Norton Lindsey has no viable public transport. Nothing to Warwick and 2 buses a week to Stratford and 2 buses a week to Solihull.This is a rural location with frequent moving of livestock and many horses being excercised together with farm machinery.the roads are narow and bendy and we already have well known accident spots any increase in traffic will only make this worse.

Object to proposal to dual carriageway the kenilworth to leamington road, and object to the 'northern relief road'. Both will cause excessive environmental damage and are not required. The whole basis for the size of the developments in this area is flawed.

We support this option because improvements to the junctions in Kenilworth and the creation of a new railway station in the town would create a safer community and attract commuter families to live in the town.

Norton Lindsey has little access to Public transport. massively increasing car use will create danger for pedestrians, children, horse riders agricultural workers etc.

Electronic attachment

Dear Development Policy Manager,

We are writing to express our views about the Local Plan.

We believe that the best option would be to develop land to the south of Leamington Spa, rather than the north. There are several reasons for this. First, we understand that land to the south has previously been identified as being suitable for development by the Council. Developing this land would expand the Heathcote community and help develop the existing local facilities there. Second, it would result in quicker links to the M40, avoiding the need for residents to pass through the centres of Warwick and Leamington. Third, residents would have quick and easy access to the local railway stations. Fourth, residents would be closer to existing employment areas, and fifth it would reduce the need to develop Green Belt.

In contrast, development of land to the north of Leamington Spa would involve Green Belt land and would result in greater traffic through the already congested town centre. It would dramatically increase traffic on the A46 and A445, and it would require a new road to be built, resulting in far greater expenditure than development to the south of the town. The money required to build this road would be better invested in improving the existing infrastructure south of the town.

As residents of the area to the north of Leamington Spa, we believe the development of Green Belt land in this area would have a dramatic detrimental impact on the local community and should only be considered as a last resort. Since sufficient land outside the Green Belt that is suitable for the proposed development is available to the south of Leamington, to the east of Radford Semele and to the south of Bishops Tatchbrook, we can see no compelling reason for developing the Green Belt land to the north of Leamington Spa.

Yours sincerely,

Prof Gregory Challis and Dr Alison Foster

I find the proposed development plan very ott and full of promises that will probably never come to fruition. I know that there is a requirement for new housing but feel that the 10,000 is excessive, bearing in mind empty properties and places proposed for in-filling. I do not believe that we have the infra-structure in this area to cope. Surely you start with employment opportunities and then start building houses. The roads in the centre of Kenilworth, Leamington Spa and Warwick can barely cope with the amount of traffic there is at present. Public transport needs to be improved first, ideas to limit car travel need to be considered before any housebuilding, otherwise the result will be chaos and gridlocked roads. Buses should be subsidised. Some routes are hardly used, e.g. the Hatton Park development where the buses into Warwick are normally empty and those living on the estate should be encouraged to leave their cars at home and use the empty buses. Otherwise the number of buses should be curtailed or stopped.

I am especially worried about areas 2 and 3 as it appears to be complete over-development. Will traffic be pouring into Warwick and Leamington from these estates? If so, Myton Road, Castle Hill, Tachbrook Road, etc. will become totally gridlocked. What plans are there to overcome this?

Infilling is also very worrying. I live opposite the old fire station in Warwick and see that it is now a very useful additional parking area for people living in Albert, Victoria and Edward Streets. It also provides many parking spaces for County Council employees who work in the Saltisford Buildings. If social housing is built on this site, not only will we lose this valuable parking space, each new house/dwelling will have to have a minimum of parking space for 2 cars otherwise it will just add to the already serious parking problem. I only have a visitors parking permit but quite often my visitors have great difficulty in finding a parking space. Thought needs to be given to the allocation of parking permits for each household. When considering infilling, thought needs to be given, not only to what will be built on the site but how it will affect everything around that site. We see very few parking attendants and the "No Entry" sign at the Saltisford and Albert Street Junction is often ignored. Parking is already a very serious problem. Unless something is done when the social housing is built it will become an even bigger problem.

I do hope that lessons have been learned from development of estates like the Woodloes where a school was one of the last things to be built.

With regard to Warwick District Council's New Local Plan and Preferred Options: I support the numerous objections of the residents of Old Milverton, Blackdown and the views of Jeremy Wright MP in the Courier of July 20th. The source of WDC's evidence for future population growth was successfully (and evidentially) challenged at the Parish council meeting on 16th July. The NPPF is referenced by WDC's new Proposed Local Plan regularly but the content is selectively ignored:
Section 3 - Supporting a prosperous rural economy
* The development of this area will keep infrastructure developments in urban areas and ignore the employment and housing requirements of more rural communities.
Section 4 - Promoting Sustainable transport
* It will increase private traffic through areas used by families and schoolchildren and ignores the requirement for sustainable well-placed transport networks.
Section 5 - Supporting High Quality Communications Infrastructure
* It ignores the need for public transport and high-speed broadband in smaller rural areas.
Section 9 - Protecting Greenbelt Land.
* It dismisses the high value of greenbelt land directly in contradiction of the NPPF.

I refer you to the foreword in the NPPF and its Core Planning Principles. Please follow the requirement of consultation by acting upon the objections of members of the local community with as much vigor as you have done with landowners and development firms. Most of the developers and landowners, particularly in Old Milverton, do not live locally. Financial gain on their behalf does not come with a qualitative cost.

Contrary to Councilor Doody's apparent advice of the 16th of July this year, I will be sending copies of this letter and its objections to my local Members of Parliament. I do not share his alleged opinion that my elected political representatives and their governing processes are a waste of time. I have attached further explanation of my objections below.
Section 9 - Protecting Greenbelt Land.
The area of greenbelt on which development is proposed was identified as such in the last local plan. It was confirmed as of high value by WDC's study of greenbelt not very long ago.
To develop this greenbelt area is to poorly site several thousands of residential houses at the opposite end of town from their road and rail links, main shopping sites and other amenities.
The proposals are contrary to the National Policy Planning Framework's Guidelines on Protecting Greenbelt Land. 'Very special circumstances' do not exist. More suitable land with better transport and amenity links has been identified in south Leamington, closer to most of the aforementioned developments (including new development at the old Ford foundry) which is not green-belt.
The proposed local plan would destroy greenbelt land which for the most part is currently good, economically productive farmland with public access for recreation and provision of views, wildlife habitat, and a barrier for the protection of further farmland that currently prevents urban sprawl.
I hope that the council does not consider the financial gain proposed by development firms more important than the social, environmental and economic needs of its future residents or the benefits derived by current residents from the green-belt land.
Section 3 - Supporting a prosperous rural economy
The smaller villages surrounding Leamington Spa have become commuter dormitories due to lack of infrastructure development and withdrawal of services. The proposed plan will set in motion their complete assimilation into the greater urban area.
The proposed development areas in Warwick University, Coventry Airport and Stoneleigh Park would afford the opportunity for local employment to some of these villages and negate the need for a large, counter-productive block of development to service them. This has obvious economic and ecological benefits.
I agree with the NPPF that there is a need for controlled rural development, it is needed in order to arrest the decline of rural communities, not to write them off completely and leave them years behind their urban cousins in order to maximize on private industry profitability.
Section 4 - Promoting Sustainable transport
Traffic on the Old Milverton and Kenilworth roads is already significant. The proposed northern relief road will do nothing but compound the poor placement of houses and park-and-ride by increasing traffic from north Leamington, through Old Milverton and through housing estates in Milverton where it already conflicts with pedestrian traffic of school children. Flow the other way will increase traffic from north and west Leamington to transport links off the A46 through the same areas.
Expanding the existing Kenilworth-Leamington road to dual carriageway will have a massive impact on long-standing greenbelt and increase traffic from the A46 through Blackdown towards Stoneleigh-park and the routes above.
Development should be concentrated to the south of Leamington keeping the destinations of park and ride nearer to the rail links in Leamington and Warwick, motorway links, shopping, amenities and better transport links which all exist to the south.
This approach would support the NPPF's aims whilst allowing for the larger developments to be focused on land to the south of Leamington and other already brown-field sites. It would also add to the revitalization of Leamington's old town.
Section 5 - Supporting High Quality Communications Infrastructure
The proposed plan states that it has chosen to concentrate development in areas where transport, amenity, communication and recreation already exist. This is clearly not the case as the infrastructure developments in the greenbelt area are huge. They are designed solely to support the proposed expansion of the urban area.
The proposals contain no mention of improving transport infrastructures such as bus, and cycle routes outside of their urban expansion; no mention of high-speed broadband in outlying villages (particularly in green-belt) and only a slight nod in the direction of community led housing - without attempting to include affordable rural housing.
Green-belt in this case is a rural environment; one which is protected for the good of the character, appearance and health of the towns it surrounds. It also contains a working populous who are to be penalized for the sake of convenience and private company income.
One of these villages is now home to 3 generations of my family. I feel that providing a future for my children offering variety and opportunity rather than conurbation and limited options is something worth discussing properly.
Developments over the last 30 or so years have changed the face and character of this area completely. Their continuation is detrimental to the character, nature and vivacity of the area. I would hate to see The NPPF ignored to further add to the urban/rural division and creeping conurbation of the area inflicted by previous planning strategies.

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.

Letter attached electronically. Full text can be viewed in the attachment.

As a Grandparent of six young children, I have always enjoyed taking them to the Abbey Fields, where I can relax while they enjoy the playground, the paths and the beautiful surroundings in a safe environment.

If a cycle path were to be introduced, the peaceful and relaxing atmosphere would, in my opinion be severely threatened. Cyclists, not all of whom are considerate, can cause severe injury to all ages, but particularly to the young, who are unaware of danger, and to the elderly who may not be able to move fast enough to avoid danger. The Abbey Fields is a place to relax and not a place to worry about being knocked over by a fast moving vehicle - and I consider that a bicycle in this context can be a 'fast-moving vehicle'.

Young people, in particular, need to be able to partake in physical activities where they can use their considerable energies, but I feel that the Abbey Fields is not the place for a cycle path.

The position at present is that the Abbey Fields is a no cycling area but this is not upheld and we all know how often we have encountered cyclists putting all pedestrians at risk. To even think of partially rescinding those Byelaws to allow a cycle path through the fields would encourage many more people to assume that the area is free to use for cyclists.

The existing path from Bridge Street to the swimming pool is the main route to the play area for families with children. This should not even be considered as suitable for more vehicular traffic. It also leads to an area which can become very congested on both sides of the swimming pool. With the natural course of the brook with its pedestrian bridges there is no scope there for making that a cyclists route.

Has anyone done a survey of cyclists to see how they wish to use the route? Is it recreational or are many using it to get to work? Much time and research needs to be given to this problem. We have to ensure that resolutions made are for the benefit of the whole community. The Abbey Fields are such a unique feature of our town the facilities must be protected for the most vulnerable of its users ie the children and the elderly.

2:2 - Why is the environment not listed as a key priority: without it, all manner of planning applications can be granted which are anti-environmental

Is leisure included in "Health and Wellbeing". If so, this should be made clear.

2:5 - As there is no way the economy can be predicted, there should be a commitment to responding to new opportunities and needs which arise

Can the areas mentioned as requiring regeneration be identified?

I am concerned about the second bullet point under Emphasis on infrastructure, as most areas of the countryside and of importance for wildlife need only a very light touch, if a touch at all. There should be a clear distinction between the approach to parks and managed open spaces, and to wilder areas (e.g. Welch's Meadow would be ruined by heavy handed management).

3:7 - there are elements referred to in this draft plan which need to be prioritised and policy made before March/April 2012; in particular a policy on the concentration of HMOs.

4:6 - the protection afforded to conservation areas should be strengthened, particularly as these cover apparently only 4% of the district

4:8, point 2 - It should be noted that one major contributory factor to the current lack of affordable properties relates to HMOs. The house next door to mine is an example of this. It was owned by an elderly lady who went into residential care. There was a large amount of interest in the property from people who wanted it as a family home, indeed so much interest that it was decided on sealed bids. Because the property needed some updating, and I met several potential purchasers who wanted to restore it to its former self, the highest bidder was, almost inevitably, a landlord who could easily find the finance and would easily recoup the investment by turning it into an HMO. I have seen this repeated time and again in my area of south Leamington where the gains from HMOs has pushed up prices beyond affordable for an individual or family: indeed a local couple I know has not been able to find an affordable small period house and, despite wanting to stay in Leamington, is having to move to Cheltenham to find such a property. In addition to the price problem, most often the conversion to HMO is the cheapest possible and degrades the period property.

4:10.2 - It is right to accommodate university students, but not at the expense of other "settled" residents. South Leamington is at a tipping point where the area could be completely dominated by students The advantages of a large student population tend to benefit the few - landlords and places selling cheap food and drink, whilst the cost and disadvantages are picked up by Council tax payers and local neighbours. It also means that businesses not directed at students tend to stay away. One south town resident recently pointed out that because Leamington is only a student dormitory town rather than a university town, we have generally ended up with all of the problems of a large student population and none of the advantages of the university culture which takes place on campus. I can see no reason why special consideration should be afforded to the University of Warwick in providing accommodation for its students.

4:11 - I agree with all these points, particularly endorsing numbers 7, 9 and 10. It is particularly important in any development not to let the developer be the tail which wags the dog, as the developer will inevitably want to take the easiest and cheapest route in contradiction to the area's best interests.

5-7 - Level of growth:
As forecasting population growth is a very inexact science, the Council should constantly monitor what is actually happening. If the expected population growth is not materialising, planned development should be scaled back accordingly. It makes sense therefore to insist on development of the brownfield sites before eating into Green Belt.

P04:D - Loss of green space should also be taken into account when assessing development of garden land. This space may not be directly accessible to the general public, but if it contributes to the overall feeling of green space which is enjoyed by the general public (e.g. with trees that can be seen from neighbouring streets), it is very important that it is maintained. It is also important for biodiversity and the environment, as gardens are now understood to be extremely important habitats for wildlife.

P06.D - It is most important to identify the locational criteria and to carry out a thorough survey of all HMOs and their residents, not just those which have previously had to get Council approval.

7.59 - We need this policy now!

P08 - We also need a firm policy now regarding the protection of existing employment buildings from change of use, as in my area I can think of several schemes either applyng for or already granted planning permission to change from commercial to residential use. The Plan already points out that f the area population is going to increase, then employment will need to increase as well and it is short-sighted to be allowing commercial property to disappear.

8:21 - Does the projection of additional job requirement take into account that the growth in the older population will automatically mean the release of the jobs these people were doing?

9: Retailing

It is a mistake to be led by the retail "experts" who push for constant retail development schemes in order to compete with neighbouring towns. There is a fine balance between having enough "High Street names" to serve shoppers and having so many that Leamington becomes indistinguishable from any other shopping centre - in which case, why would any non-residents want to come here? The success of the last major retail development - which seems dubious to me - (Parade to Regent Street) should be assessed before rushing into another similar development. Outside shoppers will travel to a shopping centre to find something different and it is this difference which needs to be identified and promoted. These major developments also seem to push up rents for retailers.

13: Inclusive, Safe and Healthy Communities

Developments should not be permitted which will downgrade and produce associated problems to an area, e.g. SEVs.

14: Transport

I suggest WDC promote a car sharing scheme.

P014: How can you plan a retail development in Chandos Street whilst aiming to maintain sufficient parking in town centres. Chandos Street is a much more popular car park than the multi-storeys.

15: Green Infrastructure

A relevant issue is that Network Rail is destroying, and has been for a long time, the natural environment and wildlife habitat along railway lines by felling all the trees and killing undergrowth every year with weed killer.

15:14 - Yes to urban tree planting; concern about messing with the River Leam borders unless already in a well-used managed area.

P017 - I agree with the continued support for the development of a cultural quarter

I believe that existing visitor accommodation should be protected from change of use.

18: Flooding

Planning permission should be sought by someone wanting to pave/concrete over a front garden, as I believe this trend has contributed to flooding problems.

Summary of major concerns

* Restrictions needed on HMOs
* Light-handed touch needed on non-parkland open spaces and riverside
* More creative study of retail demands and opportunities needed
* Although the Plan does seem to recognise this, the expansion of the district must avoid segregating areas into a single use, e.g. residential, employment, etc. Areas are much more interesting and attractive if they include a mix of residential, employment, cultural/leisure, etc. properties.

The County Council, under the Localism Act 2012, has a "duty to co-operate". The duty to co-operate requires councils to 'engage constructively, actively and on an on-going basis' on issues relevant to statutory plans. Therefore, we will assist in the plan making process and infrastructure planning on an on-going basis.

We welcome the vision and direction of the local plan to create sustainable communities and a quality environment for all those who live and work in the District.

As well as our statutory duties our view is also set out in the context of the County Council's vision contained in the "Going for Growth" paper approved in April 2012. The purpose of this paper was to identify how the County will embrace the coalition government's twin primary aims of reducing deficit and securing growth in this challenging period of public sector austerity. The "Going for Growth" paper sets out how we will assist in stimulating and influencing the business and economic environment (with the necessary educational, skill development and community ambitions) to deliver 'growth' for Warwickshire.

In respect of indicating support for any particular development Option: our view is that there should be a right balance of sites that support growth. Therefore, it is a matter for the District Council, to satisfy itself and strike the right balance, in respect of deliverability, viability and sustainability and supporting infrastructure required to deliver each option.

The planning issues and policies contained in the "Preferred Options of the Local Plan" will impact at differing levels on the County council's corporate responsibilities, particularly economic, transport, support for the elderly and extra care housing, library services public health, gypsies and travellers and education. The Director of Public Health has already responded directly to you on the consultation and evidence.

The key values contained in the "Going for Growth" paper are stated below in emboldened text and their implications for planning and landuse policy is explained in the embolden text below:

* Our social investment will contribute to a county where the will compare well to other British communities.

We will look for planning policies that support technological Infrastructure and in particular in rural areas. We will support the strategic employment sites of the strategy.

* With a sense of mutual ownership of public services (the Warwickshire Shareholder).

We will support positive planning policies that embed co-location of services with the voluntary sector, private sector providers and other public bodies.

* We will achieve a discernible reduction in inequalities in social, economic, health and well-being regardless of age disability or culture.

This applies to access to goods and services for local residents including adequate provision for gypsies and travellers.

Planning policies on extra housing and affordable is provided with the necessary long term supporting services. We will support proposals and policies for co-location of services.

* A vibrant economy will produce high quality job offers in Warwickshire, raising the skill levels in the overall workforce so that we are as productive and competitive as the best in the Country.
* Warwickshire will be a place which looks actively at the best practice from other places - international as well as national - to develop innovative and entrepreneurial solutions. Our economic well-being will be measured by international comparison not simply against "West Midlands" regional standards. Our urban town centres will punch above their weight when compared with similar sized English town centres and our rural infrastructure will be amongst the best in the Country.

We will support planning policies that support a competitive economy for inward investment.

Warwick and Stratford upon Avon are international destinations and make a significant contribution to the economy of the region and sub region.

Therefore, we will support planning policies that support and sustain the key town centres.

* Our growth plan will attract people to live and work in Warwickshire as a specific choice. There will be a strong brand image, underpinned by a recognition that this as one of the best places in the Country to live and work.

Our strategic policies contained in the Local Transport Plan and Growth strategies support the improvement and the provision of strategic infrastructure such as junction improvements to strategic highway network and provision of new railways stations.

* There will be a strong Health and Well-being ethos about the quality of lifestyle we are encouraging.....where the brand "Warwickshire" will be directly associated with a health-focussed lifestyle supported by the health infrastructure to match.

The National Planning Framework requires Local Plans to include policies for health and well-being. The County Council is also responsible for Public Health and we would seek overarching planning policies in the Local Plan that support health and well-being as part of new developments in the District.

We are committed to delivering the best possible health and wellbeing outcomes for everyone, helping people to live Warwickshire.

Planning for health is important not only from a legislative perspective, but
also in relation to costs. Promoting healthy lifestyles, avoiding health impacts
and tackling health inequalities throughout the planning process could result
in major cost savings to society. There is significant evidence on the effect that spatial planning has on community health and well-being and spatial planning policies can address local health inequalities and social exclusion. Some local authorities have adopted planning policies to promote the health and well-being of residents through development management. The Local Plan can contribute to health and well-being in the following way:-

* The quality and opportunities of the local environment is a contributory factor in shaping health.
* Transport and traffic, access to public transport, lack of open space and where we shop for food are just a few examples of how the built environment influences our physical and mental health.
* Planning can positively affect the health of residents by shaping and influencing the layout and the open spaces in between developments and securing investment for the public realm.
* For example, planning policies can include; design requirements for housing layouts to encourage safe and pleasant walking short distances to amenities and services.
Developer obligations can be used to build infrastructure such as healthcare facilities, parks or cycling routes. There should be an overarching policy that promotes health and welling for communities in the District area. Spatial planning policies can promote and provide opportunities for healthier lifestyles.

It is against the above background that the comments are made to the specific questions. This letter contains an amalgamated response from various services. Whilst we have endeavoured to bring together as many responses as possible to assist you in the development of your Core Strategy, please be aware that there may be other services that may have comments to make at subsequent consultation periods as the process moves forward.

We wish to make detail comments on the Infrastructure Delivery Plan by mid-September. However, our general comments are set out below:

Comments in relation to adult social care and specialists housing needs.

Preferred Option 6 (PO6) Mixed Communities & Wide Choice of Homes

Para 7.5.3.
C. Homes for Older People should also include homes that include the needs of local older people, adults and children with disabilities and other local vulnerable people who need care and support. Therefore, this policy should include provision for; extra care housing and supported living accommodation suitable for adults/children with disabilities.

Para 7.5.8.
The Local Plan should provide clarity on the difference Use class C2 and C3 Usage Class. All too often we are seeing the C2 Usage Class applied to individual dwellings, which seem to become institutional if they are providing independent living solutions to vulnerable adults, e.g. McCarthy Stone development in Southbank Road, Kenilworth.

Extra care housing and use class C2 and C3

There is currently some uncertainty about the precise the definition of the different care market sub sectors, including that of 'Extra Care'. Extra Care may be defined as a scheme where occupiers have their own self-contained apartment or living space(s), and generally do not wish to live entirely by themselves without access to care, but do not require either, constant care. Such occupants would have the option of purchasing, as their needs require or are determined varying degrees of domiciliary care.
In terms of which use class order Extra Care falls within, its widely recognised definition, particularly regarding the varying degrees of care provided to residents, has led to debate over whether it comes under C2 Residential Institution or C3 Dwelling Houses.

The issue here is that care homes and extra care housing - both offer long term care solutions - but the preferred model (and this is the view of older people) is independent living (use class C3) with access to 24/7 care rather than admission to residential care (use classC2). We are seeing the market over providing ie residential care homes delivered ahead of extra care housing. If the number of residential care beds introduced to the market hits the predicted number of overall required care places (extra care housing and residential care), planners are likely to argue that there is little need for extra care if the residential care market has already delivered the required/reported numbers

Housing polices within the Local Plan should, therefore, clearly set the distinction between the class uses and also address how those needs will be met.

Demand for Extra Care housing
Based on the 2001 census Warwick District Council will need to provide 1197 units of extra care housing of which 299 should be "social rented" extra care housing. The latter figure should be form about 10-15% of the affordable housing numbers for the District.

Draft Infrastructure Plan
4.4.1.
The first sentence could be re-written to read as "Adult Social Services are mainly concerned with adults and older people with physical and/or learning disabilities and/or mental health problems"

4.4.4.
The last sentence should read as "Residential care accommodation is..."

4.4.5.
May be better to refer to "older people and adults" rather than "...elderly and non-elderly people..."

4.4.6.
This needs to reflect the current 50/50 service model promoted by the County Council, i.e. a model where 50% of people who would normally go into residential care are diverted into extra care housing.

4.4.13.
The suggestion that "Housing accommodation...for people with learning or physical disabilities will be met as the need arises" needs to be clearer.

At present only a limited number of people with learning disabilities are afforded the opportunity to live independent and meaningful lives with choice and control over where and who they live with. Instead, many have their lives constrained by having to live in residential care where individual outcomes do not generally improve. With approx. 300 people with learning disabilities currently living in residential care in Warwickshire, the overall programme intention is to deliver no less than 200, 1 and 2-bedroomed apartments that are suitable for adults with learning disabilities, including an initial short term target of an average of 25 apartments per annum between 2011 and 2015 in line with the County Council's Transformation agenda.

There are about 227 people with learning disabilities in the Warwick District, some are living in extra care accommodation and the others with their main carer (this could be parents or partner). Some residents are living in "hard to let" properties and can be victims of abuse and hate crime. These specialists accommodation would provide suitable and safe accommodation for these vulnerable residents.

General comments:
The District Council needs to include both anecdotal and specific needs analyses from a range of partners, such as local GPs, CCG, NHS Warwickshire and WCC. All these partners directly support and commission services for vulnerable people with a range of health and social care requirements, and these factors need to be considered when looking at overall housing provision.

Development Management and the consideration of planning applications for Care homes.

It is the joint view of the South Warwickshire Clinical Commissioning Group and the County Council as the Public Health and Adult social care providers that the District Council should consider bringing forward a Supplementary Planning Documents ( SPD) to secure the proper distribution of housing and the implications the potential residents have for supporting care and clinical services.

We are therefore request that a moratorium on C2 applications placed. We also recommend that there should be an introduction of a two-stage process to assess planning application on behalf, i.e. a preliminary panel at Pre-Application stage. This could be made up of WDC, WCC, CCG (inc. local GPs) and NHS to consider any specialised accommodation, particularly as the District continues to attract interest from private developers who are seeking to provide specialised accommodation clearly geared to attracting the private pound and/or an imported population. This has implications for both Health and Social Care as follows:

1. NHS Continuing Health Care budgets are being used to fund services for an imported population rather than local residents. These new (and expensive) care homes or housing developments provide an attractive solution to meeting the needs of the private funder, however, we are still seeing those who cannot afford these prices being moved away from their local communities to where services are available. There will also be a drain on local GP and Nursing resources as these new and sizeable care homes come on stream.
2. Extra Care Housing delivery is complex and continues to struggle when reaching planning and enabling stages as it becomes embroiled in local policies. Therefore there should be planning policy guidance to create the proper balance of C2 and C3 housing for the District.

Subject to the input from the "specialist care and clinical services" panel, a development proposal could then progress to formal application for planning consent.

Heritage and Culture matters

We support the District Councils Local Plan direction in safeguarding and enjoyment of our natural and historic environment together with the district's rich heritage and visitor economy. Our specific comments are:-

Section 4, we would welcome specific reference to the interdependency between the district's tourist offer and the safeguarding of its natural and historic environment, and the provision of heritage and cultural activities and venues.

Section 7, we welcome reference to the need to maintain and develop the heritage and cultural infrastructure to support the needs of new residents and to support new communities in developing a sense of identity and social cohesion.

Section 10 tourism and the quality of the built and natural environment are linked, therefore, the contribution of the high quality of the environment should be specifically stated in any policy to maintain the role of towns as visitor destinations.

Section 17, we feel that the introductory list of cultural venues should include museums and archives. The paragraph on "Seeking contributions" should include heritage and cultural facilities; as communities grow, the cultural infrastructure and activities programme needs the opportunity and financial framework to grow accordingly.

Archaeology
We welcome the acknowledgement given to the importance of the District's historic environment in para. 11.1. However, archaeology and the historic environment in some cases should be joined up.

The document refers to the 'built and natural environment', (e.g. para. 4.11.7, 4.12.14, 10.4, 10.6, 11.2). 'historic areas' or the protection of 'historic assets', these terms appear to be used interchangeably. We recommend that the references to 'built and natural environment' throughout the document be re-worded to reflect that the historic environment is made up of a wide range of different types of heritage assets (including archaeological features, historic landscapes etc), rather than just historic structures.

Para. 11.1 describes the historic environment in terms of statutory protected, designated sites, such as Listed Buildings, Scheduled Monuments etc, and locally important historic assets. There are also a number of archaeological sites across the District that are of national or regional significance but may be undesignated and the local plan should also recognise this
There are also several instances where references to the protection of historic structures (such as the references in PO11 to the submission of nationally important historic assets for listing, and the bringing back of Listed buildings into use), could be expanded to take into account other, non-built, heritage assets. For example, PO11 could be expanded to include the putting forward of nationally important archaeological sites for protection as Scheduled Monuments, not just historic structures for listing.

Further clarification is needed in PO11 by "support the understanding of the significance of Heritage Assets, by: There should be provision for appropriate research for all applications relating to the historic environment".

Further clarification is needed about the reference to the Planning Authority undertaking research for all applications relating to the historic environment, or reference to requiring any planning applications relating to the historic environment to be accompanied by an appropriate assessment of the likely impact that the proposal will have upon the historic environment, as per para. 128, of the National Planning Policy Framework (NPPF). We recommend the re-wording of this section of the document and assistance from the County's specialists can be provided.

Further clarification is needed about the term 'locally designated historic assets' in PO11. It is not clear whether this is referring solely to designated historic assets such as those included on 'Local Lists', or whether this is also referring to historic assets recorded on the Warwickshire Historic Environment Record (HER). We would recommend that reference is made to appropriately considering (and protecting if appropriate) all heritage assets as part of the planning process, whether designated or not, and that reference also be made to heritage assets recorded on the Warwickshire HER. We would also recommend that this policy acknowledge that there may be as yet unidentified heritage assets across the District which may be worthy of conservation, and which may also require protecting during the planning process.

The terms 'heritage assets' and 'historic assets' are used interchangeably throughout the document. We would recommend that the term 'heritage assets' be used in preference to 'historic assets' as this is the term used throughout the NPPF and other policy documents.

We support the reference in PO11 to the use of Article 4 directions to help protect the historic environment.

PO11 proposes protecting the historic through the submission of nationally important historic assets for listing. Not all heritage assets of national importance are listable, some may be better protected by being statutorily protected as Scheduled Monuments or included on the English Heritage 'Register of Historic Parks and Gardens of special historic interest in England'. This policy should reflect this.

We also suggest that indirect impacts of development on heritage assets should also be added to any criteria based policy, for example, the impact that a proposed development may have upon the setting of a heritage asset which may be outside of the planning application site. Whilst there is reference to setting in para. 11.9, this is only referring to the setting of Conservation Areas.

Chapter 11, Para. 11.6 should read 'putting them to viable uses consistent with their conservation'

We also note the intention to draw up Local Lists of heritage assets (PO11); There should be clear methodology for identification of appropriate sites on the basis of our Historic Environment Records data. There should be acknowledgement throughout the Local Plan that open space can support conservation of the historic environment as well as the natural environment.

The list of areas of historic or environmental importance in the District should include reference to "41 Scheduled Monuments". We would also recommend that reference be made to the significant number of undesignated heritage assets within the District which are recorded on the Warwickshire Historic Environment Record.

We welcome that Chapter 15: Green Infrastructure makes reference to the Warwickshire Historic Environment Record (including the Historic Landscape Characterisation and Historic Farmsteads studies) (para. 15.21), however, it is disappointing that no reference is made to these within chapter 11, which specifically deals with the Historic Environment. It should be noted that whilst para. 15.21 states that the District Council has the Historic Environment Record

Proposed development sites
The Strategic Housing Land Availability Assessment (which has informed the choice of preferred development sites included in the proposed Local Plan) should also assessed the impact that the proposed development of these sites could have upon the historic environment.

Whilst the assessment has identified statutorily protected sites on and within the vicinity of the potential development sites, however these have not considered a number of known un-designated heritage assets which the Council may also wish to consider. . These undesignated, heritage assets are of national significance and worthy of conservation. The assessment should also consider the historic landscape character of these areas.

In addition, as noted in our previous responses to the earlier Options paper of July 2008 and the 2009 "Proposed Submission Core Strategy" consultation, there will also be archaeological sites as yet undiscovered which will not be recorded on the HER, and even in areas where no archaeology has been recorded, evaluation may be required to confirm the presence/absence of remains. Consultation on a site by site basis will remain the best means of identifying archaeologically sensitive areas on the basis of current knowledge, as well as areas where archaeological potential will need to be assessed through more detailed work.

Since the individual allocations will need to take account of the impact upon historic environment we recommend that further work be undertaken to identify the issues in respect of the historic environment.

The selection criteria for the major development sites should also include for a thorough consideration of Historic Environment, and proper appraisal is undertaken and allowance made where necessary for preservation of sites of national Importance (in the sense of the 1979 Ancient Monuments and Archaeological Areas Act and the National Planning Policy Framework). We perhaps need a separate meetings to work on a systematic assessment of potential sites being put forward.

Tourism policy - general comments
We support the tourism policy of the Local Plan. Tourism is a significant sector of the overall economy within Warwick District and is recognised as a strategic priority within WDC's emerging Economic Development and Regeneration Strategy, it is recommended that Local Plan polices. Therefore, the District Council should also consider to referencing tourism as part of policy no P0 8 Economy and vica versa.

PO 8 Economy
We support the preparation of the Economic Development and Regeneration Strategy to provide a clear direction for growing and sustaining the economic position of the District Council area.

PO 17 Culture & Tourism
Rural broadband policies and policies for Culture and tourism should be cross referenced to promote the quality of the offer in the District.

It is therefore recommended that an introductory statement along the lines of Weston-Super-Mare might be more suitable:

"The Council will work with partners to support the development and retention of new and existing tourism facilities, for both business and leisure markets and promote their sustainable expansion across the District, whilst maximising their co-locational and cumulative benefits to:

* assist in regenerating our town centres by supporting growth of their retail, evening and night time economies by offering facilities and functions that could encourage spending within the wider areas;
* assist with development of green infrastructure corridors linking destinations and attractions for the benefit of both residents and visitors;
* improve the range, quality and distinctiveness of the District's tourism destination;
* provide high quality hotels and serviced and non-serviced accommodation formats and conferencing facilities;
promote the image and reputation of the District to attract visitors and secure investment."
Town centre tourist accommodation
We support the "town centre first" sequential approach for the further hotel accommodation. To support this and as an alternative, it is recommended that the Council consider the following policy wording:

Within the existing urban settlements of Warwick, Kenilworth and Leamington Spa, proposals that would result in the change of use hotels and tourist accommodation will be permitted unless:
* the proposed use or uses would reduce the overall capacity and attractiveness of Warwick, Kenilworth and Leamington Spa as tourism hubs and result in the loss of an otherwise viable hotel or tourist facility which would consequently harm the provision of tourist accommodation;
* the proposed use or uses would be incompatible with the surrounding area and businesses and would harm the character of the town centre;
* there would be no clear, additional benefits from the proposal in terms of improving the character of the area, the vitality and viability of the town centre and the economic and, cultural and environmental impact on the town as a whole.
Applicants seeking change of use away from existing hotel or tourist accommodation use will need to submit detailed evidence relating to the viability of the business and details of how the business has been marketed.

Rural accommodation

We support tourism in rural areas and we recommend that the Local Plan should have a specific policy to address expansion and re-development of existing tourism accommodation and tourism facilities within the Green Belt.

Accommodation not in permanent buildings
The District Council may wish to consider an additional policy to cover accommodation not in permanent buildings (i.e. camping, caravan and chalet parks). This type of accommodation can be damaging to the character of landscapes, and in rural areas the added light pollution can be intrusive. It is recommended that small scale developments should be supported in areas of open countryside or next to small settlements provided they are not prominent in the landscape and have high quality landscaping. The policy may choose to exclude locations in sensitive landscapes and areas prone to flooding.

Ecological & Geological
We welcome and support the strategic direction outlined in the Preferred Options document in relation to the Natural Environment and would like to make the following suggestions:

4. Spatial Portrait, Issues and Objectives
4.7 - Sites of Importance for Nature Conservation are now referred to Local Wildlife Sites. It is suggested that Local Geological Sites are also listed. You may wish also to consider using the Habitat Biodiversity Audit and the State of Biodiversity Report to provide a Spatial Portrait of the District's Biodiversity.
4.8 - You may wish to add climate change as a pressure in bullet point 9

7. Housing
7.5 - You may wish to add within the important issues a reference to the natural environment such as "Maintain access to the natural environment in both urban and rural settings to reap social, economic and well-being benefits".
PO4 Distribution of Sites for Housing: (A) Allocated Sites - we are aware of the habitat evidence submitted for the previous work on the local plan, but would suggest that a new model has been produced to measure Habitat Distinctiveness and Connectivity throughout Warwickshire, Coventry and Solihull. This approach is placed at the heart of the National Planning Policy Framework as a way to indicate 'sensitivity' of habitats within potential allocated sites and how the site acts within the ecological corridors. We would recommend that this approach is investigated as partners to the Habitat Biodiversity Audit with the knowledge that the habitat data is current and sound.

PO4 Distribution of Sites for Housing: (C) Development of Brownfield Sites - we welcome the comment relating the development having 'no serious impact on the amenity and environment of their surroundings'. However, brownfield sites can be e very important ecological sites in their own right so suggest that this aspect is noted in the future policy.

8. Economy
There is no reference to the relationship between a healthy environment and the economy. It is suggested that this link is made in the introduction to add weight and substance to subsequent paragraphs within the policy such as 8.15. For example a statement could be, "There are proven links between the natural environment and economics (National Ecosystem Assessment, 2010) through an Ecosystem Services approach. It is essential that these links are maintained and enhanced through both the placement and setting of commercial activities coupled with the retention of agricultural and silvicultural practices." Further pictorial reference to explain Ecosystems Service can be found in the National Ecosystem Assessment documentation.

9. Built Environment
We support the 'Sustainable Garden towns, suburbs and village' design guide as well as the Relevant Issues and Strategic Objectives.

10. Climate Change
It is recommended that more be added in relation to Climate Change Adaptation within the introduction to support the last bullet within the box titled PO12 Climate Change.
12.25 - 12.26 These paragraphs outline the impacts and issues relating to Climate Change Adaptation, however, it is felt that this topic could be expanded upon within future documents, e.g. an addition Supplementary Planning Document or equivalent. This additional document could promote green roofs, green walls and other ways to promote urban cooling etc. WCC Ecological Services is able to signpost you to a couple of other Local Authority documentation on this topic.

11. Transport
It is recommended that reference be made to the Natural Environment White Paper (2011) and the importance of transport networks and ecological connectivity assets.

12. Green Infrastructure
In our opinion we suggest that this chapter is well balanced and support its approach. It is suggested that additional references to Ecosystem Services, the Warwickshire Biological Record Centre and the importance of using up-to-date ecological and geological / geomorphological data is used is the assessment of development proposals. These should be added to the future policy and the Ecological Services are able to assist you with this advice, subject to resources.
By the time the future policy is formed the Sub-regional Green Infrastructure Strategy will have been produced for consultation and can be more fully referenced as a mechanism to deliver your objectives outlined in this chapter.

18. Flooding and Water
In relation to ecology it is recommended that there is future referenced to the safeguarding or promotion of natural flood alleviation areas at strategic sites within the district as short, medium and long term aspirations to assist with flood risk measure. We are aware that this may form part of the Catchment Flood Risk Management Plan (18.9) or fall within the Sustainable Urban Drainage Approving Body's remit, but would suggest that these strategic potentials should be particularly noted within the future policy. These sites could then be potential delivered through the biodiversity offsetting metrics (15.16).

It is also recommended that a further discussion be held regarding the assessment of allocated sites using latest modelling of habitat data.

Comments regarding minerals safeguarding
Para. 143 of the National Planning Policy Framework (NPPF) requires that in preparing Local Plans, local planning authorities should define Minerals Safeguarding Areas and adopt appropriate policies in order that known locations of specific mineral resources of local and national importance are not needlessly sterilised by non-mineral development, whilst not creating a presumption that resources defined will be worked; and define Minerals Consultation Areas based on these Minerals Safeguard Areas.

The British Geological Survey's 'Guide to Minerals Safeguarding in England' (October 2007) provides the following advice:

"A district DPD could include policies that set out the general approach the district will take when determining proposals for non minerals development within or close to MSAs or existing mineral workings. Such policies should acknowledge the procedures for consulting the MPA on the existence and extent of mineral resources present and considering the case for prior extraction of mineral where appropriate."

In June 2009, the British Geological Survey (BGS) completed a piece of work to delineate Warwickshire County Council's Mineral Safeguarding Areas (MSAs)/Minerals Consultation Areas (MCAs). The BGS identified the extent of individual mineral resources in Warwickshire and these, in turn, were used to develop safeguard areas for each mineral. WCC would suggest that these MSAs/MCAs are either identified on WDC proposals maps and/or a link is provided in the Local Plan to Warwickshire's Minerals Safeguarding webpages. This will help to ensure that minerals implications are taken into account as part of decision making for District planning applications.

We would request that where certain applications may potentially sterilise minerals deposits within an MSA, the District Council consults the County Council. If the County Council concludes that minerals reserves may be sterilised, the applicant may be required to submit a Minerals Survey to establish whether the reserve is economically viable. In some cases, the County Council may insist that prior extraction of the minerals is undertaken prior to the non-mineral development being carried out. It is considered that the inclusion of this procedural information will improve the effectiveness and deliverability of the policy.

In assessing the Preferred Options, it is noted that there appear to be sand and gravel deposits under the 'Whitnash East', 'West of Europa Way' and 'South of Gallows Hill' sites - see attached map (appendix A). It would be beneficial if a minerals survey was undertaken by the developer to determine the quality and depth of the resource and to establish the feasibility of prior extraction.

Waste
Policies for the development of major residential development sites should include waste management issues as part of the overall design of larger residential/retail developments. For example, provision for waste recycling/composting on site will ensure that waste is managed in accordance with the principles of proximity, self-sufficiency and the Waste Hierarchy. Furthermore, there is a need to provide adequate waste facilities for flats and apartments - see WRAP's 'Good Practice Guidance - recycling for flats' WRAP, available at http://www.wrap.org.uk/content/recycling-collections-flats.

It should also be noted that policy CS8 of the Warwickshire Waste Core Strategy (due for Submission in September 2012) seeks to safeguard existing waste management sites. At this stage, it is considered that none of the preferred option sites are likely to prevent or unreasonably restrict any waste sites. However, if necessary the Council may object to other proposals which may sterilise important waste facilities (e.g. those delivering significant waste management capacity to meet the County's landfill diversion targets). To prevent this, WCC intends to supply each District/Borough Council with its latest waste site information, possibly in GIS format, so that the County Council can be consulted on any proposals within reasonable proximity (e.g. 250m) of existing waste management facilities.

Customer Services/One Front Door/services that support communities and families.

The County Council is open to co-location, co-access, and co-servicing of support services including support for the elderly, vulnerable adults, and families , however, these services should be located or are accessible to communities they serve. Further for new development these key services should evolve with the phasing for large developments. One solution could be providing lay-bys with " electric hook up points" for mobile services (including a mobile shops) this would build up sufficient demand before most of the dwellings are built. Consequently, make communities and developments sustainable.

Transport and Planning matters
The key transport strategies are contained in Warwickshire Local Transport Plan 2011-2016. The County Council is already working with the District Council to assess the transport impacts of various development scenarios as part of our Strategic Transport Assessment work and will be responding directly on this and other relevant transport matters. The key matters are access and sustainability of the pattern of development for homes and jobs.

We support the direction and economic strategy of the Local Plan and we need to undertake further work on some key matters ie transport, archaeology and ecology matters.

I strongly condemn any proposal of cycling in Abbey Fields. With the total absence of anything like a park keeper or a policeman these days the lunatic fringe of society and yobs will just abuse the place, ruin the already limited tranquillity and potentially cause unnecessary serious injury.

I write in support of cycling being allowed through Abbey Fields to join up the current cycle routes at either side of the park. I recognise that this needs to be managed properly, but should be a positive improvement In taking cyclists off the roads, many who will be families with young children.

I understand that there has been a proposal to create a cycle path through Abbey Fields.

My family have a number of concerns:

1. Small children - the proposed route will attract more cyclists into the park in an area where there are small children playing and running freely. At present the WDC web site markets Abbey Fields as a no-cylcing zone - such a proposal has the potential to change the whole character of the Fields and the free play enjoyment & safety of small children.

2. Monitoring - anyone who uses the main road between Kenilworth & Coventry will know that not all cyclists use the cycle pathways, and for those who do not all move to the road when the path ends but remain on the pedestrian pathway. This raises the concern of individuals keeping to designated pathways, or whether we would witness the same disregard by some cyclists for walkers, once more raising concerns for safety. As residents of High Street Kenilworth we already have some cyclists using the 'no cycling pathway' down to the Church from the High Street - they do not show respect for any walkers or for members of the congreation outside the church.

3. Landscape - Given the visibility in some areas of the Fields and the gradient of the proposed route the presence of cyclists will inevitably lead to accidents and injury for cyclists and non-cyclists alike.

4. Aesthetics - Abbey fields is an area of natural beauty attracting many visitors & revenue to the area. To carve up a new pathway / extend an existing pathway will leave a permenent scar on the fields and potentially turn it into a 'rat run'.

5. Parking - presumably should this go ahead parking bays for bikes will be required, potentially taking more space from an already congested car park by St Nicolas Church.

6. Cost - The monies required to fund this to be re-directed into funding an extension of cycle pathways adjacent to pavements running up Rosemary Hill.

While the idea of extending cycling routes is commendable, we would urge that alternative, road linked, routes are investigated.

GREEN BELT - National Planning Policy Framework requires "very special circumstances"
The Green Belt covers only 13% of the area of England. This preferred plan is for 10,800 dwellings and 43% of land used will be green belt. How can this be justified when there is still plenty of white field land available south of Leamington? Presumably the "very special circumstances" come into effect when the 57% development on white fields has been used. This growth is scheduled to take 15 years at a constant annual rate of 555 houses per year. 57% of 15 is 8.55. So it will be eight and a half years before these "very special circumstances" (ie. white field sites are filled and green belt is needed) comes into effect. By then another plan will have been made!
I disagree strongly with any relaxation of the green belt which is there to stop conurbations merging. This plan will leave less than 1 1/2 miles between Kenilworth and Leamington.
Why does Kenilworth need to expand? It has always been in the past a much smaller town than Leamington and Warwick and mushroomed massively in the 1960s, and also in the 1980s when Knights Meadow estate was built. Why should we let this happen again to keep pace with the other towns? Councillors tell me that the Green Belt is strangling Kenilworth. This is precisely its purpose. We should be grateful that our town has these safeguards in place to protect it.
770 dwellings equates to about 1770 people which is almost a 10% increase in Kenilworth's population in an area which is quite detached from Kenilworth and is not likely to make its inhabitants feel a part of the community. The town centre should be in the middle of the town. Far too much development is on the east side and it should now be the turn of the west, if the Green Belt has to be sacrificed, where there is no risk of it merging with other towns and which would be a short walk to the centre of town without cars needing to be used.
THICKTHORN.
How was the Thickthorn site chosen?
Surely not because it abuts the A46 which is noisy both day and night. Was a site visit made to see just how noisy it will be for all the inhabitants? Were decibel readings taken at various points up the hill to ascertain the suitability of this site? The noise is particularly bad on a hot sunny day with the prevailing south-west wind. What about HS2? The boom will be heard at Thickthorn as it passes 18 times per hour in both directions on the EAST side? This estate will be on the flight path of Coventry International Airport where there is no restriction on night flights and jets scream over the proposed development land and at a very low level on their way to Baginton as they have to avoid the Birmingham flight path, (which is also noisy) as this is the crossover point of the two flight paths.
It would be a very selfish decision to commit people to a life of misery with all this noise even through double glazing. This is not the same scenario as the Woodloes where houses abut the road, which at that point is 4 lanes instead of 6, where there the A46 is the other side of the natural sound barrier of Primrose Hill. At Thickthorn noise is impossible to stop owing to the contours of the land which is a basin causing the noise to be trapped and sweep up the hill towards dwellings. The noise is incessant both day and night. It is an ideal location for the sports fields which are already there, where people can go away at the end and not have to endure it 24 hours a day. Office buildings along it will not dissipate the sound.
TRAFFIC
Having 1200 cars discharging from the estate each morning will be a nightmare and cause even longer queues up Birches Lane and into Glasshouse Lane. It will be a worse effect than the horse fair there every day of the year. Updating St Johns gyratory presumably means traffic lights which will cause long tailbacks into the town centre as they have priority under the give-way scheme.
I cannot understand how a dual carriageway between Kenilworth and Leamington will help as all the traffic will have to funnel in at either end and will just result in 4 lanes of slow moving traffic instead of 2. Creation of bus lanes will in any case limit traffic flow to one lane in each direction to speed up a bus every 10 minutes if you're lucky, and nothing will be gained in terms of traffic build up.
There are no points wide enough along Glasshouse Lane for the junction of a spine road, as the corner with Rocky Lane is on a dangerous bend. In any case, Glasshouse Lane is a unique and attractive feature of 1930s period landscaping, a Kenilworth gem, which should be preserved and which junctions along its length will destroy.
NUMBERS
Where do these figures come from for 10,800 houses?
It is in the interest of the District Council to have as many new houses as possible, as they receive 6 times the Council Tax from the New Homes Bonus Scheme for every new dwelling completed and more than that if they are affordable housing.
This plan is not led by suitability but the interest of landowners to sell off their land for housing.
These are not sufficient grounds for this massive increase in population concentrated in a small area as the plans make little use of rural area development. Lots of villages need regenerating. Radford Semele has had no growth since the 1960s and has a school in place already. It has good transport links to the M40, Fosse Way and Leamington Station and IT IS IN A WHITE FIELD ZONE. If such a large number are needed, they should be put in the South Leamington area on white field sites as Leamington already has all the amenities (parks, department stores, nightclubs, cinemas) jobs to support it. This is a Warwick District Council plan not a Kenilworth plan and there are plenty of other places where housing could be built.

CONCLUSION
Population figures should be challenged.
Green belt should be protected.
Consideration of the effect on the HEALTH of people living alongside a motorway with NOISE and POOR AIR QUALITY owing to constant fumes and directly under a flight path with NOISE due to very low flying aircraft should be made.
DISTRICT COUNCIL
Having looked extensively at your website, I note that according to feedback from the public there is low satisfaction with the way you communicate with people.
I note that you are consulting the people of Kenilworth on Friday 20th July in Kenilworth Library. As the consultation is of 2 months duration, why do you choose to liaise with the people of this town just 7 days before the cut off date for written responses?
Every household in the town should have been notified by post (why not with the Electoral Role info) and notices should have been placed in relevant places about the town as happens for a single house alteration. Instead, the local press is left to do the job for you. You are reaching a small minority. Ask the KWN for circulation figures.
In order to improve this during the further consultation in March / April, I hope you that you will consult everyone by means of a written communication to every household.

I wish to place on record my objections to cycling in Abbey Fields, Kenilworth, which I consider to be foolhardy, dangerous and lacking in consideration of the majority of Kenilworth residents who wish to retain the Fields in their present state.
Currently By Laws exist that prevent cycling within Abbey Fields which enable all the general public to move freely in a safe area. It is the largest open space in Kenilworth and attracts people who can enjoy being able to have their children run around in safety; adults and pensioners to take daily walks at their own pace and dog owners to let their pets have freedom. Many walkers use the Fields for regular exercise, possibly far more than the number of cyclists. Cyclists would endanger the walking public particularly as their speed could not be safely policed.
The act of removing the By law preventing cycling along the proposed route would by inference mean that ALL the footpaths would become cycle ways, which again could not be policed. All the footpaths would have to improved to meet the minimum 2.5m width. By doing so two of the footpaths would become particularly dangerous:- from
High St to the St.Nicholas cemetery and from the War Memorial down to the Swimming Pool.
Both these footpaths are extensively used by pedestrians.
It would also make the Fields an open play ground for all types of off-road cyclist;
again increasing the danger to users of the Fields.
Bridge Street entrance to Swimming Pool. This is a controlled vehicle access enabling service and disabled motorists access at a speed of 5mph. to the Swimming Pool . At its road junction it is also the vehicle access/exit into the heavily used St Nicholas car park Entering the car park is already both difficult with pedestrians using both the Bridge St. footpath and the Swimming Pool roadway.
The meadows on both sides of the Bridge St entrance and road to the Swimming Pool are used annually as a Fair ground. It is very popular and the fairground stalls encroach to the roadway and have covered cables running across it.
Approach to the Swimming Pool. This is a particularly heavily used area by parents and children using the Children's Play area with the roadway splitting the play ground from the café and swimming pool. There is no way that this area could be safely policed to ensure that children were not put in danger. It could well become an even greater issue as there are proposals to improve the Play area thereby increasing its popularity and use. At present children are quite safe to walk/run to the café to purchase drinks or to use the public toilets etc... this would be denied them if a cycle path was allowed. During the Summer months the disabled car park at the side of the Swimming Pool is used for bands providing concerts during the afternoon... the band would be separated from their audience by the cycleway.
The Swimming Pool is the focal point of Abbey Fields with all the footpaths converging to it. Therefore there is the highest concentration of people in this area.
Bird Feeding Station. At the end of the Swimming Pool building are two blind corners where the footpath is too narrow, sometimes even for pushchairs and prams. Again this is too dangerous for consideration as a cycle way and could become a hotspot for provocation between pedestrians and cyclists. The Feeding Station is popular throughout the year with children and adults wishing to feed the ducks and swans, becoming very congested at weekends and holiday times. There is insufficient room to extend the pathway to make it safe.
It should be recognised that this part of Abbey Fields is a Nature Reserve approved by Warwickshire County Council.
Footbridge. Directly past the Feeding station the footbridge is itself not wide enough for two prams to pass each other. Another probable area of provocation.
Footpath to Castle Rd. Despite other comments this narrow footpath is extensively used at all times of the day not only by walkers but also adults with children in prams and pushchairs, dog walkers and as a route to and from the town centre, avoiding the steep incline up to the War Memorial. The pathway would have to be extended to 2.5m in width which would require approval from English Heritage
All of Abbey Fields has Ancient Monument status from English Heritage who would have to approve any alterations to paths.
Estimated usage. I know from experience that Abbey Fields is widely used by many people of all ages. No quantifiable number of cyclists has been established to warrant consideration, let alone sanction, of cycling. Nor have the Kenilworth residents been directly asked whether they approve or not.
Annual events. As mentioned previously, Abbey Fields is central to leisure activities held each year by Kenilworth. In addition to the annual Fair events in the Fields include Kenilworth Festival, The Lions Show, Town Carnival, Peace Festival plus regular band concerts. All would impact adversely with any cycling through the Fields.
I believe that the proposal for a cycle route in Abbey Fields is an insidious move. It would be far more suitable to route the cyclists round the outskirts of Kenilworth and not prejudice the tranquility and peace of Abbey Fields. What is far more important is that cycles could be a danger to children, people and dogs. It should not be a thoroughfare.
Abbey Fields is a protected treasure in our Town; an area with many features and facilities that do not lend themselves to being used as a short cut for cyclists.
It is not merely a "park" . It has far greater significance than that. It is a nature
reserve ; has a wealth of specie trees; many varieties of wildlife including most
native English bats; animals and insects; a newly planted Wild Flower Meadow.
It is the breathing space for many residents and visitors who do not have that facility at home.
A playground for the young and not so young; tranquility and recreation for the elderly.
Unique in its setting and well balanced between the people who enjoy it and the
flora and fauna that make it such a special place.
Alternative routes. There is no need for a cycle way to go through Abbey Fields. Various alternatives are available , without any cost to the taxpayer, among others one from Station Rd via Hyde Rd onto Albion St and Rosemary Hill. Then along Abbey Hill and into Forrest Rd/ Castle Rd.

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