PO1 Preferred Level Of Growth

In summary we agree with the option for the Local Authority to go for a moderate growth. There may be evidence to suggest that higher growth is required but in these challenging economic times and the practical and political pressure the Local authority will be under in making this decision, we believe the moderate growth option is a more realistic and such a pragmatic approach is likely to be achievable.

PO2 Community Infrastructure Levy

We support the idea to bring in a CIL.
One item that is missing from the document is any indication towards New Homes Bonus. This is something we would support as a revenue stream and serve to reinforce your support for Affordable Homes (paid on non s106 schemes only). Again the NHB could be shown to assist in the provision for extra care (under PO5)

PO3 Broad Location of Growth

We support the Preferred option for Growth.

PO4 Distribution of Sites for Housing

We support the establishment of new boundaries. RSL's would like to be involved in discussions with Parish Councils from an early start to dispel the myths around affordable housing and this could assist the provision of housing in these areas.

PO5 Affordable Housing

We agree with the 40% affordable housing on new residential developments with the exception where the scheme is to be delivered as a 100% affordable housing scheme, in these cases the properties can be dealt with under a separate planning condition .
We agree with the housing being held in perpetuity but we would draw attention for a balance. In many cases RSL's will need to show a level of asset churn. The asset however can be ring-fenced to be used soley for the provision of future affordable housing in the district.

In rural terms we support a certain level of market housing but it should be on a case by case basis given the likely high land and sales values generated in many of the District's villages

There is no reference to new Affordable rents. The document does refer to affordability however, but with no mention of the level of affordable rents and with many areas of WDC the level of rents can vary greatly within a 1 mile radius (Micro Markets) Therefore we would recommend some primary data in the document to support your arguments.

PO6 Mixed Communities & Wide Choice Housing

Employment is very high on everyone's agenda currently and there are many threads that tie housing/ construction to this. There are opportunities through apprentices and other work opportunities that can be brought about by new housing and this could be a opportunity to ensure this happens on future sites.

Homes for older people and the link to the Extra Care rented opportunities will remain difficult to deliver with the decline in grant funding form the HCA, & Warwickshire CC .

PO16 Greenbelt

Again we support the option for Green Belt but we would like to be involved in any discussions with parish councils or other interested parties to outline what is affordable housing and dispel any myths.

We represent the West Midlands HARP Planning Consortium which includes all the leading Housing
Association Registered Providers (HARPs) across the West Midlands. Our client's principal concerns are
to optimise the provision of social / affordable housing and to ensure the evolution and preparation of
consistent policies throughout the region.
PO1: Preferred Level of Growth
The preferred level of growth identified would fail to meet even the basic level of affordable housing need
identified in the 2012 SHMA of 698 affordable dwellings per annum. For this reason Preferred Option 1 is
not supported. Our previous representations to the 'Helping Shape the District' consultation indicated that
the preferred options should be based on a full, robust evidence base, and the Council now has this to
rely upon.
The decision to bring forward a very basic level of housing growth across the District is likely to result in a
much lower level of affordable housing being brought forward over the Plan period than is necessary due
to significant viability constraints on development. The SHMA notes:
"Given the viability of residential development within the District and the availability of funding for
affordable housing, it is unrealistic to assume that all housing needs can be met. ... the supply of
affordable housing is likely to fall short of identified needs. The Council should look to maximise provision
of affordable housing where possible, including in working proactively with developing RPs ...." [Our
emphasis]
The implications of providing just 4,320 affordable dwellings over the lifetime of the plan needs to be
considered as part of the wider housing target. This reduction in the general housing target, and
subsequent reduction in the deliverability of affordable dwellings is very significant and will have a further
detrimental impact on housing waiting lists and affordability across the district. A single affordable
dwelling was completed in the monitoring period 2010/2011. With significant uncertainty as to general
development viability and the Affordable Housing Viability Assessment indicating variable viability across
the district, it is important for the Council allow sufficient flexibility in the housing land supply target to
secure affordable housing.
The Local Plan should be aiming for a much higher figure to take account of the need not only for
affordable housing delivery, but also to plan for economic growth across the district. We recommend that
a minimum target should be that set out in the SHMA, of 11,900 dwellings; the SHLAA indicates a more
substantial 13,385 dwelling capacity across the District to 2029 which could accommodate that minimum
target.
Unit 2 Eclipse Office Park Staple Hill Bristol BS16 5EL
T: 0117 956 1916 E: all@tetlow-king.co.uk
F: 0117 970 1293 W: www.tetlow-king.co.uk
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PO2: Community Infrastructure Levy
We support the Council's intention to bring forward CIL.
PO3: Broad Location of Growth
We support the Preferred Option for growth. We do however recommend that the Council clarify that the
hierarchy will allow for development at smaller villages. The NPPF states:
"In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities
should be responsive to local circumstances and plan housing development to reflect local needs,
particularly for affordable housing, including through rural exception sites where appropriate. Local
planning authorities should in particular consider whether allowing some market housing would facilitate
the provision of significant additional affordable housing to meet local needs.
To promote sustainable development in rural areas, housing should be located where it will enhance or
maintain the vitality of rural communities. For example, where there are groups of smaller settlements,
development in one village may support services in a village nearby." (NPPF, paragraphs 54 and 55)
By the use of this minor textual change, the Council will signal flexibility to development at villages with
housing need but where there are no infill opportunities. As shown above, this approach is in line with the
NPPF and the Council's own commitment to meeting housing need across the district. The Council can
control the extent of development at rural villages by requiring this to be proportionate in scale to the
settlement size and housing need.
PO4: Distribution of Sites for Housing
B. Category 1 and 2 Villages
We support the establishment of new village boundaries to enable development to come forward at rural
villages. In addition to discussion with Parish Councils, Warwick District Council should also ensure
consultation with local landowners and developers, including HARPs, to support development in the most
sustainable locations. We support the removal of land within village envelopes from the Green Belt.
D. Development on Greenfield Land
We support the proviso that affordable housing development will be permitted on greenfield land.
PO5: Affordable Housing
A. Affordable Housing on Housing Development Sites
We support the Council's intention to seek 40% affordable housing delivery from new residential
developments, as this is supported by the Affordable Housing Viability Report. The thresholds for urban
and rural areas are also supported, as this strikes the right balance between seeking affordable housing
from a high number of developments, whilst still making allowance for viability considerations.
We note the Council's intention to require affordable housing be retained in perpetuity. The NPPF
requires only that affordable housing delivered on rural exception sites be subject to this condition and we
advise therefore that the Council adopt this approach.
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B. Affordable Housing on Rural Exception Sites
As per our comments above, we recommend a word change to state that rural exception schemes will be
permitted at village locations where housing development would not normally be permitted. This would
support the provisions already set out under this Preferred Option.
We strongly support the allowance of some market housing under this Preferred Option to support the
delivery of affordable housing. This is in line with NPPF definition of rural exception sites which states:
"Small numbers of market homes may be allowed at the local authority's discretion, for example where
essential to enable the delivery of affordable units without grant funding."
We are however concerned by the imposition of a 30% cap on the level of market housing to be permitted
to cross-subsidise affordable housing delivery. The reason for the level of the cap is not explained in the
justification section, nor is it discussed in the Affordable Housing Viability Report. It would be useful for
the Council to set out its reasoning for the cap figure as without this the policy is unjustified.
PO6: Mixed Communities & Wide Choice of Housing
B. Lifetime Homes
Whilst we support the Council's intention to seek a proportion of new residential developments as
meeting the Lifetime Home standards, a formal policy in the next draft of the Local Plan should recognise
the potential for those standards to change, as new standards could be implemented at a later date,
rendering the Local Plan outdated and ineffective.
C. Homes for Older People
We strongly support the Preferred Option for all strategic sites to include an element of Extra Care
housing. We also support the Council's intention to make allowance for Retirement Villages and
Continuing Care Retirement Communities (CCRCs). Locational factors, such as proximity to local shops
and public transport, should not be as strict as for general market housing, as Retirement Villages and
CCRCs typically provide a suite of on-site facilities which reduce the need for site residents to access
local services and facilities, as well as having a nil requirement for services such as local schools.
PO16: Green Belt
We support the Preferred Option for the Green Belt. The requirement however for affordable housing to
be brought forward "through a Neighbourhood Plan" removes the ability for development to be brought
forward on an ad hoc basis - for example where a community does not wish, or have the capacity, to
develop a Neighbourhood Plan. We recommend instead that a formal policy sets out the ability for
affordable housing to be brought forward, including through a Neighbourhood Plan, or otherwise where
there is evidence of need.

Your new plan to build on green belt land is undoubtedly the thin end of a wedge. I know it is inspired by needs of new housing, financial greed and other incentives but this is clearly a travesty. Green belt land has served the country well for more than half a century in stopping urban sprawl and increasing commuter issues.
Brown field sites are a plenty and while financially less appealing are surely a better option both for existing infrastructure and for the long term environment.
This new plan makes no sense and is a u turn on previous policies

The preferred sites surely must be to the south of Warwick and Leamington as these do not encroach upon green belt.

This is made very clear on your map which shows the various options.

Building to the south would mean that residents would have more direct access to the road network, including the motorway, and to the various community facilities and would breathe more life into those areas.

Going north makes the danger of a Kenilworth-Leamington conurbation likely in the future - which seems to be most undesirable - as is the destruction of green belt. Warwick is a victim of high volume traffic as it is and building to the north of the town would encourage more traffic to try to drive through causing likely chaos.

The south with its clear access to the motorway and to the shopping etc is the preferred site.

I wish to register my objections to the Preferred Options of the New Local Plan, which have come as a complete shock to me when the previous plan seemed so eminently sensible! Although I'm not a constituent of Jeremy Wright MP I support much of what he has written in this weeks' Leamington Courier. Why has development been moved from areas adjacent to Warwick Gates to Green Belt land north of Warwick and Leamington? How exactly have the projections for the numbers of houses needed been arrived at? They do not seem to have paid any attention to the consultations in which 58% of respondents said that the lower growth option was preferable.

I wish in particular to comment about my own local area and the proposal to build 180 houses at Loes Farm. They would be built on the hill or ridgeline, which is what anyone entering Warwick from the north along the Coventry Road sees. This is against the NPPF, which says that the historic character of our towns should be preserved. The last plan stated that the area was "unsuitable for development' and I would like to know what has changed! I understand that the Local Plan of 1949 refers to the undulating land as a "beautiful buffer" for Warwick.

Woodloes Lane, with its view of open fields has always been a favourite walk of mine since moving onto the estate in 1978. This is because of the clearly very old hedgerow, which runs either side of the lane. This habitat supports and encourages a wide variety of wildlife. I expect a new full biodiversity assessment would be needed but I believe that there are for example 280 species of moths, including one previously thought to be extinct; 16 species of butterfly, great crested newts and at least 2 species of bat. The Millennium Way runs up the lane and there are a wide variety of birds living in the area. Green woodpeckers can be seen feeding on the ants in the field and I'm told that there are rare yellow ants living there. Aren't areas of such great biodiversity meant to be safeguarded in the National Policy Planning Framework? Isn't there also legislation which protects ancient hedgerows?

I understand that access to the Loes Farm site is proposed via Primrose Hill, which will cut straight across the old hedgerow I've mentioned above. What consideration has been given to the additional traffic the new estate will generate onto Primrose Hill and out to the Birmingham and Coventry Roads? Traffic at the roundabouts off the estate is congested already at peak times. Whether a roundabout or a new junction is built traffic hazards will obviously increase. The junction with Woodloes Avenue South is notorious for accidents already and this could be another such problem. Presumably this is why a police presence with a "speed trap" has been needed just where the access is proposed.

I refer again to Jeremy Wright's "Westminster Briefing" column where he identifies the councils' failure to consider other sites first whether brownfield or those previously identified for development south of the two towns. I believe these must be properly considered first before any incursion is made into Green Belt land. For this reason I'm not opposed to the eventual development of the former Ridgeway school site and equally near to Woodloes.

In conclusion, I believe there are many good reasons not to include the Loes Farm site in the final plan.

GENERAL OBSERVATIONS

1. There is far too much development in Warwick. 40% of the proposed development is within or on the boundaries of Warwick town. This is disproportionate, and calling the developments 'garden suburbs' does not make it any more acceptable.

2. Warwick has already had two large developments; Chase Meadow and Warwick Gates. Why is it selected to take the bulk of the next phase of development? Other areas, Kenilworth for example, have been left relatively free of development, yet is hoped that many of the new employment opportunities will be created in Coventry, which is much nearer to Kenilworth.

3. Warwick is a very congested town because of its old streets and the necessity to cross the river by bridge. There is little that can be done to relieve that. Wider roads in the areas imediately surrounding the town may move traffic more quickly over a short distance , but the fact remains that Warwich snarls up on a daily basis already and short of demolishing old, existing buildings to accommmodate increased traffic, Warwick will become a traffic nightmare.

4. I have recently become aware of the term 'green wedges' It means, I assume, that the green belt has had chunks taken out of it. I accept that not all green belt land can be kept sacrosanct, but I object to green belt land being used before brown belt land has been exhausted. It is disingenuous to say that all the land is potentially available to developers and they can decide which bit to develop. Which would you choose? It is the green belt that will be gobbled up first. If the current plans go ahead there will be no visible break in development between Warwick, Leamington and Whitnash.....not even a green wedge.

5. The planning document admits that there is already a problem of air quality in Warwick. In some places pollution levels are dangerous to health. The planning document also says that there is little possibility of reducing the problem because of the road layouts and the old buildings. Why make it worse?



COMMENTS ON SPECIFIC DETAILS


6. I have already mentioned air quality. My particular area of concern is round ST John's where it is accepted there is a serious problem. In that imediate area there is a Children' Centre and housing for old people, both of whom are particulary vulnerable to air pollution. You state in your document that little can be done to improve the situatio, yet you propose to build at Loes Farm and Guy's Cliffe. It is likely that traffic from these two areas, plus the increased traffic from other developments around Warwick, will only add to congestion on the Coventry Road junction further endangering the health of the very young and the old.

7. Loes farm has been suggested for development before. It has been surveyed and found to be rich in biodiversity and to have ancient ridge and furrow markings. It is a site of botanical and historical interest, and as such should not be considered for development.

8. Guys Cliffe is another site of historical interest surrounded by woodland and in an elevated position. Development here would impact adversly on a site which is rich in local legend and history. Because of the elevation of the land and the proposed new road it would also be highly visible and add to the traffic problems and air pollution mentioned previously.

9. Warwick's crown jewel is the Castle. Warwick's most iconic view is of the castle from the bridge over the Avon; an old bridge, built to accommodate the traffic of a small market town over a hundred years ago. Will it withstand the onslaught of all the cars that will come into Warwick from its vasly increased size? The beauty of Warwick is that it has a river in its heart. That is a geographical feature which no planner can alter. But planners can ignore it, and this local Plan seems to have done just that.

And finally I appreciate that Warwick district is obliged to come up with a plan that Central Government will accept as sustainable, but just look at the map of preferred sites on pages 5 and 6 of your booklet. Warwick town is being asked to accept too much of the proposed development.

I am writing to oppose the District Council's plans to develop on Green Belt Land as shown in their 2012 Preferred Options booklet. Nothing has changed since the 2009 Core Strategy, so there cannot be any justification for these fundamental changes now.

I strongly object to this development as it is on Green Belt.
Green Belt was introduced to prevent this very activity

Now that the national economic model based on bank fraud has been found wanting and despite our inglorious politicians attempts to revive this model, it would be criminal to sacrifice any agricultural land where it was unnecessary or possible to do otherwise. In the not too distant future I foresee the need to provide a larger proportion of the nations food resources from our own land. Therefore the destruction of farmland to build houses should not be an option and I do not believe it to be necessary.

I have noted that the development at Portobello the site of the old Potterton facility is some way off being fully occupied, so I would question the need for large additional amounts of housing. Nor do I see any great draw pulling people into the area as I see that businesses are closing for example Pottertons and Fords have closed sites employing large numbers of people. Perhaps it would have been more appropriate to build houses on the old Ford site rather than another supermarket? The requirement for another supermarket is doubtful to say the least even though I personally have a preference for Morrisons. They do not create jobs as is often claimed, they just move them around.

Developers are always keen to build on green field and hence green belt sites because they can sell these properties at a premium and they can be easier to construct once permission is obtained. Decisions should not be made by democratically elected persons that favour the short term interests of the few at the expense of the long term interests of the many. However this frequently happens and it leaves the motives of the elected persons open to question or suspicion.

I therefore conclude that all plans involving incursions into the Green Belt or destruction of farmland should be rejected.

See attachment

GENERAL OBSERVATIONS

1. There is far too much development in Warwick. 40% of the proposed development is within or on the boundaries of Warwick town. This is disproportionate, and calling the developments 'garden suburbs' does not make it any more acceptable.

2. Warwick has already had two large developments; Chase Meadow and Warwick Gates. Why is it selected to take the bulk of the next phase of development? Other areas, Kenilworth for example, have been left relatively free of development, yet is hoped that many of the new employment opportunities will be created in Coventry, which is much nearer to Kenilworth.

3. Warwick is a very congested town because of its old streets and the necessity to cross the river by bridge. There is little that can be done to relieve that. Wider roads in the areas imediately surrounding the town may move traffic more quickly over a short distance , but the fact remains that Warwich snarls up on a daily basis already and short of demolishing old, existing buildings to accommmodate increased traffic, Warwick will become a traffic nightmare.

4. I have recently become aware of the term 'green wedges' It means, I assume, that the green belt has had chunks taken out of it. I accept that not all green belt land can be kept sacrosanct, but I object to green belt land being used before brown belt land has been exhausted. It is disingenuous to say that all the land is potentially available to developers and they can decide which bit to develop. Which would you choose? It is the green belt that will be gobbled up first. If the current plans go ahead there will be no visible break in development between Warwick, Leamington and Witnash.....not even a green wedge.

5. The planning document admits that there is already a problem of air quality in Warwick. In some places pollution levels are dangerous to health. The planning document also says that there is little possibility of reducing the problem because of the road layouts and the old buildings. Why make it worse?



COMMENTS ON SPECIFIC DETAILS


6. I have already mentioned air quality. My particular area of concern is round ST John's where it is accepted there is a serious problem. In that imediate area there is a Children' Centre and housing for old people, both of whom are particulary vulnerable to air pollution. You state in your document that little can be done to improve the situatio, yet you propose to build at Loes Farm and Guy's Cliffe. It is likely that traffic from these two areas, plus the increased traffic from other developments around Warwick, will only add to congestion on the Coventry Road junction further endangering the health of the very young and the old.

7. Loes farm has been suggested for development before. It has been surveyed and found to be rich in biodiversity and to have ancient ridge and furrow markings. It is a site of botanical and historical interest, and as such should not be considered for development.

8. Guys Cliffe is another site of historical interest surrounded by woodland and in an elevated position. Development here would impact adversly on a site which is rich in local legend and history. Because of the elevation of the land and the proposed new road it would also be highly visible and add to the traffic problems and air pollution mentioned previously.

9. Warwick's crown jewel is the Castle. Warwick's most iconic view is of the castle from the bridge over the Avon; an old bridge, built to accommodate the traffic of a small market town over a hundred years ago. Will it withstand the onslaught of all the cars that will come into Warwick from its vasly increased size? The beauty of Warwick is that it has a river in its heart. That is a geographical feature which no planner can alter. But planners can ignore it, and this local Plan seems to have done just that.

And finally,,,,I appreciate that Warwick district is obliged to come up with a plan that Central Government will accept as sustainable, but just look at the map of preferred sites on pages 5 and 6 of your booklet. Warwick town is being asked to accept too much of the proposed development.

We act on behalf of The Trustees of the F S Johnson 78NEL Settlement in respect of land at Station Lane, Lapworth, and welcome the opportunity to make representations on the Warwick Local Plan Preferred Options Development Plan Document (DPD). The extent of the land ownership is shown on the attached plan, and I am pleased to set out our formal representations below.
General Comments.
1. We support the principle for delivering 'Our Vision for the District' which proposes to meet the housing needs of the existing and future population of the District, including the identification of land for around 550 new homes per annum on new allocated sites, and proposing to distribute development across the District.
Comments on Specific Policies.
PO3: Broad Location of Growth
2. We support the Council's Preferred Option to distribute growth across the District, including within and / or on the edge of some villages, and to allow for a hierarchy of growth in the rural area to include a higher level of growth in those villages with a broad range of services and public transport to the towns.
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PO4: Distribution of Sites for Housing
3. We welcome and support the identification of Lapworth as a Category 1 village in recognition of the range of services and public transport links available within the settlement. We also support the explicit recognition given in the policy to the need to define the boundaries of village envelopes, and then to exclude land within those village envelopes from the green belt to enable development to take place.
4. We support the proposal to allocate land for 100 dwellings within Lapworth to be built and phased across the three phases of the Plan up to 2029.
5. The supporting text, in paragraph 7.36, confirms that in the case of category 1 and 2 villages which are currently 'washed over' within the green belt, it will be necessary to identify areas with potential for limited development and include it within a village envelope along with the built up area of the village. The boundary of the green belt would be adjusted accordingly around the village envelope.
6. In the case of Lapworth, the current village envelope reflects the largely linear nature of the settlement, and includes the development along the length of Station Lane and two small consolidated areas of development along the Old Warwick Road to either side of the railway bridge.
7. In our view, the opportunities to identify land that would be seen as a 'natural extension' of the current village envelope are limited, being constrained by the clear physical boundary provided by the railway line, the location of the Grand Union and Stratford Canals, the land at risk of flooding, and by the presence of attractive natural features such as wooded areas or trees.
8. However, our clients' land provides one of those limited opportunities where development could take place to provide the additional new housing that is needed whilst being seen as a natural extension of the village envelope.
9. The land is located within Station Lane, with a frontage to the eastern side of the road between an existing ribbon of houses to the south, which are already included within the village envelope, and a further ribbon of houses that are not currently within the envelope boundary. On the opposite, western side of the road, there is an established line of relatively closely packed houses, and the frontage is therefore seen within an urban context such that its inclusion within the envelope would be seen to be entirely
appropriate.
10. The land is very close to the village railway station and therefore provides a highly sustainable location for new residents who need not be dependent on the use of a private car to access employment opportunities or the higher order level of services and facilities available in town and city centres.
11. The land is unconstrained, being open and available to accommodate a range of development options. Field boundary hedging could be retained as part of any scheme of evelopment if desired, and access could be provided along the Station Lane frontage whilst retaining the two existing mature trees. Only the strip of land along the canal lies ithin the flood area, but this part of the site would be excluded from consideration in any event.
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12. The land is within the central part of the village, as defined by the current village envelope, rather than at the periphery and therefore the village school, post office and shops and services are all within easy walking distance.
13. The existing field boundaries would provide clear physical boundaries which could be utilised to define a robust and defensible boundary to the enlarged village envelope.
14. The land is one of only 3 gaps on the eastern side of Station Lane which lie outside the current village envelope, which otherwise embraces the development along both sides of the road. Whilst the land to the north of Meadow Lane is closest to the station, it is well treed and the removal of those trees as a consequence of development would result in the loss of an attractive feature in the Lane. Of the two remaining gaps, our clients' land is closer to the village centre than the land near Kingswood Close, enhancing its credentials for selection as a first-choice allocated housing site.
15. The extent of the land available lends itself to a variety of development options, including cul-de-sac development to mirror similar patterns of development elsewhere within the village, including Station Lane, without looking in any way out of place or out of character with the prevailing pattern and style of development within Station Lane, whilst providing for the housing needs of the village.
16. In short, our clients' land constitutes the best opportunity available within the village to achieve the housing requirement for Lapworth in a manner that meets the normal planning objectives for site selection whilst minimising the impact on the village environment. It is a 'natural' infill opportunity within a Lane that is largely characterised by linear development on both sides, and its development would be easily absorbed into the built fabric of the village without appearing, in any way, to look out of place or out of character. On that basis, and on behalf of our clients, we commend the merits of the site to the Council and request that it be favourably considered as a formal housing land allocation in the next stage of the plan preparation with the publication of the Draft Plan early in 2013.
17. We formally request that land forming part of our client's land holding at Station Lane be allocated for housing development and included within an expanded village envelope for Lapworth to accommodate the housing development proposed in this Preferred Options draft, as proposed in this submission.

I strongly object to the new proposals to develop the land between Leamington and Kenilworth.

Land is specifically designated as Green Belt to protect urban sprawl, encourage urban regeneration, stop towns from merging into each other and protect the countryside setting of historic towns and cities. This is why the Green Belt North of Leamington is so precious. It was established to stop Leamington and Kenilworth merging. I recognise and support the need to plan for the future housing and infrastructure needs of our communities, but I strongly oppose the current proposals to build on the Green Belt in between Leamington and Kenilworth because it is an important barrier to stop the two towns merging. It will also reduce the amount of green belt for us to enjoy.

PO1 Preferred level of growth
Representation: The Council is ignoring the opinion of the majority of respondents to the March 2011 questionnaire. Instead it is opting to use one isolated exceptional period of growth to substantiate its preference for unacceptably high development, apparently in the mistaken belief that housing growth would promote economic growth. We only need look at what has happened to the property market in Spain to see how catastrophic this would be.

Changes: The projection for growth should be based on a much lower, more balanced and reasonable expectation of level of growth.

PO3: Broad location of growth
Representation: It is essential to avoid development of Green Belt land, which affords essential open spaces and recreation opportunities where little else exists for public use nearby. Even if the highest level of projected growth were to be adopted, there is adequate land available elsewhere (eg in the Heathcote area) without encroaching on Green Belt land. The Council has, therefore, no grounds on which to justify the use of Green Belt land. Furthermore, to develop the areas of Green Belt land included in the proposals would necessitate a whole new infrastructure to the north of Leamington, which would in turn eat up even more Green Belt land - with disastrous consequences for one of our few remaining areas of untouched rural character, Old Milverton - whereas to the south the necessary infrastructure is already in place. If the Council it were to proceed with the current plans to decimate our countryside unnecessarily it would contravene national guidelines on the use of Green Belt, lose credibility, and as a consequence it would suffer severely in the next round of local elections.

Changes: I would urge the Council in the strongest possible terms to reverse its recommendation to build on Green Belt land, and to resist pressure from developers who are waiting poised to destroy our precious countryside. Instead I would urge the Council to concentrate development in logical, sensible locations, such as the Heathcote area.

I would like to strongly object to the proposed savage irresponsible planning for new housing in leamington and warwick. The area chosen is a massive sprawl and has huge impact on the local community. the sad thing is that the elected council who are there to protect the town are not doing their job.
It is an easy soft target instead of regeneration of unsightly areas dotted around the area which need help. The schools are underfunded the leisure facilities are a disgrace and nonoe has any money to buy a house.

It would not be workable without more infrastructure. Also there is plenty of brown field space to build. Has anyone thought about traffic??

Any large development should include "green channels" such as persists on the Woodloes park. As well as enabling rented apartments and local shops, to facilitate attractive areas to live in, a wide social mix and reduced environmental impact of shopping trips.

Warwick Town should encourage shops, whilst at the District level expansion by the BIG retailers should not be encouraged.

Existing wild places should be kept, particularly the river side walk between Warwick and Leamington. Potentially the path behind Tesco's could be enhanced from a mud track to a gravel path, similar to that in place where the path passes on the South side of the river by Edmondscote running track.

The plan has several areas shown as Confidential. This is clearly unhelpful from the point of view of commenting on specifics. If the land of or around Jephson Farm (between the river and Myton Road) is proposed to be developed this would be a significant diminution of amenity, and more "paving over of Warwick".

Whilst the plan proposes utilising the Regency Terrace opposite the old Council Courts in Warwick, there appears to be no plans for the Courts themselves? Surely there is scope for, say a Museum of Justice to keep these fine buildings and their historic interior, as well as adding to the vitality and attractiveness of Warwick.

Taking the sections in the plan:
P04: am surprised at just how far you plan to expand Warwick South! At this rate Warwick Castle Park will be a green island ? Assuming you are serious then it is behold that the Castle Park be available as an amenity, to enable the expanded population a proportional access to quality green space/park

P05: Affordable housing - agree.

P06/7/9/10/13/15: agree

P08: see earlier comment

P011: see earlier comment re: County Courts

P012: whilst agreeing climate change is real and has to be addressed, I'm unclear on what 20% reduction means. 20% of what ? will this be an annually revised value? (20% in year1, year2 = 20% of previous year etc, presuming each year is an improvement on the previous)

P014: use of public transport is as much a financial decision as access to it. If it's unaffordable to many it won't get used. By ignoring HS2, does that mean any costs associated with it WILL be met by Central Government then? I don't understand (and you don't explain) the risk of ignoring HS2 (or conversely) the risk/downside if you did plan for HS2.

See attachments

I would just like to let you know that I firmly object to your proposed local plan.

The temporary lifting of green belt law is ridiculous and cannot be justified.

It also appears not to have been thought out correctly .

Please register this email as a formal objection.

I object to your Proposed Preferred Option plans, because you could have adopted those prepared in 2009 for the Core Strategy Plan, which did not require the use of Precious Green Belt Land. These previous plans would have been much less expensive as they did not require the extravagance of a whole new infrastructure, which we do not need.

The Green Belt Land under consideration has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists. Such activities should be encouraged with so much focus being on the public taking regular outdoor exercise. In my opinion taking our dog for a 30 minute walk across this Green Belt land is much more rewarding than going to a gym in town.

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I am writing to oppose the District Council's plans to develop green belt land as part of the new Local Plan.

The Council's plans are somewhat alarming given the extent of the planned development on green belt land and also the extent of the planned development for Warwick, Kenilworth and Leamington overall. By 2029, Leamington and Warwick will be almost half as big again.
If this number of dwellings is really required then I feel there needs to be a new approach. You cannot continue to bolt on great big developments to towns, filling in all open countryside spaces without ultimately ending up with endless suburbia and everywhere becoming the same. This amount of new dwellings requires actual "new town" planning, not constant town extending.
It seems that Warwick District Council is taking on a huge proportion of the required development for Warwickshire as a whole and this is already a very over-populated area. There are less populated areas in the south of the county where potential new sites could be found with good transport access to the M40. Perhaps something on the lines of Hatton Park, but with some school and service infrastructure?
Once this level of development starts on the green belt around North Leamington, what is there to stop a complete in-fill? Old Milverton is in danger of becoming a scattering of period properties amongst a mass housing estate? This area is used by many for a variety of recreational purposes - walking, running, dog walking etc. Old Milverton and its surrounding rolling countryside is a rural idyll, not just for those of us who live here but for many residents of North Leamington. People need access to open space, countryside and fresh air; free of incessant traffic noise and concrete. Development of the scale shown in the plans will be detrimental to the quality of life for people in the area - people who have chosen to live in/close to a small town environment with easy access to countryside. We are running out of space!



Also of great concern is the lack of specific information. The Council has asked for the public to comment on their preferred options and all the plans available to view, do not show where the new roads, schools, supermarkets, park and rides etc. are going to be. It is all of these elements that will carve up at least half as much green belt again and change the character and landscape of the North of Leamington and Old Milverton forever. I feel that the Council is collecting public opinion based on information that is so vague it is to all intent and purposes, inaccurate.
In 2009 a plan was drawn up to make provision for more dwellings than are being considered in the current plan and there was no requirement for green belt land to be developed. What has changed? Certainly not the role of the green belt, the benefits the green belt offers to residents or the views of residents.
I don't believe that green belt land should be built on when there are other options, particularly when, after building so many homes on green belt, so much more green belt needs to be carved up for new roads and facilities. There are brown belt sites available in South Leamington with good roads and motorway access all in place and, once again, I believe that development of this size requires a whole new town planning, otherwise it will swamp our landscape in suburbia.
Please re-consider your plans and protect Leamington from becoming a faceless suburban sprawl.

"Very special circumstances" are required by The Government's National Planning Policy Framework for there to be development in the Green Belt and for the harm created to be outweighed by the benefit. That there is nowhere else for the homes to be built is cited as the special circumstances. The previous plan adopted by Warwick District Council (the "2009 Core Strategy") identified land South of Leamington for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure to support it. It is close to the M40 and there are existing employment opportunities South of Leamington. The reasons for not considering this now are stated that there is not as higher profit expected for the developers.

I'm afraid the era of the quick building buck has gone. A sustainable approach to land use needs to be taken in general in the UK due to the limitation of space as we are a small densely populated island. Other, much bigger countries such as France and the US seem to value their space more and come up with more innovative solutions: Sinking multi storey car parks below ground to use the space above for open space and mixed used accommodation, this would free up several acres of land in Leamington centre alone allowing houses to be built where existing infrastructure can be used or improved benefitting many. Higher density solutions need to be used. There are in the UK an appalling number of "empties" which are vacant properties that are not lived in as highlighted by Architect George Clarke in his recent TV series. We cannot continue with such short sightedness as to continue to eat up swathes of this beautiful countryside with more building and more rail (HS2) "solutions" these do not address the cause or provide a viable long term solution as there is no going back once the land has gone. Yes, these are more expensive solutions but what price do we put on our countryside and it's future, it is so much of what England is, that the opening ceremony of the Olympics is depicting it! The era of a quick buck has gone and developers need to know that we will not continue to develop and expand town boundaries.

Our towns of Leamington, Warwick & Kenilworth have suffered in the recession and as a result there are disused shops, disused pubs, disused business premises, disused garages, disused schools and many "out of town" poor quality shopping complexes with little footfall. A more innovative approach needs to be taken here - turning some of these premises into residential use, they already have a lot of the required infrastructure, if this is inappropriate turn them back in to green fields, woodlands and parks. We should protect the remaining greenbelt at all cost, it is a finite and incredibly valuable resource, we should not just delay proposals to build on it but simply never allow any development of it, it is not a sustainable solution and what legacy do that leave to our children and grandchildren.
A "buffer" of 1400 homes has been included in the number of houses Warwick District Council believes will be necessary between now and 2026. There is no need to include the land at Old Milverton and Blackdown in the proposals if this "buffer" is removed from the assumptions.

The group have over 700 members producing fresh and wholesome food for nearly 3000 people
We are reassured that the land proposed for development in the Preferred Options of the draft Local Plan does not encroach upon existing allotment sites. Access to the proposed sites is close, however, particularly approaching the Binswood allotments from Northumberland Road, and passing the Campion Hills allotments on Black Lane. At the former, there is a wetland field adjacent to the track leading to the allotment site which is highly likely to have European Crested Newts, which are a protected species. The hedgerow bordering the Black Lane allotments is ancient, and teeming with wildlife.
BLAST has been assured that allotment provision would be made for any new development of over 100 dwellings, yet this doesn't appear anywhere in the local plan. An increased local population will need to be fed and put more pressure on the existing food supply chains. The sharp increase in allotment interest has meant that many more individuals and families are coming to rely on allotment grown food as a budgetary necessity, physically and mentally healthy, enjoyable activity. Fruit, vegetables, foul, rabbits, goats and bees are all current on the local allotments. As important areas of wildlife habitat, rainwater and ground water collection and storage, allotments can also be sited to provide community facilities.
We are conscious that more houses are needed, however we are opposed to building on the Green Belt until sufficient evidence is shown that the available Brownfield sites, Council and non-Council owned, have been used in priority.
Paragraph 84 of the National Planning Policy Framework states that in reviewing Green Belt boundaries, authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages which are within the Green Belt, or toward locations beyond the outer Green Belt boundary.
7.19 of the Consultation Document states that the sustainability appraisal of the options showed that development which is not in the Green Belt has clear advantages such as the provision of sustainable transport options and reducing the need to travel at all. The carbon impact of increased vehicle travel will be huge. Therefore the proposed development of Green Belt land fails the review criteria of paragraph 84 of the Framework. Development of non-Green Belt land to the South of Leamington meets the review criteria both in offering more sustainable transport, services and utility options, and are existing predominantly Brownfield sites.
At Paragraph 80 of the Framework, five purposes of the Green Belt are indicated;
to check the unrestricted sprawl of large built up areas;
to prevent neighbouring towns merging into one another
to assist in safeguarding the country side from encroachment;
to preserve the setting and special character of historic town's; and
to assist in urban regeneration.
The Green Belts around the town were intended to conserve the open space between Leamington and Kenilworth, Radford Semele, Warwick and Coventry. Encroachment upon this land will negate this purpose, by reducing the buffer between them, leading the way to even further infringement. The reduction in the existing wildlife corridors will further lessen the opportunity of migration of species as the effects of climate change continue to effect flora and fauna. We need to protect and safeguard these areas in order to be provided for by them. At PO 10, Built Environment, the Council gives an objective 'to protect, enhance and link the natural environment', which these Green Belt developments will seriously compromise.
As part of the work on the BLAST response to the Options for Growth, a Bio-Diversity Survey was carried out by the Ecology Unit of Warwickshire County Council. Ecological diversity demonstrated at allotment sites by a survey showed the presence of the rare and protected European Crested Newt. Environmental surveys will need to be carried out to asses the impact and subsequent legality of these proposals.

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The group has 200 members and is locally active in promoting awareness about peak oil and climate change, and finding solutions.
We recognise that the Council is obliged to build more houses, however, we are concerned about the proposed encroachment upon Green Belt land when there is urban Brownfield land available which is vacant and / or derelict. These should be used as a priority and in preference to the Green Belt and Green Field options. WDC has not made a compelling case for the necessity for building on the Green Belt, which should be kept sacrosanct. Paragraph 84 of the National Planning Policy Framework states that in reviewing Green Belt boundaries, authorities should take account of the need to promote sustainable patterns of development. Sustainable development can be achieved by channelling development towards urban areas, avoiding the Green areas.
In 7.19 of the Consultation Document, the sustainability appraisal of the options showed that development which is not in the Green Belt or Green Field has clear advantages, such as the provision of sustainable transport options and reducing the need to travel. The carbon impact of increased vehicle travel from suburban developments will have a huge impact on local air and noise pollution levels and traffic congestion. Therefore the proposed developments fail the review criteria of paragraph 84 of the Framework. We would expect any new developments to accommodate cycle tracks with comprehensive connections to the town centres, and increased bike parking facilities. Development of vacant and derelict non-Green land in the South of Leamington and Warwick, and pockets within the town centres meets the review criteria both in offering more sustainable transport, services and utility options.
At Paragraph 80 of the Framework, five purposes of the Green Belt are indicated;
to check the unrestricted sprawl of large built up areas;
to prevent neighbouring towns merging into one another
to assist in safeguarding the country side from encroachment;
to preserve the setting and special character of historic town's; and
to assist in urban regeneration.
These considerations also apply to Green Field sites. Green areas around the towns conserve the open space between built up areas. Encroachment upon this land will negate this purpose, by reducing the buffer between them, leading the way to even further infringement. The reduction in the existing wildlife corridors will further lessen the opportunity of migration of species as the effects of climate change continue to effect flora and fauna. We need to protect and safeguard these areas in order to be provided for by them. At PO 10, Built Environment, the Council gives an objective 'to protect, enhance and link the natural environment', which these developments will seriously compromise. Bio-diversity studies need to be carried out to establish environmental impact on our flora and fauna, and to ensure that protected species are not endangered.

Transition Town Leamington is concerned about the environmental impacts of building works. Water supplies and ecological considerations need to be accommodated. In the Netherlands, all new developments need to ensure that water run off does not burden the drainage existing system, and that ground water is maintained. Planting trees is an important factor in retaining water in urban landscapes, thus helping to prevent flooding. Sewage can be dealt with in wet systems and reed beds, which increases biodiversity and reduces pollution. We note that some areas proposed for development, particularly south of Leamington and between Warwick and Leamington, are on flood plains, which is not wise.
The Garden suburb proposals do not address the rise in the price of oil as they encourage car dependency. Town planning needs to take into consideration climate change and the current energy crisis. Decreasing supplies of gas will also have a tremendous impact as prices rise, and alternatives for domestic use become more viable. If housing is built at a greater density, it will not encroach so much upon land, which can be used for growing food. The sites need to accommodate enclosed allotments, to prevent the possibility of future development.
The proposed increase of our local population will need food and services, and put more pressure on existing supply chains. Promotion and production of local energy and food sources needs to become a priority in the town planning department, which is not shown in the existing local plan. District heating systems and smallholdings would alleviate these issues.
Higher density will also allow for larger green wedges, which need to be instated to encourage communal areas for recreation and wildlife corridors.
We hope that these concerns will be considered useful in the re appraisal of the local plan.

Document scanned

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

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

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

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

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

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

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

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

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

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

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.

As attached