consideration.
* Small independent providers of accommodation tend to support far more local jobs and
have a bigger local economic impact by their use of local suppliers.
* It is desirable to have a diversity in type and location of accommodation providers.
* New budget chain hotels which have a similar impact on existing hotels and guest houses,
to that of supermarkets on independent retail traders. They should only be permitted where
it can be demonstrated there is an unmet demand or capacity need. And there will not be a
detrimental impact on existing buisnesses.
Green Wedges
This seems to be a meaningless concept.