See attachments

Scanned representation

See attachments

1 INTRODUCTION
1.1 RPS Planning and Development (RPS) has been instructed by Lenco Investments (Lenco) to
prepare representations to the Warwick District Council New Local Plan Preferred Options
consultation document, in respect of their land interests at Baginton.
1.2 Warwick District Council (the Council) has proposed their Preferred Options in terms of housing
and economic growth and their vision for the district generally over the plan period to 2029.
These are currently being consulted upon until 27 July 2012.
1.3 RPS has made representations on behalf of Lenco to the previous stages of both the Warwick
Local Development Framework and the Coventry Core Strategy, to ensure a suitable approach is
taken to cross boundary development led growth.
1.4 Lenco's land interests at Baginton relate to a site which lies to the south of Baginton village
situated within the Green Belt, as shown at Appendix 1. It is important to note that Lenco has the
controlling interest in the majority of this land.
1.5 The site Lenco has interests in lies to the south of Baginton village, and. The site extends to
approximately 50ha and is in a sustainable location within easy access to Coventry City Centre,
close to the perimeter edge of the airport, with excellent cycle, pedestrian access to the
surrounding areas, and vehicular access to major transport links such as the A45 and A46.
1.6 Whilst the site falls within the local authority area of Warwick District it remains very close to
Coventry's administrative boundary, as well as the major sub regional employment base centred
on Coventry Airport. RPS is aware of the current proposals to expand Coventry Airport, and a housing development at Baginton would support these expansion plans.
1.7 The representations, therefore, address the need for housing growth within Warwick
administrative boundary and suggest that large-scale growth should be situated within close
proximity of employment development to ensure that people can live and work in close proximity.
Such proposals will support the Government's objectives to encourage economic growth in order
to revive the economy. Furthermore, these representations address the need for cross-boundary
growth and for full and proper cross-boundary working to be established between, Warwick,
Coventry and Nuneaton and Bedworth Boroughs as required by the Localism Act and NPPF.
1.8 The following chapter provides details about the site at Baginton, and our comments in response
to the Preferred Options document are provided in Chapter 3 and are set out in the same format
as the Council's response forms.
1.9 RPS are willing to meet with Planning Officers from Warwick District Council again concerning
Lenco's land interests and the New Local Plan process to discuss the potential of the site in
meeting local housing needs.
2 LAND SOUTH OF BAGINTON
2.1 The site Lenco has interests in extends to approximately 50ha and lies to the south of Bagington
village. The site is in a sustainable location close to Coventry City's boundary and the urban
area, and within easy access to the City Centre, and major transport links such as the A45 and
A46. The site, being close to the perimeter edge of the airport, with excellent cycle, pedestrian
and vehicular access, provides an exceptional opportunity for the provision of balanced housing
growth in the most sustainable manner.
Planning Policy
2.2 The Local Plan Preferred Options promotes 10,800 new dwellings within Warwick District for the
plan period up to 2029, at an annual delivery rate of 600 dwellings a year.
2.3 Evidence advanced by the West Midlands regional assembly for the West Midlands RSS
Examination in July 2009 from the Cambridge Centre for Housing and Planning Research,
based on 2006 ONS Household Projections and allowing for the economic downturn, concluded
that Warwick District's housing requirement between 2006 and 2026 was 18,200 dwellings at a
rate of 910 dwellings/year. Whilst the RSS is not longer in place, the evidence base is still to be
taken into account by Local Planning Authorities in preparing development plan documents.
2.4 The 2012 Strategic Housing Market Assessment indicates a requirement of 698 dwellings a year
to meet the affordable housing needs of the District in addition to market housing needs, which
is significantly higher than the level of housing currently being proposed by the Council.
2.5 The 2008 ONS Household Projections predicted an increase of 17,000 households between
2008 and 2028, at a rate of 850 dwellings a year. This represents an additional 150 dwellings a
year than is currently proposed through the Local Plan, which clearly will not meet the District's
identified need for new homes.
2.6 RPS is also aware that the 2012 SHLAA indicates that the District has a supply of deliverable
sites to provide 13,385 dwellings between 2014 and 2029, excluding windfalls, which is greater
than the numbers proposed within the Local Plan. Therefore the Council has identified the
ability to deliver housing sites at a higher annual rate than is currently proposed through the
Preferred Option.
2.7 RPS, on behalf of Lenco, therefore believes that the proposed figure of 10,800 new dwellings is
insufficient and that a higher level of growth would better reflect the projected population
increase and ensure that identified housing needs can be met, as suggested within the evidence
base. The Council cannot meet a higher target without locating housing on greenfield of Green
Belt land, and therefore should consider sustainable locations outside of the urban areas to
ensure housing needs can be appropriately met.
Cross-boundary Growth
2.8 The NPPF states that Local Planning Authorities have a 'duty to co-operate' on cross-boundary
planning issues, in particular for strategic priorities including housing, to meet development
needs which cannot be met solely within their own administrative boundaries.
6 rpsgroup.com
2.9 It has been recognised in Coventry's SHLAA assessment that the Council cannot meet their
housing targets on land within their administrative boundary alone. It is considered, therefore,
that Green Belt locations on the periphery of the urban area should be recognised as
appropriate locations for accommodating future growth.
2.10 The Green Belt south of Coventry was recognised through the Warwick Core Strategy process as
being an appropriate location for accommodating future growth of the City. Although the site is
within Warwick District it lies close to Coventry's administrative boundary, as well as the major
sub regional employment base centred on Coventry Airport.
Coventry Airport
2.11 Whilst both Coventry Airport's major sub regional employment base and Baginton village are
located outside of Coventry's local authority boundary, they are socially and economically
associated and physically adjoin the Coventry urban area. Residential development in this
location at Baginton could balance the existing significant employment base on the southern
side of Coventry, such as those around the airport at Stonebridge Trading Estate and
Middlemarch Business Park, both of which are within a very short distance of the site, as well as
the air freight and terminal employment opportunities.
2.12 RPS is also aware of the current Coventry and Warwickshire Gateway Scheme proposals
(Appendix 2) to expand Coventry Airport, and a housing development at Baginton would support
these expansion plans. RPS recommends that housing supply is focused in those areas where
there are important benefits to be gained where future economic growth is planned.
Site at Baginton
2.13 A residential-led mixed use development at Baginton could contribute sustainably to crossboundary
growth as required by the NPPF, and to meeting both Warwick District and Coventry
City's housing needs by delivering approximately 1,000 new homes either in isolation or as part
of the wider regeneration proposals for the area. The location of the site in relation to the
Gateway proposals is shown at Appendix 3.
2.14 Development at this location would also allow for new facilities and services to be provided,
making the best use of existing and proposed infrastructure. The site can be appropriately
phased over the Local Plan period to develop an available, suitable and deliverable urban
extension proposal.
2.15 The promotional document 'Land south of Baginton: A Sustainable Urban Extension' prepared in
2008 has previously been submitted to the Council and provides further details of how the site
could be sustainably developed.
2.16 In addition to this, extensive technical surveys in relation to flood risk, noise, ecology,
conservation and heritage, landscape, and highways have been undertaken of the site and
submitted to the Council, to demonstrate the site's suitability for a significant residential-led
development either in isolation or in connection with proposals for the wider area. An Air Quality
Assessment will also be undertaken to demonstrate the site's suitability for development.
2.17 RPS, therefore, considers that to help deliver greater sustainable development opportunities, it is
important that sufficient housing land comes forward in areas of proven market demand, such as on this Green Belt site to the south of Baginton, to contribute towards delivery of additional
dwellings and higher levels of growth to meet the needs of both Councils.
2.18 Responses to individual policies and topics within the Preferred Options consultation document
are included in the following chapter

Scanned Representation Attached.

Attached letter

Attached letter

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

See attachment.

See attachment.

attached

Whitnash Town Council respond to each of the Preferred Options in turn, and
make comments in respect of the Vision and Objectives.
Vision and Objectives
We broadly support the Vision and Objectives for the Local Plan, but reserve
our position on the level of housing supply, for the reasons set out in our
response to PO1 below.
PO1 - Level of Growth
In principle we agree that sufficient housing should be provided across the
District to meet future housing needs. However, we are unable to comment on
the proposed level of an average provision on 555 per annum on allocated
sites, plus windfalls, as housing numbers are an immensely technical issue.
Notwithstanding this, we are very concerned that Warwick District and
Coventry City Councils are failing to exercise their statutory Duty to Cooperate
under the Localism Act 2011 by not addressing the important matter
of cross-boundary housing need.
We are concerned that, in its current state, the proposed strategy will be
found to be "unsound" by the Inspector at the eventual Examination. This
could well result in additional housing provision having to be made, and this
would have clear implications for non-Green Belt areas, such as those
surrounding Whitnash.
We therefore urge the District Council to effectively exercise the Duty to Cooperate
with Coventry in respect of cross-boundary housing provision at this
WHITNASH TOWN COUNCIL
Franklin Road Town Clerk
Whitnash Mrs J A Mason
Warwickshire Email: jenny.mason@whitnashtowncouncil.gov.uk
CV31 2JH
Telephone and Fax: 01926 470394
2
stage, therefore preventing the danger of the Local Plan being found
"unsound" in the future and the Council having to consequently revise its
strategy and land allocations.
PO2 - Community Infrastructure Levy
We fully support the District Council in seeking to introduce a CIL scheme as
the Town Council considers it vital that full and appropriate infrastructure
provision is made, in advance of development wherever possible. It is
essential, however, that the funds raised are used to develop infrastructure in
the areas where the impacts will be felt, irrespective of Town and Parish
administrative boundaries.
We look forward to seeing and commenting upon the Infrastructure Delivery
Plan in due course.
PO3 - Broad Location of Growth
We support the strategy to make Green Belt releases to the north of
Leamington. For the first time in many years, this will allow a spatial
rebalancing of the urban form and provide for significant development in areas
away from the southern edge of the Warwick/Leamington/Whitnash urban
area.
Apart from relieving some of the development pressure on the south, it also
represents sensible planning practice by creating a more rounded and
balanced urban area, enabling greater accessibility, especially for the town
centres, and should enable more effective transport planning through
maintaining a more compact urban form with Leamington and Warwick Town
Centres as two central hubs.
Past development allocations had resulted in Leamington Town Centre
becoming increasingly less "central" to the urban area as development
extended to the south. The proposed strategy ends this practice and is
therefore welcome.
PO4 - Distribution of Sites for Housing
At this Preferred Option stage, we do not have detailed proposals for any of
the sites covering, for example, access arrangements, amounts of
employment land, types and forms of community facilities to be provided, and
such like.
Therefore, we wholly reserve our position in respect of objection to, or support
for, any of the sites and we will make strong representations in this respect at
the Draft Local Plan stage.
However, we have a number of concerns in respect of several of the sites. We
draw these to the District Council's attention at this stage so they can be
addressed in formulating detailed proposals.
3
Education Provision
A general comment we wish to make is that it is critical that detailed
consideration is given, up front, to the level and location of future school
provision, both Primary and Secondary.
In Whitnash we have suffered from the lack of provision of a Primary School
at Warwick Gates. The draft Development Brief included a school, but this
was subsequently deleted as the County Council, as LEA, took the view that a
better option was the expansion of the existing three schools in Whitnash. As
this was, in planning terms, "policy neutral", the District Council amended the
Development Brief accordingly and deleted the school site.
This has led to problems for the residents of Warwick Gates and we would
seek to ensure that such a situation does not arise again through this Local
Plan process.
Our comments on education more specifically related to individual sites as
follows.
Sites 2 and 3 - if these sites progress, these should be seen as incorporating
a possible location for a Secondary School.
Site 6 (Whitnash East) - we understand that access could only be achieved
through the Campion School site. We are concerned that the school should
remain viable and continue to be located where it is.
Site 10 (Warwick Gates Employment Land) - consideration should be given to
siting a Secondary School on this land, given its advantages in terms of
accessibility from across the south of the urban area. The opportunity should
also be taken to explore the siting of a Primary School on the site, to meet the
needs both of existing Warwick Gates residents and also the needs arising
from any additional housing, on the site itself or in the vicinity.
Site 2 - Myton Garden Suburb
Our concern in respect of this proposed allocation is that its development will
result in the coalescence of the three components of the urban area, Warwick,
Leamington and Whitnash. We consider that this will result in a loss of
individual identity for the three towns.
Site 3 - South of Gallows Hill
We raise the following concerns in relation to this site:
* The land is extremely prominent in the landscape and will be highly
visible when entering the urban area from the south
* The site does not represent a logical extension of the current urban
form. It is in no way "rounding off" and would constitute a "peninsula" of
development extending to the south
4
* It would have a negative impact upon the setting of Warwick Castle
Park
Site 6 - Whitnash East
We raise the following concerns in respect of this site:
* We are not convinced that access to the site is feasible. Our
understanding is that the South Sydenham development constituted the
maximum number of dwellings that could be accommodated off a cul-de-sac.
Given that access to the site via Church Lane or Fieldgate Lane is clearly not
feasible, access would have to be achieved via land within Campion School.
As this would involve relocation of school buildings, we are sceptical that the
number of houses proposed could fund the necessary works required to
achieve this solution
* Given the above issue, and our earlier comments on the wider subject
of education provision, we do not wish to see the future location of Campion
School prejudiced by this development
* There are, in the immediate vicinity of the proposed site, substantial
areas of both historical and nature conservation interest. Any development
must not have an adverse impact on any of these cultural, historic and natural
heritage resources
* In the event that the site is developed, we would wish to ensure that
sufficient community facilities are provided within the development and also
that adequate footpath and cycleway links are provided between the
development and the existing community of Whitnash
Site 10 - Warwick Gates Employment Land
We raise the following concerns in respect of this site:
* The site appears to be proposed for development at an extremely low
density. We make this observation elsewhere in respect of other proposed
allocations. We are concerned that, to accommodate the projected housing
need, land is allocated at appropriately high density, thus reducing the overall
level of new land that is needed
* This site is currently a high quality employment land allocation and we
understand that a reason the land has not been developed is landowner
aspirations, rather than demand for such a site. It is essential that the Local
Plan provides a balanced supply of employment land to meet all sectors of
demand, if economic growth and prosperity is to be fostered. There is
currently no other site in the urban area that offers this amount of land area in
such an accessible location. We are therefore concerned at its proposed
reallocation from employment to housing
5
Site 11 - Woodside Farm
We raise the following concerns in respect of this site:
* We fail to see how two access points could effectively be achieved to
this site. We do not consider access from Harbury Lane to be feasible due to
the existing road alignment. We doubt whether access could be achieved
from Tachbrook Road due to the proximity of the Ashford Road and Harbury
Lane junctions to the north and south of the site respectively. Construction of
a roundabout at the Tachbrook Road/Harbury lane junction would offer
potential for one access point, but we are concerned about the impact of such
construction on the important oak trees in the vicinity
* We also doubt whether the development could carry the cost of such
highways works. The option of gaining access via Landor Road is utterly
unacceptable due to the road alignment and lack of vehicle capacity.
Furthermore, it appears that physical access could only be gained through
demolition of existing buildings
* In the event that a single access point was sought, we consider that
this has the potential to isolate the housing from the existing community and
also lead to unnecessary and unsustainable vehicle movements
* The site would be highly prominent in the landscape - there is
therefore a concern about visual impact
* The presence of underground High Voltage electricity cables will limit
the site layout
* There is considerable local opposition to the proposed allocation of the
site. It is our duty as a Town Council to inform you of this high level of
opposition
Site 12 - Fieldgate Lane/Golf Lane
The raise the following concerns regarding this site:
* We consider there to be fundamental access problems and have
concerns about the capacity of the Coppice Road/Morris Drive and Whitnash
Road/Golf Lane junctions to accommodate the additional movements
generated by the development, especially at peak periods
* We are concerned that, at a proposed level of 90 dwellings, the site
density is too high. This would be a prestigious site and the proposed density
should reflect this. Our argument does not run contrary to that made in
respect of other sites, where we consider the density to be too low, as
provision needs to be made at varying densities to reflect different sectors of
the housing market. This includes provision of sheltered housing and singlestorey
dwellings on appropriate sites. This may or may not be the case at
6
Fieldgate Lane, but should certainly be considered across the portfolio of
proposed housing allocations
PO5 - Affordable Housing
We support the provision of appropriate levels of affordable housing but would
seek this to be distributed across all sites to ensure the development of
socially balanced communities
PO6 - Mixed Communities and a Wide Choice of Homes
We support the Preferred Option PO6.
PO7 - Gypsies and Travellers
Given that Whitnash has experienced particular problems through unlawful
traveller encampments in recent years, we support the principle of the
Preferred Option of proper site provision
PO8 - Economy
We support the principles of PO8. However, we reiterate our concern that
appropriate levels of employment land should be provided, in the right places,
and this should constitute a balanced portfolio of sites to meet as wide a
variety of needs and demands as possible
PO9 - Retailing and Town Centres
We support the principles set out in PO9
PO10 - Built Environment
We support the principles set out in PO10
PO11 - Historic Environment
We support the principles set out in PO11
PO12 - Climate Change
We support the principles set out in PO12
We will seek to ensure that any future development in Whitnash seeks to
reduce the Town's overall carbon footprint through the application of
sustainable development and design principles
PO13 - Inclusive, Safe and Healthy Communities
We support the principles set out in PO13
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PO14 - Transport
We support the principles set out in PO14 with the exception of the section
relating to High Speed 2.
Whitnash Town Council neither objects to nor supports HS2
We urge the District Council to ensure that the final Infrastructure Delivery
Plan takes full account of public transport needs and the principles and
policies set out in Warwickshire County Council's Local Transport Plan 3
PO15 - Green Infrastructure
We support the principles set out in PO15
PO16 - Green Belt
We support the limited release of Green Belt sites as set out in PO16 as this
will create a more balanced and sustainable urban area and urban form
PO17 - Culture and Tourism
We support the principles set out in PO17
PO18 - Flooding and Water
We support the principles set out in PO18

Dear Sirs,
Please find below my views regarding the Consultation for the New Local Plan. I am
submitting this as a letter because the consultation web site appears unreliable and also
does not appear to allow me (as requested by the Council) to make alternative proposals. It
only appears to allow me to make comments on particular sites.
SUMMARY
I am totally opposed to the plans to allow development on the Green Belt to the North of
Leamington Spa and the complete change in direction since the 2009 Core Strategy
document. There is no evidence or requirement to change any of these North Leamington
Green Belt Boundaries.
In particular I oppose the proposed developments to the Milverton Gardens (North of
Milvertion) and Blackdown. Your references are I believe are L03 and L07 together with L48.
L07, and L03 in particular, must be among the highest public amenity value of any rural
space in Warwickshire providing very highly used public footpaths from two access points
directly onto open country side.
The Green Belt has been vital in maintaining the identity of the Warwickshire towns for
many years and Government policy under NPPF is very clear regarding the importance of
preserving Green Belt.
The Council have not demonstrated the required very special circumstances to build on the
Green Belt to the North of Leamington. It is therefore unacceptable to change the Green
Belt boundaries to the North of Leamington.
Plans for a major new relief road, to alleviate the traffic caused as a consequence of the
proposed new housing, only causes further loss of Green Belt and is unjustified.
Housing should be provided, as the previous 2009 Core Strategy document, to the South of
Leamington Spa where the employment and infrastructure exists and where there are not
the issues of coalescence.
The evidence base is not sufficient for the preferred plan to be derived from it. It fails to
provide balanced investigations of the considered sites. It is clear that it must have been
used to attempt to justify a politically motivated plan to 'share the pain'. Further evidence
of this has been provided from Council responses to enquiries with statements that the plan
has in fact arisen as a result of lobbying pressure from South Leamington.
Other such statements have indicated that the reasoning behind the proposed housing to
the North of Leamington Spa also relate to assumptions about employment arising from
around Coventry airport. This would be inappropriate because housing should be provided
close to the employment in Coventry providing a more sustainable future with shorter
commuting. Furthermore the Council should be planning to invest for employment in
Leamington Spa rather than making Leamington a commuter area for Coventry. If this was
part of the reasoning for the plans, then this should have been made clear in the
consultation documents for people to comment upon. If on the other hand employment
arising from Coventry airport was not part of the reasoning behind the proposed housing to
the North of Leamington Spa, then the Council should not be using it as a justification in
responding to consultation questions.
On a positive note the proposals to enhance the quality of the proposed new housing
developments (along the lines of garden towns) is positive and would be an asset to, and
raise the housing diversity in, South Leamington Spa.
EVIDENCE BASE
The Council Preferred Options plan are not, as we would be lead to believe in the Forums,
developed from an evidence base. On inspection there are significant omissions in the
evidence base and significant conclusions are included in the plans which are not supported
by the evidence base. The only conclusion I can make is that the evidence base was
developed in retrospect to try and support a political plan to 'share the pain' or 'spread it
about'.
Not only does the evidence demonstrate this lack of consistency in approach, the anecdotal
comments from some Councillors, as well as presentations by officers, have demonstrated
the back to front approach to developing the plans.
When pressed for an explanation regarding the errors in the statistical analysis of the
population growth, Councilors have made the statement that the council settled on the
required number of houses "as what was considered we could get away with".
There is over-provision of housing resulting from the Council making projections from past
population data which includes a period of exceptional growth. Calculations of future
population should have more accurately taken account of the reducing trend in population
growth, rather than having an unlikely high projected population as a result the past, short
period, of abnormal high growth. If the calculations and projections exclude the period of
abnormal growth then the housing on the Green Belt is not needed.
The Council has stated in forums that the infrastructure to the South of Leamington Spa has
been investigated and found not to support the required number of houses. However they
also state that their infrastructure plans to the North are not yet completed. Request for
details of the traffic surveys established that they have not in fact been carried out. This is
further evidence that the infrastructure investigation is being used to justify the plan rather
than being the basis for it.
The Council have concluded that more houses in the South of Leamington Spa than is
allocated in the plan cannot be delivered. This is not evidenced anywhere. When challenged
in Forums, the Council stated that the Developers with whom local residents have consulted
(to confirm that the Council assumptions are incorrect) cannot be trusted 'because they
have a vested interest'. Can it be that the Council have therefore only consulted with
Developers / Landowners of the Green belt to the North? Clearly these parties would have a
far greater vested interest to have the Green Belt boundary redrawn!
What appears more likely is that the Council have simply made an assumption on
deliverability rather than carry out a proper investigation. It would appear that the Council
have lost track of the phased nature of the delivery requirements when considering the
deliverability argument.
The conclusion that the area to the South of Leamington Spa cannot accommodate more
homes and therefore there is no option but to put the houses on Green Belt is not
evidenced and is incorrect.
GREEN BELT
The reasoning behind relocating the development from South to North of Leamington is the
result of previous objections from South Leamington with no account taken of the
underlying planning advantages which exist. It is a purely political move.
The Local Plan is governed by the National Planning Policy Framework (NPPF) which clearly
states that Local Plans must accord with its principles. The value of Greenbelt is set out in
the NPPF to prevent urban sprawl by keeping land permanently open. Green belt land
should not be developed when other suitable land is available for development.
The National Planning Policy Framework (NPPF) sets out five purposes for Greenbelt land. In
summary these are, to prevent urban sprawl of built up areas, to prevent neighbouring
towns merging, to protect the country side from encroachment, to preserve the setting and
special character of historic towns and to assist urban regeneration by encouraging the
recycling of urban land. The Greenbelt land identified for development in the Preferred
Option does fulfill the majority of these purposes and its development would therefore be
contrary to the NPPF.
The NPPF requires there to be "very special circumstances" for development in the Green
Belt. It also requires the harm caused to the Green Belt by the development to be
outweighed by the benefit of the development. According to Warwick District Council the
very special circumstances are that there is nowhere else for the homes to be built. This is
demonstrably untrue.
The Council identified available land east of the A452 (Europa Way) and south of Heathcote
towards Bishops Tachbrook however these sites have not been included in the Preferred
Options sites. Presumably, this is because of the policy of 'spreading it around'. That is not a
planning policy, it's a political policy.
The proposals ignore Warwick District Council's study of the Green Belt land at Old
Milverton and Blackdown, which concluded that these areas have high Green Belt value.
The proposals will reduce the "Green Lung" between Leamington and Kenilworth to less
than 1 1/2 miles.
Planning policy dictates that Green Belt must be valued more highly than Green Wedges.
Therefore the Preferred options are flawed as the opposite has in fact been planned.
NO EVIDENCE OF ANY VERY SPECIAL CIRCUMSTANCES FOR DEVELOPMENT ON
GREEN BELT
No "very special circumstances" have been proven for the use of Green Belt land.
The Council's own previous plan the "2009 Core Strategy" accommodated significantly more
houses and identified suitable sites without using Green Belt. The land south of Leamington
Spa (not in Green Belt), was identified and is still available, for development.
The assessment performed by Warwick District Council shows that this land to the south of
Leamington is easier to develop and already has a substantial amount of infrastructure to
support the development, and the new residents who will live there. It is close to the M40
and there are existing employment opportunities in the South of Leamington Spa as well as
existing out of town shopping facilities and good access to the town centres.
Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are
alternative areas for development other than the Green Belt and that consequently there is
no evidence that very special circumstances exist to change the Green Belt Boundary.
Warwick District Council argues that the land in the South of Leamington is not as attractive
to developers because concentration of development in that area may result in the
developers making less profit. Consideration of the developers' financial gain is not a very
special circumstance to permit unnecessary development in the Green Belt. Concentration
of development would encourage the housing to be competitively priced and more
affordable when built in the south of Leamington Spa.
RECREATION VALUE OF OLD MILVERTON AND BLACKDOWN
Milverton Gardens (North of Milvertion) is an important local amenity for exercise and
recreation as there is very little alternative publicly accessible open space in this area.
It is enjoyed by many walkers, runners, riders, and cyclists. It provides a countryside
environment close to the neighboring areas of Leamington Spa. Evidence has also shown
that people are traveling from the Centre and also the South of town to use the amenity,
further demonstrating the value of this amenity to a wide community.
Both the proposed building development and the "Northern Relief Road" would
substantially reduce the amount of land that is available to be enjoyed and have a
catastrophic detrimental impact on the ambience and hence the amenity value of the land.
The implication that somehow the proposed type of development will magically turn some
of it into a maintained park land is both unlikely and unsustainable. It would also detract
from, rather than enhance its value; managed parkland is a poor substitute for access to fine
agricultural land.
North Leamington Forum recently (and ironically at the presentation of these plans!) had to
allocate funds to struggling local groups trying to maintain and create small recreation
spaces within housing developments which the Council will not / or cannot afford to
maintain. This demonstrates the value of the currently free amenity which the community
enjoys.
North Leamington Spa does not have parks such at Victoria Park and Jepson Gardens as do
other areas of Leamington Spa. This area of Green Belt provides an invaluable and
irreplaceable open and free resource to the community. A great many signatures have been
collected on petitions in support of keeping this amenity.
The Housing Assessment fails to identify the footpath between Milverton and Old
Milverton. Policy QE4 in Regional Spatial Strategy for West Midlands states that footpaths
and the green spaces around them must be preserved. The document is being used
powerfully at the moment in the "evidence base" to support council desires, yet has been
heavily cherry picked. Indeed Policy QE6 states "Local authorities should
conserve...protecting and where possible enhance natural features that contribute to the
character of the landscape and local distinctiveness"
INFRASTRUCTURE / PROPOSED NEW ROADS
The Northern Leamington Relief Road, at an estimated cost of £28 million, would ruin Old
Milverton and divert resources from other much needed public investment. As a Charted
Quantity Surveyor it is evident that this estimate is unlikely to be the maximum outturn cost
considering the ground over which the road must run and the bridges and retaining
structures which will be necessary together with the other costs which will be attributed to
it.
Traffic flows in the area tend to be north to south rather than east to west. The road will
serve no purpose other than to take new home owners quickly on to the A46 and to jobs
and shopping opportunities away from our Town. If the development does not go ahead the
road will not be required.
Turning the A452 between Leamington and Kenilworth into dual carriage way will not help
traffic flows. At peak times the delays on the A452 result from commuters wanting access to
the Town centres. Building nearly 3000 houses north of Leamington will simply increase the
congestion. The dual carriage way will have a detrimental effect on the picturesque
northern gateway to Leamington and southern gateway to Kenilworth.
A "Northern Relief Road" will form a natural barrier and encourage further development in
the green belt up to this new road. It will need to be built across the flood plain and will
violate an important nature corridor along the River Avon.
If the proposed development is concentrated in the South of Leamington there is an existing
road network that could be upgraded at considerably lower cost than the £28m allocated to
construct a "Northern Relief Road" so reducing the sale price of the houses.
NEW OUT OF TOWN STORES AND EMPLOYMENT
The proposed "out of town" retail operations will be another blow to independent retailers
in Leamington, Kenilworth and Warwick who make the area an attractive place to live.
Further "out of town" shopping will take trade away from the Towns.
However the Council have stated at Forums that they don't plan out of town shopping,
apparently therefore the Consultation information is inaccurate?
They have also played down the concept of new employment land in the Green Belt in these
same Forums and have been totally unable to give details at to what is alluded to in the
Consultation by these phrases. They indicate this has yet to be thought through. Further
demonstrating that the evidence base is still being developed to justify the plan not the
other way around as should have been the case.
LOSS OF AGRICULTURAL LAND
There will be a loss of a significant amount of high quality agricultural land in Blackdown and
Old Milverton which is unnecessary.
OVERALL LEVEL OF HOUSING PROVISION / NUMBER OF HOMES INCLUDED IN THE
FORECASTS
There appears to be over-provision of housing resulting from the Council relying on
projections from a past period of exceptional growth as noted earlier.
Furthermore the Council have agreed in the Forums that there is a "contingency for the
consultation" to the tune of at least 1400 homes. Detail investigation of the low numbers
assumed for allocations on sites such as the Fire station and other town centre sites indicate
that there is also a further 'hidden' contingency.
The Council appears to be building contingency on contingency. Consequently, even
accepting the population and demand projections, the units proposed for the green belt to
Milverton Gardens (North of Milvertion) can easily be deleted without causing a deficit,
even if no alternative sites were substituted.
The situation is exacerbated in that having identified non Green Belt Land as suitable for
development, but then having rejected it without adequate justification, there is a real
possibility that the owners of this will gain planning permission on appeal resulting in
further over provision of land.
Returning to the 1400 homes contingency alone. If this "buffer" is removed from the
forecast there is no need to include the Green Belt land at Milverton Gardens (North of
Milvertion) (L03 & L07) in the proposals.
ALTERNATIVE PLAN
The Council have said in Forums that in making objections to the plan, residents should also
give solutions. However the Council have done little to publicise the very short 8 week
consultation. Furthermore the Council have refused requests for an extension until the last
few days (It was slipped quietly into the Consultation details page after the 18th July with no
announcement and the Web landing page was not updated to make the public aware of the
change). This gives the impression that this was a consultation in name only and very little
time has been available for people to make alternative proposals. However the plan is
poorly put together and there are clear considerations and alternatives which should have
already been accommodated.
Significant areas of land to the South of Leamington Spa have been stated by the Council to
be undeliverable. This is incorrect.
Developing the land to the South of Leamington has significant advantages:
 The employment land is to the South and local employers are already saying they
need much more affordable housing in this area.
 The transport routes to M40 exist in this area and relatively affordable traffic
solutions will accommodate the expansion.
 The infrastructure already exists in this area, even to the point that traffic islands
have been built to take some of the new development!
MY KEY POINTS OF OBJECTION ARE
1. Local Amenity: The land proposed for development is a vital local amenity for
exercise and recreation; the recreational value of this land would be lost. The heavily
used footpaths make this element of greenbelt one of the most valued in the area. It
is for this reason there is such strong opposition.
2. These areas of greenbelt meet 4 of the 5 purposes of greenbelt land and should
therefore be protected from development. The Greenbelt Study undertaken by the
council is highly subjective and residents don't believe this is a sound basis for the
Preferred Plan.
3. Greenbelt land should not be developed because the Local Plan is governed by the
National Planning Policy Framework which states greenbelt should only be built on in
exceptional circumstances, and local residents believe exceptional circumstances
have not been demonstrated. In particular there is suitable land identified by the
Council to the East of Europa way and South of Heathcote that have not been
included in the local plan. Namely Grove Farm.
4. The apparent Council policy of spreading development around the county is not an
appropriate planning policy, but is rather a political policy and thus this greenbelt
land should not be built on.
5. There is further adequate land available around Radford Semele, this land has been
unnecessarily discounted by the Council due to the presence of gas mains, but this
land is viable in spite of the 100m exclusion zones by incorporating these zones into
part of the open space of a garden town.
6. The National Planning Policy Framework states that one purpose of greenbelt is to
prevent urban sprawl, the Preferred Option ignores this and causes sprawl, which is
compounded by Southward development of Kenilworth.
7. Even accepting the population and demand projections for housing the units
proposed to be built on the Green Belt land to Milverton Gardens (North of
Milvertion) could be deleted by omitting the 1400 over provision without causing a
deficit; residents believe this should be done.
8. Non greenbelt land that has not been included by the council is likely to have
planning permission granted on appeal from developers resulting in an overprovision
of land and needless development of this greenbelt.
9. The existing infrastructure is not appropriate to the new development, requiring a
£28 million relief road. The need to include such a massive undertaking invalidates
the argument that there is exceptional circumstances to build on the greenbelt. The
£28 million, even if raised from developers, is a waste of public money and will have
an adverse impact on the price of the houses and undermine the aims of affordable
homes
10. There is significantly better infrastructure in the South with access to the M40,
where development should therefore be placed.
11. There are inadequate employment facilities in the North of the town surrounding
the proposed development site and little evidence how the employment land, which
the Council propose to allocate, would be used. In contrast there is a good track
record and existing employers in the South of the town who chose to be locate close
to the M40. The plan must be evidence based and there is not enough evidence to
suggest there will be enough employment opportunity in the North of the town.
12. If additional housing is required for Coventry and Warwickshire Gateway then that
housing should be adjacent to the airport site to allow sustainable transport e.g.
cycling, avoid congestion, avoid coalescence, and justify exceptional circumstances.
If this were not possible then non-greenbelt land in the South should be released
capitalising on the M40 infrastructure and improved road layout near the site that
has already been identified by Councillors.
13. To be sustainable housing should be planned close to proposed employment
otherwise it will have adverse impacts on commuting and travel. If for example
people end up having to commute to the Coventry Gateway project then and is
contrary to a sustainable community and contrary to the declared aims of the
Gateway project.
14. The preferred options plan states that it is vital to ensure that new housing is
affordable, construction on the greenbelt to the North of the town will not create
affordable housing. House prices are higher in the North of the town and the cost of
the relief road will be passed on by developers to new homeowners in the
development. Furthermore if development is focused in the South then an increase
in housing supply will ensure that the developers focus on delivering good quality
affordable homes. This is a simple supply and demand argument.
IN CONClUSION
I strongly urge you to reconsider your plans. There are no grounds in your evidence base to
justify building on any Green Belt Land at Milverton Gardens (North of Milvertion) and
Blackdown.

I am writng to oppose the District Council's plans to develop on Green Belt Land as shown in their 2012 Preferred Options booklet. The reason given for this ,"to spread the building around", surely doesn't justify using beautiful countryside, well used by the local people. I worrry hugely about the amount of traffic there would be in this part of town and the problems it would cause. Please reconsider.

I am writing to register my strong objection to the new Proposed Development Plans. It would be a crime, unforgiveable & irresponsible to damage this area of North Leamington, when other brown and white field sites could be found.
It is Greenbelt the fundamental aim of this is to prevent urban sprawl. The joining of Leamington to Kenilworth would be just this. The 2009 plan would have been much less expensive, not requiring a whole new infrastructure. Please reconsider & safeguard such precious countryside.

I wish to object most strongly to the draft proposals to build on green belt land to the north of Leamington. I understand there are brown field sites still available and not considered in your proposals. This, in my opinion, is irresponsible planning. You are the custodians of our environment which menas you must preserve green belt land, at all costs.

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Submission attached.

Submission Attached.

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

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

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

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

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

I am writing to express by serious and deep-felt objections to the preferred options plan as part of the consultation process that ends on the 27th July. In particular I object to construction on the greenbelt land to the North of Leamington, particularly the area North of Northumberland road, and South of Old Milverton, which seems to be being referred to as "Milverton Gardens." I propose that there are sound and sensible planning reasons not to build on this land, and viable alternatives elsewhere. To build on this land would be to fail to "protect for future generations" an essential part of the National Planning Policy Framework.

SECTION 1: INCORRECT PLAN TO BUILD ON GREENBELT LAND

Development unsuitable on Greenbelt land:

The part of the plan that I am quite simply outraged about is the destruction of valuable greenbelt land. This is not in accordance with national planning policy, for National Planning Policy Framework identifies that greenbelt land should only be built on in exceptional circumstances. The plan the council has put together does not demonstrate exceptional circumstances, not do I believe are there exceptional circumstances within the county for this to be validated (it would be unacceptable for the council to simply take this consultation and find some more evidence that they argue makes greenbelt use warranted, the point of consultation is not to argue with it, but to find out and accept local views). No evidence has been cited by the council explaining the exceptional circumstances, and as this is an evidence based consultation this is unacceptable and the plan to build on greenbelt land must be removed. This is further compounded by the fact that development is proposed also on the South edge of Kenilworth increasing the risk of sprawl as the two towns are being moved closer together. There is already significant established sprawl between Leamington and Warwick, to allow future sprawl risking coalescence with Kenilworth would destroy the local area, the community and result in people not wishing to move to the area and thus prove unsustainable.

Arguments that the need for housing in the area warrant construction on the greenbelt as an exceptional circumstance are false; this is demonstrated by strong evidence for in Cheltenham (a region which like Leamington has a strong need for housing and a large proportion of the county covered by greenbelt land), here the NATIONAL planning inspectorate ruled that these were not sufficiently exceptional circumstances to building on greenbelt land, and it is only right that Warwick District Council take heed of this evidence in their plan and remove the greenbelt from their plans. It has been argued that 80% of the county's land is greenbelt, however this is a misleading statistic for in fact a far smaller percentage of the rural-urban fringe is protected by greenbelt land. It is therefore totally unacceptable to use greenbelt land to build 44% of the housing required under the plan. Furthermore the % of greenbelt bordering the rural urban fringe is there to prevent urban sprawl, this is a nationally stated policy, it is my opinion that building on the greenbelt to the North of Leamington risks sprawl with Kenilworth and Coventry (this is indisputable as an original purpose of the greenbelt is to prevent sprawl with these areas, nothing has changed with regard to these areas, so building on the greenbelt encourages sprawl).

Use of greenbelt land is also unacceptable for there are other suitable areas for housing to be built, which are outlined later in this letter. Early in the consultation process the council discussed the need to "spread the pain" around the county, and for this reason there was construction on the greenbelt. This is not a planning reason for building on the greenbelt and certainly not an exceptional circumstance; as this was mentioned by council members early in the consultation it is only logical this is the logic for construction on the greenbelt land. This logic is unsound and the greenbelt should be removed from the plans. Creating alternative arguments later to counter residents objections that "spreading the pain" or as you have referred to it as in your preferred policy document "spreading development around the district" is not in-keeping with the process of consultation, for this is arguing with the publics views gathered consultation rather than being guided by them.

It is important to note that the National Planning Policy Framework sets out five purposes for Greenbelt land. In summary these are; to prevent urban sprawl of built up areas, to prevent neighbouring towns merging, to protect the country side from encroachment, to preserve the setting and special character of historic towns, and to assist urban regeneration by encouraging the recycling of urban land. Given that the greenbelt land to the North of Leamington Spa and South of Old Milverton fulfils the first 4, and arguable also ensures the 5th of these objectives, this is quite clearly greenbelt of very great importance and therefore its development would be contrary to the National Planning Policy Framework and common sense.

I believe the council have been disingenuous, or certainly at least short sighted in their plans. The land to the North of Northumberland Road that is planned for development leaves no distinct boundary to the greenbelt, particularly to the West of the site. This is in contravention of the NPPF, but would inevitably result in further development of the greenbelt land beyond that currently mapped by the council. This site therefore is inappropriate for development for once the boundary of the greenbelt is breached in this location and housing built upon it, this will create a "slippery slope" of further greenbelt development; a disaster to the region and totally unwanted by residents.


Advantages of focusing building in the South:

I am a young person (23) returning to Leamington Spa to work, the access to rural space and greenbelt land are essential to me choosing in this area to live. These rural spaces and areas of greenbelt are essential to the heritage and character of our town. It is essential we preserve this to encourage future skilled people to live here. However I cannot afford to purchase a house in the area, rather I am forced to live with my parents. As a resident of the area looking to purchase a house I am strongly opposed to construction on the greenbelt land to the North of Leamington, rather I would prefer extensive construction to the South. Housing in North Leamington has always been, and no doubt will continue to be more expensive, this is why developers want to build there (as stated by a senior officer of the council) as developers can then sell the houses for more profit. We are desperately in need of new affordable housing, as stated in your plan, so not only is construction in the greenbelt not warranted as an "exceptional circumstance" but actually contrary to what the district so desperately needs! Allowing more construction in one area (the South) would increase supply and therefore decrease demand for houses there, and with increased supply and decreased demand it is a simple economic argument that housing would be cheaper in that area. A key part of your plan is to ensure affordable housing is available and therefore by persisting with construction on greenbelt land to the North of the Town you fail to provide an adequate and sustainable supply of affordable housing. Again your policy of "spreading development around the district" is not only not based on planning principles and harmful to the district, but in fact prevents you achieving the large stock of affordable housing, which you set out to do.

In the Milvertion Parish Council meeting I attended a senior officer of the council stated that putting all housing in the South would be "more than the market could bare," quite simply this is argument is not valid for justifying construction in the North Leamington Greenbelt. If the market cannot support that level of housing then clearly there is no need to build any more housing in the district for there is no more demand!

Furthermore focusing housing in the South would allow financial saving for the council; this is important in a time of recession with an uncertain future; it is the councils responsibility to spend taxpayers money as effectively as possible and by focusing construction in the South rather than "spreading" development around the town, then the council could benefit from economies of scale whereby new schools and other services could be built singuarly in one area rather than having to spread service provision at increased cost around the county. This would thus allow the council to benefit from an economy of scale.

Health Grounds

As a medically qualified doctor with a special interest in diabetes and obesity I believe it is vital that the council and planners take on-board that Warwickshire is set within the West Midlands, which exhibits the highest rate of obesity in England. Such an epidemiological problem is of tremendous importance to the health, wealth, sustainability and enjoyment of futures generations. The greenbelt land to the North of the Town has an incredibly important exercise resource; the footpath between Leamington and Old Milverton and on to Warwick. I believe this must be one of the most popular footpaths in the region and provides vital exercise and leisure benefits for the local population who walk, cycle, ride horses, jog on it. Destruction of this greenbelt would prevent people using this footpath ( being realistic very few people would use a footpath that runs through the centre of a housing development, even if it is a "garden" one, and this goes for arguments of putting it in a belt of parkland, which also would not give any benefit to the community, and as in many areas can result in foci for crime.

Attempts to recreate this leisure resource would not I believe be successful in a garden town; the footpath is free of charge to use, requires no special equipment to use, is open whenever local residents want to use it (even at night), can accommodate a high volume of people, can be used by those of any age (indeed people who grow up using it as children are likely to continue to use it as adults thus bridging a vital gap in ensuring exercise throughout life), it can be used individually or in groups. It also provides a low resistance, low impact, long duration form of exercise that is vital to older people needing to exercise. It is my opinion that even a combination of play areas, sports grounds, parks and facilities would fail to fulfil these criteria. When canvassing opinions from people using the greenbelt we were amazed at how widely people come from across Leamington to use this resource - it is a benefit for the whole town, and indeed the whole region - this letter, and the strong opposition to the greenbelt destruction cannot be accused of being "NIMBY (Not in My Back Yard). Ensuring the health of the population of Leamington is vital to creating a sustainable development plan, building on this vital local resource fails to meet the needs of today's population but also destroys a vital amenity for our future increasing the risk of heart disease, diabetes, stroke etc and increasing the burden on our health services. Building on the other sites suggested in this letter avoids such problems.

It is of particular importance to myself and local residents to note that the area of highest use, accessibility and therefore greatest amenity and health benefits are the fields closet to Leamington Spa, therefore even the smallest amount of encroachment into the greenbelt would be unacceptable and harmful to the community and it's future sustainability and this is not what the very strong opposition to your plans from local residents have asked for.

The area between Kenilworth and Leamington Spa is subject to air quality management measures due to the high pollution created by surrounding pre-existing infrastructure, not only would new roads create increased levels of air pollution (harmful to the population, and in particular those with respiratory diseases eg asthma) but also the proposed development would reduce the Green Lung between Leamington and Kenilworth to less than 1.5miles reducing the ability of this land to absorb and decrease surrounding levels of air pollution. It is hardly sustainable to future generations to encourage harmful levels of pollutants in the air and therefore building here fails to achieve the plans aims for another reason. The land to the South of the town, does not suffer from the risk of coalescence with other towns, and indeed areas to the East and West not subject to air quality management, and thus would provide far better locations for the construction of new developments.

Wildlife Value

There is considerable wildlife and conservation benefit to the greenbelt between North Leamington and Old Milverton; it is essential we preserve diversity of wildlife for future generations, and this is intrinsic to a sustainable plan. Protected wildlife in the area includes; bats and their flight-paths, gliss gliss mice, great crested newts and badgers and their sets. This is without any study and I'm confident that careful study would elucidate other important species, this is likely to produce significant delays with biodiversity study, and protest questioning the ability of the council to deliver the site in an appropriate timescale if at all. I and many like me believe that we and Warwick District Council have a duty to protect these creatures, attempts to move them are unacceptable.

Employment

The preferred option plan's suggestion of construction of housing in the North Leamington Greenbelt fails to take into account the employment landscape of the district past, present and in future. Myself and other residents have strong objections and concerns that there will not be enough employment in North Leamington. This is a further reason that construction should not occur on the greenbelt. Whilst the plan suggests that some land will be made available for employment there is no thought as to what, where, or who this might be. There is no consideration as to why employers would consider not locating in the South where there is far better access to the M40 and national infrastructure (even with the proposed trunk road) nor why they would leave an area where there is already both competitors and suppliers, both of whom would make South Leamington more attractive. I believe that the only employment you could be confident of having in the North would be employment to service those who live in the new houses there, this would no doubt involve out of town shopping and further damage the centre of Leamington Spa, disastrous for the local economy at. Furthermore there is NO EVIDENCE provided whatsoever as to whether and if so which employers would locate in the North. The vast amount of employment and retail land in the South provides an abundance of EVIDENCE that employers are not only there, but also want to be there and new development/employers continue to locate. You have failed in your consultation document to demonstrate evidence of successful employment opportunities deliverable to the North and as a consequence myself and local residents do not want construction in the North, again this is not an invitation to attempt to justify your decision to put housing in the North, but rather listen to resident's views and act on them by not building in the North.

Housing in the North poses a very serious risk that people would need to commute to South Leamington to work, or alternatively to the M40 both these would involve travelling across the river at peak times when congestion is already unacceptable, this would hardly be sustainable and contribute to air pollution which has already shown to be excessive in the North.

At the Milverton Parish Council meeting it was proposed that the construction of the Coventry Gateway/airport project(s) would provide employment for those living in the North. This is unacceptable for two reasons; the first is that this is construction on greenbelt land seemingly justifying more development on greenbelt land - this is of course poor reasoning for justifying exceptional circumstances for construction on the greenbelt land! Furthermore this employment land abuts and provides significant benefit to Coventry; I do not believe Warwick district should be responsible for providing housing in Leamington for employment that is effectively in Coventry regardless of where historic district borders are drawn, nor will the planning inspectorate. If this land is exceptionally required from the greenbelt to provide housing for employment, that land should be provided near Coventry. Furthermore having people living in North Leamington yet working in Coventry risks turning Leamington into a commuter town - with great disadvantages for our town centre, and those who work there. Finally there is considerable congestion around peak times in journeying to Coventry, the infrastructure is not in place to allow people to commute to Coventry and indeed any improvements that were made have simply begun to tackle the current problems. These highways agency solutions have hardly corrected the problems that currently exist for significant congestion remains at peak times For all these reasons construction on the greenbelt in the North is incorrect and an alternatives strategy should be sought.

This plan goes against almost a century of town planning in Leamington; the 1943 Royal Leamington Spa plan for development identified that employment land had already been focused in the South of the Town, and highlighted the importance of continuing this development this further. Vitally this was seen (and has continued to be seen) as the correct policy when the M40 did not exist, the presence of the M40 only strengthens the desire for business to locate in the South of the town, and therefore it is essential housing locates close to this to prevent further congestion in the town. The 1943 plan further elucidates that construction of housing in the North would serve simply as commuter accommodation for those working in Coventry. The local residents do not want Leamington to develop into a commuter town, nor the demise of the town centre that would result from this, this is a further strong argument for not building on the North Leamington Greenbelt. These are hardly pithy historical notes, but instead provide a firm evidence base tested over 60+ years demonstrating successful location of employment land in the South of the town, and the risks of commuter accommodation in the North. The council have totally failed to provide strong evidence for employment to locate to the North, nor for this to function as successful housing for the town, indeed at the Milverton Parish Council meeting the Deputy CEO couldn't give any significant detail as to what sort of employment would locate to the North. I must repeat again that this letter is not an invitation for the council to now seek this evidence or contest these arguments (supported by petitions, other letters, and record breaking meeting attendance), but to listen to local views and use them to modify their plans to remove construction on the North Leamington Greenbelt - to fail to do this would be to fail to consult properly.

To be sustainable housing should be planned close to proposed employment otherwise it will have adverse impacts on commuting and travel. If for example people end up having to commute to the Coventry Gateway project then and is contrary to a sustainable community and contrary to the declared aims of the Gateway project.

Infastructure

The current infrastructure is completely unable to meet the demands that would be placed upon it by new construction in the greenbelt to the North of Leamington Spa. This means that new land would be needed for a Northern Relief Road. Land that is so unsuitable for development that it requires a £28 million investment to make it suitable - again hardly justification for exceptional circumstances to build on the greenbelt. Professional opinion further suggests that this £28 million is an understatement and costs would be far higher. Furthermore this relief road would destroy the character of Old Milverton, one of Warwickshire's greatest villages. I believe this should not happen, particularly because Old Milverton is a conservation zone an "areas of special architectural or historic interest, the character or appearance of which it is desirable to preserve or enhance." It is therefore unsustainable to destroy such a village's character, and furthermore irresponsible after the residents have spent so many decades preserving their village for the council to destroy it themselves on the basis of inappropriate planning decisions. Additionally this development is a waste of council money, for although the cost of the relief road would be met by the developers if an alternative site was chosen this funding could be spent on other requirements for a new development required by the council, eg schools/cycleways. The problems with infrastructure costs also link back into arguments regarding the cost of housing to consumers; the housing developers are commercial companies and they will pass on the cost of building the relief road to those who go on to purchase the houses. The council has already recognised the importance of building affordable housing and therefore questioning construction in the already expensive North Leamington, but adding to the cost of housing due to the need for a relief road will only make the housing more expensive and inaccessible to the people, who like myself who cannot afford housing.

The recent disastrous modification of infrastructure in Jury Street Warwick demonstrate the poor ability of this country to develop it's infrastructure appropriately, and the public have no faith in the council's ability to successfully deliver such projects, therefore the insertion of a £28 million relief road is of great concern to residents, there is shockingly little evidence in the local plan as to how this would be successfully implemented and local residents can only fear it would be as disastrous as other plans without this evidence base; it is put in we believe as an afterthought to justify construction on the greenbelt land, and must therefore, along with it's concurrent development, be removed from the development plan.

The plan argues that turning the A452 between Leamington and Kenilworth into dual carriageway would be a benefit to the area, however a more thorough assessment by the council would identify that at peak times delays on the A452 result from commuters wishing to access the Town Centres, which a dual carriageway would do very little to improve.

The Northern relief road planned by the council will form an artificial barrier, which will encourage further unacceptable development that will further destroy old Milverton; risking such a development is inconsistent with the NPPF and Regional Spatial Strategy, as Milverton should be protected under policy RR1 of the RSS.

Housing Provision

I personally believe that there is an over-provision of housing in the preferred options plan, this occurs because the Council is relying on projections from a past period of exceptional growth, that is very unlikely to be continued. Furthermore even if the proposed housing demand was accepted then amazingly the preferred options plan could have the housing removed from the greenbelt sites without causing a deficit and this is without other (more suitable) alternative sites, as suggested below being substituted. Quite clearly therefore exceptional circumstances cannot be justified for construction on the greenbelt, and this wouldn't be accepted at later stages of the process if/when such a development was inspected/contested. For this reason I strongly believe that the result of the consultation should be the removal of construction from the greenbelt land, due to overprovision of housing alone (but with the potential for including other sites if the results of the consultation seem necessary). I feel particularly strongly that this argument should be accepted and included in the future plan for it was the leader of the council stated at the Milverton Parish Council meeting that if we thought there was overprovision of housing then we should say so. This must therefore be a valid reason to object and one I expect to be taken onboard.

SECTION 2: Need to consistently align Local Plan with West Midlands Regional Spatial Strategy

When I examine the evidence base for your plan, and in particular the Strategic Housing Land Availability Assessment I note that almost all the suggested rural areas are discounted because they conflict with RSS policy point RR1. It is clear that overwhelming importance has been placed on the policies in this document. This must be balanced with the important policies expressed in the National Planning Policy Framework which rightly protect the vital importance of greenbelt land.

However this RSS document includes policy QE14 that states that "Development plan policies should create and enhance urban greenspace networks by ensuring adequate protection is given to key features such as parks, footpaths and cycleways, rivervalleys, canals and open spaces". It is not recorded in the Strategic Housing Assessment that a footpath crosses the land between Northumberland Road and Old Milverton, but there is most definitely one there, marked on OS maps, and heavily used as a local amenity to people living in urban areas including Leamington Spa; this provides important health and lifestyle benefits. In the Regional Spatial Strategy each policy is given equal standing and therefore this policy is as important as RR1 which you have already used to discount so much other possible development land. It only therefore stands to reason that this greenbelt land too (as QE14 protects more than just the physical path, but also the green land around it) should be removed from the preferred options plan. Indeed the proposed sites L07 and even more so L03 are in my opinion some of the most highly used footpath and recreational natural green space areas in the district and must be protected as such.

The suggestion of ignoring QE14 and building on the greenbelt, yet leaving the footpath is logically unacceptable. The QE14 protects GREENSPACE, therefore there must be GREENSPACE around the footpath. (This is essential to it's use). The policy identifies that footpaths and parks are different and must both be protected. It is therefore unacceptable to put the footpath into parkland as this is entirely different. The footpath and the greenspace around it must be therefore be protected in their current form!

Furthermore the RSS also states in policy QE6 that; "Local authorities and other agencies, in their plans, policies and proposals should conserve, enhance and, where necessary, restore the quality, diversity and distinctiveness of landscape character throughout the Region's urban and rural areas by: protecting and, where possible, enhancing natural, man-made and historic features that contribute to the character of the landscape and townscape, and local distinctiveness." The greenbelt to the North of Leamington is quite clearly a natural feature of the landscape that contributes greatly to the character of North Leamington, Old Milverton and the surrounding area, and is essential to the local distinctiveness of these areas. This is clearly demonstrated in the huge number of signatures in petitions returned to the Council surrounding the proposed construction on these areas.

Furthermore the protection of villages under RR1 is quite inconsistent; land is being used incredibly close to Old Milverton for housing and particularly in the construction of the Northern relief road. It is been ignored that Old Milverton should be protected by RR1: "rural areas which are subject to strong influences from the MUAs and which are relatively prosperous and have generally good access to services. For these, the main priority will be to manage the rate and nature of further development to that which is required to meet local needs, whilst ensuring that local character is protected and enhanced." It is clear that Old Milverton is as strongly influenced as other Warwickshire villages from the key MUAs, it is relatively prosperous and the residents are quite contented with their access to services. Therefore just as development sites, for instance those neighbouring Radford Semele (and still contacting the Leamington Fringe), have been rejected on the basis of RR1 so should the developments between North Leamington and Old Milverton - neither these houses, nor the relief road, nor the infill that would surely follow the construction of these two things are meeting local needs, the character is certainly not protected nor enhanced.

In discussion with Daniel Robinson at Warwick District Council he informed us that the Old Milverton to Northumberland road site is labelled as "an extension of urban land that happens to come close to Old Milverton", not as a rural site in itself, this is not consistent with sites eg R46 which is equally an extension of urban land that happens to come close to Radford Semele but is protected by policy RR1 in the RSS document. These inconsistencies persist throughout the SHLAA.

SECTION 3: More Appropriate Sites

Previously identified viable sites

The quite remarkable problem with the Council's plan is that a previous plan (Core strategy plan 2010) identified ample land within the district without resorting to construction on the greenbelt, this fact alone means that there must be adequate land elsewhere to build on, thus there cannot be exceptional circumstances to justify construction on the greenbelt land, when nothing significant (except the publication of the National Planning Policy Framework stating that greenbelt land should not be built on unless exceptional circumstances) has changed in the district. Indeed during this consultation the council has suggested that people objecting to the greenbelt land use must not just state they don't wish that land to be developed, but suggest alternatives; I propose to you that at least one valid alternative has already been part validated is the Core Strategy Plan and this can be used as a solution to ALL THOSE PEOPLE who are objecting to the greenbelt. At the Milverton Parish meeting the a senior officer of the council suggested changes had been made to the Core Strategy Plan's of building in the South due to infrastructure problems, however this is hardly sufficient to justify building in the North; a significant infrastructure investment in the South (akin to the Milverton relief road proposed for the North) could sort out the infrastructure problems there, and whilst significant investigation has gone into the South's infrastructure and congestion problems woefully little has gone into examining the North. In short selective investigations have been completed to rule out land the council has decided not to build on, whilst no such investigation has gone into land they do wish to build on. A carefully examination of current and future congestion in the North should have been completed before the plan was decided on (not after), it is now impossible to complete a post-hoc analysis without bias creeping in to favour development in the North. It is very clear from the congestion currently in the North that already exists that further development would only exacerbate this, whilst the South is already better placed with easy access to the M40.

Warwick District Council have argued that land in South Leamington is not as attractive to developers because concentration of development in that area may result in developers making less profit - financial gain quite clearly cannot be expressed as a "very special circumstance" to permit unnecessary development in the Geenbelt land.

Radford Semele

There is ample room to move a significant number of the greenbelt housing allocation into and around Radford Semele. This preferred options allows for 500 houses in Category 1 villages, this a low proportion relative the total requirement and across the Category 1 villages which are not in greenbelt land there should be a significantly more houses planned for there. The preferred options document does not identify those specific sites surrounding villages that are suitable to meet the 500 houses target, not only should this be done but it is very likely these villages could absorb more accommodation, potentially even a doubling and this would be preferable to current plans to build on the greenbelt.

Whilst at Radford Semele there is a possible argument against coalescence significant sites still remain; R67 and R41 total 11.16 acres, and seem to have been excluded due to the presence of gas mains, these gas mains require a 100m exclusion zone, however both sites could in fact be extended towards the gas main and remain outside the exclusion zone. Indeed the garden town approach to development would easily allow these exclusion zones to be incorporated into the required green space and cycle-ways that the council is so keen to provide. Professional advice suggests there is significantly more housing that could be built in this area near the gas mains and still conform to planning law, it is essential the council reconsider this and identify how to extend the provision in this non-greenbelt land. Furthermore the site boundary of R41 does not seem to follow and fence or hedge line and could therefore be extended significantly, even if there is a fence/hedge line the site could still be extended to include more land to boundaries further out, or boundaries could be completed. Flooding risk to the Warwickshire Exhibition Centre is stated as a risk, but this is over a km away and is of negligible import - this needs to be reconsidered and potentially simple flood alleviation methods installed. Furthermore site R56 to the West of Radford Semele was also identified as being suitable subject to alleviation of flooding issues and is an excellent site given that it would not contribute to coalescence, again the garden town approach to the development would allow the incorporation of flood alleviation schemes, and thus these schemes and this site (potentially also enlarged) would be far preferable to construction on the greenbelt. Any risk of coalescence between Radford Semele and Leamington is dwarfed in comparison to the consequences of risking coalescence between Leamington and Kenilworth/Coventry as produced by building on the Northern Greenbelt and it is far preferable to build here; indeed almost all towns across the UK have grown by inclusion of local villages and there is little reason why the open space between Radford Semele and Bishop's Tachbrook should not be used such given this is not greenbelt land.

Grove Farm

Grove farm also could provide additional housing, removing the need to build on the greenbelt; L09 we are told by David Barber (via Councillor Bill Gifford) has not been developed for the main reason of coalescence, but even if this site was developed there would still be 1km between built up areas, this would provide a suitable green wedge, though personally I believe building on this wedge would be preferable to building on greenbelt land. Indeed significant areas of land have been discounted as they would result in coalescence or the destruction of a greenwedge; however discounting these sites whilst building on greenbelt land is contradictory to the national government policy outlined in "Strategic gap and green wedge policies in structure plans: main report." The document states "There would be significant problems in giving strategic spaces and green wedges the status of greenbelts. Strategic gaps as greenbelts would reduce peripheral land development options on the edge of large settlements, often in sustainable locations. Problem over the interpretation of prominence and the possible need for safeguarding land would also occur. If green wedges were given Green Belt status then the area covered by a strong presumption against development would be more closely drawn into cities and large towns". This demonstrates that the status of greenbelt is above that greenwedges, so the wedges should be built on fir
Other Sites

Site L09 should be reassessed as it is more suitable than the greenbelt suggested to be built on, the problems outlined in the SHLAA are less than the problems with building on the North Leamington greenbelt. Site L09 is not in greenbelt land, objections that the land would need employment and infrastructure are no different to the problems identified with the greenbelt land the council intends to build on, and the development of the countryside is not an serious reason not to build on the land when in contrast you want to build on the greenbelt. The topography would not provent sensibly designed/developed housing.

It is quite simply idiotic that site W07 is not being built on, currently the council propose building on greenbelt land rather than improving the county by building on slurry contaminated land, which is in my opinion effectively brownfield land. Indeed the council even identify it as suitable for development once ground remediation work is completed.

W03 is exactly the same - it slurry contaminated land, identified as suitable for development after ground remediation works should be built on prior to brownfield sites. The arguements in the SHLAA regarding whether the market could support it is bizarre - if the market cannot support such land then certainly land to the North Greenbelt requiring a £28 million+ relief road isn't needed because there wouldn't be demand!

Furthermore considerable research and indeed I believe actual inclusion in the plan should go into the development of a new village(s) to the South of the district in the extensive non-greenbelt land there, such virgin land would be hugely attractive to developers, and there is ample space to build such a site without contacting existing rural settlements and therefore avoiding harming their character. Indeed I issue it as a challenge to the council and the planners to include such a site, using imagination to create a garden village, which would be a true innovation in our district and one of which all local residents could be proud.

Whilst it is clear that a plan such as the Preferred Options plan produced by the council cannot be expected to please every resident in every area of the town, it is the council's responsibility to listen to arguments that are based on clear planning policy and supported in numbers. The arguments produced against development of the North Leamington greenbelt are backed by a substantial number of residents and backed by firm planning policy either National (eg the National Planning Policy Framework), Regional (The Regional Spatial Strategy for the West Midlands), or Local (ensuring development is in accords with WDC's aims as stated in the consultation document). Opposition in the South from my experience is centred around a lack of infrastructure, schools, and an over-burdening of development there. None of these are firm planning reasons; the council have very clearly identified that local infrastructure can be put in place by developers and the M40 provides an excellent foundation for this countering that argument, wherever there is new development there will be new schools and the council must do more to persuade residents that this will be the case, and finally the concerns of overdevelopment are a "NIMBY (not in my back yard) argument backed up by no sound planning arguments - indeed there are plans to build a New Mildland City in the Meridian Gap is supported by national planners and shows that this region has the need and ability to support a substantial amount of housing in one area, and whilst nothing of this size is proposed for Warwickshire it quite clearly demonstrates that whatever the council proposes it would not be an overburden in an area that in now way risks coalescence with another town.

SECTION 4: National context

It is vital that all those involved in the consultation process do not become blinkered in their view, but respect the national context within which this plan stands. The importance of the "National Planning Policy Framework's" AND "Strategic gap and green wedge policies in structure plans: main report protection of the greenbelt land" have already been highlighted, as well as the failure of the current plan to take account of these - which I imagine will be a major problem when the plan is submitted to the inspectorate. There is however even more evidence of the importance of greenbelt land, which should be considered with regards to this plan.

The government's original proposals for planning policy (the draft national planning policy framework) provided very little protection to the greenbelt land, however it was immense public opposition to this with nearly a quarter of a million people signing a petition organised by the national trust (a scale unprecedented for a planning policy document) that resulted in greenbelt land being protected as per the final document, and as ignored by the preferred options plan. This clearly shows however the immense value the nation place in greenbelt land, and in the protection provided for it by the National Planning Policy Framework. The preferred options plan fails to take account of this and residents in the North, myself included feel it is of national importance to ensure the NPPF's protection are not ignored, particularly by an executive committee of the same political party as the government who instituted the plan, and we believe we would have national support if our arguments were to be wrongly ignored during the consultation. It is afterall the people of the nation that we wish to attract to Warwick District to live, work and play!

SECTION 5: The consultation process

Omissions from Consultation

Whilst trying to understand the Council's reasoning for what seems to be a highly unusual plan it has come to my attention that there are two key omissions from the consultation that are either being used as justification for the plans submitted, or used to contradict local residents views and arguments, this does not make for a fair consultation and produces the view held by many that the council are determined to build on greenbelt land to the North, and then find any planning evidence/arguments that justify their desires. This is not a sound grounds for consultation and it can only be made fair if such arguments are ignored. My chief concerns are listed below.

Senior individuals within the council have stated that previous opposition to development in South Leamington, particularly around Bishop's Itchington have prompted the need to force development on the greenbelt in this plan. If this were to be a valid basis for planning then it is of vital importance that such information is included in the consultation document - yet it is not. The absence of discussion on this matter within the consultation document, as well as the fact that this would result in a plan based on a popularity contest/political pandering rather than sound planning principles means that additional development in the South should not be excluded with resultant development on the Northern greenbelt. There has been tremendous resident opposition in the North (see submitted petitions of over 2000 individuals) alongside strong planning arguments dictated by National Planning Policy, which the council are compelled to follow, and on which basis the plan will be judged when sent to the inspectorate. It may not be possible to please all residents with the subsequent plan to develop the town, but the council's responsibility is to listen to the views of this consultation and build their plans based on the views of local residents that are supported by sound planning arguments.

Another senior member of the council has stated that the need to develop on the Northern Greenbelt stems from a need to provide worker accommodation for subsequent employment land at the Coventry airport site. However it is not identified in the consultation that such land has been allocated for this purpose and it would be impossible to allocate such land at the stage for which the consultation document was written (and the greenbelt land assigned to development land) as the document states with regards to the Coventry gateway site that "It has the potential to provide in the region of 14,000 jobs as well as facilitate major improvements to the transport network. The Council is supportive in principle but considers that further work is needed to justify the identification of this site." The (very senior) officers justification of such a site for Coventry housing is therefore an afterthought, not explained in the consultation document with no evidence base to suit such a project and a major omission from the consultation document. Furthermore such a claim that the land is to be used for commuter land with respect for Coventry is inconsistent as land closer to Coventry has been identified as suitable for development, yet not included as suitable land for the construction of housing. Additionally there is a huge expanse of greenbelt land between the proposed North Leamington greenbelt site and Coventry which would be closer, with reduced environmental/congestion impact that would be suitable for that housing. It is totally impossible to justify exceptional circumstances to build on the greenbelt to the North of Leamington for such a development in Coventry without a detailed analysis of the situation, which should be provided with evidence.

A further key omission from the document is that despite Warwick District council performing a study of greenbelt land between Old Milverton and Blackdown, which concluded that these areas had high greenbelt value, this information was consequently rejected from the consultation document, or if it exists and I cannot find it - then it certainly has not been used to sufficient extent.

Expectation that resident views/submissions to consultation will be ignored

I am deeply concerned about the nature of this consultation process, and I like very many other residents feel that our views will be ignored despite strong objections by letters submitted to yourselves, petitions, and exceptional attendance at public meetings such as the North Leamington Community Forum and Milverton Parish Council. Indeed we have been told one member of the council explicitly stated that residents should get used to the plan as it would go through regardless - quite clearly bringing into question the fairness of the consultation. National government policy states the importance of localism to ensure that the views of local people not ignored and I believe the council must take the views of North Leamington residents on board, and act on them.

The consultation process has asked for the views of local residents, which I believe have been strongly voiced in terms of not building on the greenbelt land to the North of the town. I believe it is the councils responsibility to listen to these views as part of the consultation, take them on board and change their plans accordingly. It is not the councils responsibility to argue with these views, cite counter evidence, or employ professionals to create reasons/argument to ignore such views. Indeed the council's documentation for the consultation has not provided all evidence that was used to create their plans, therefore limiting residents to only being able to provide their views and not assess and counter all the evidence. All residents could therefore do is provide their views, which must then, in my opinion by listened to and acted on, as there is nothing else they could provide. Furthermore the document is referred to as the "preferred options plan" however there are NO options as to which land could be built on, therefore as local residents have objected to construction to land on the greenbelt the council must then seek alternative land and submit this to the second consultation round with the greenbelt land removed. The council must not ignore over 2000 residents views resisting construction on the greenbelt because the residents (who are not planners) have not all identified land elsewhere, there is as demonstrated here alternative land, and it is the councils responsibility to search an alternative option.

The strength of opposition I have seen from local residents to not building on the North Leamington greenbelt demonstrates that if the council fails to take on board views of the residents as a result of this consultation then I firmly believe those views will only be expressed more strongly in the second period of consultation and stronger still following that if our views continue to be ignored. I and others would have no hesitation in involving national groups and media attention in opposing these plans, which I and others so strongly object to. It is irresponsible of the council to risk a failed plan. The council have repeatedly told us that if a plan is not submitted and accepted then developers will be free to build wherever they want and there will be a lottery of developments (this sounds remarkably like a threat to residents not to submit their views and oppose the plans), however in fact it is the councils responsibility to ensure that we are not left in this situation by taking on board, and acting on the locals views. It will be their fault, not ours if we are left without a plan. Furthermore it would be foolhardy of the council to risk the phenomenal cost in fighting local residents legally, on which I believe the council would have little no grounds to proceed, there are many far better things to spend money on. From the strength of opposition I have witnessed I have little doubt that if the council ignored North resident views then there is the demand and resources to pursue this fight further.

At a recent Milverton Parish Council meeting the chairman of the council announced to the approximately 150 people there who opposed the plans that they should not write to their local MPs. The people at the meeting had widely expressed their view that the council had failed to put in place National Policies developed by their MPs' government. I, and everyone else there saw it as entirely appropriate to write to our MPs, but again the Council seemed determined to allow nothing to influence their views and seemingly politically motivated plans for the county. This is furthered by the title of the consultation document - "Local Plan Preferred Options" for a plan that does not contain a single option as to the provision of housing land.



Online Submission Form and Information Provision

The online submission form that Warwick District Council has as the main way to register submissions to the consultation is not fit for purpose. Firstly the system is incredibly complex, with the need to register to even access the system, and once there a bizarre system that took me a considerable amount of time for me to fathom, once completed you must object on particularly items/sites - this is despite the repeated messages from the council that they do not wish people just to object but to provide solutions and say where they would like to build. The system is not fit for this purpose. In fact I have not before seen such a poorly designed online data collection tool. Furthermore a considerable number (of intelligent computer literate) people have failed to access they system and to understand how it operates. These points suggest to me that the council is less than interested in the views of the local population, for it would not have been difficult to design a far simpler, user friendly system, accessible to the young/old alike.

Leamington library has been advertised as a location of consultation information; however this could only be viewed once asking at the desk, from whence a box containing the information was produced. If the council genuinely respected the views of local residents an eye-catching display could be simply and cost-effectively be erected to attract attention. Similarly when visiting Warwickshire College to view the information, reception at the College did not in fact know that the information provision existed, it was only after ringing the council that the information became apparent.

These points are not intended to be taken as a "moan" but rather when taken together they demonstrate that it is not surprising that residents of North Leamington feel that their views will be ignored, and it is essential that the petitions and letters such as the one above are taken onboard and acted upon by the council to ensure the North Leamington Greenbelt is protected.

Concluding Remarks

The plans as they stand are totally unacceptable in that they involve greenbelt on the land to the North of Leamington Spa. In particular the land to the North of Northumberland Road and South of Old Milverton is one of the most used pieces of greenbelt in the whole district, with immense amenity and health benefits. The planned construction in the greenbelt is contrary to the national policies of the "NPPF" and "Strategic gap and green wedge policies in structure plans: main report." The immense local opposition to this plan and the National Policy of Localism mean the greenbelt sites to the North of the town should be excluded permanently from the plan.

The council has a choice; they can devastate the character and attractiveness of a unique Royal Spa town, that has been cherished and lovingly developed for centuries OR the council can seek an alternative option. The alternative option will need their imagination and determination to build on the views of the populous, but it will build a town of which we can be rightfully proud for decades to come.

See attached

Dear Sir,
My preferred option plan consultation feedback:
GREEN BELT - National Planning Policy Framew9rk requires "very special circumstances"
The Green Belt covers only 13% of the area of England. This preferred plan is for 10,800 dwellings
and 43% of land used will be green belt. How can this be justified when there is still plenty of white
field land available south of Leamington? Presumably the "very special circumstances" come into
effect when the 57% development on white fields has been used. This growth is scheduled to take
15 years at a constant annual rate of 555 houses per year. 57% of 15 is 8.55. So it will be eight and a
half years before these "very special circumstances" (ie. white field sites are filled and green belt is
needed) comes into effect. By then another plan will have been made!
I disagree strongly with any relaxation of the green belt which is there to stop conurbations merging.
This plan will leave less than 1 Y, miles between ~Kenilworth and Leamington.
Why does Kenilworth need to expand? It has always been in the past a much smaller town than
Leamington and Warwick and mushroomed massively in the 1960s, and also in the 1980s when
Knights Meadow and the Lindisfarne Drive estates were built. Why should we let this happen again
to keep pace with the other towns? Councillors tell me that the Green Belt is strangling Kenilworth.
This is precisely its purpose. We should be grateful that our town has these safeguards in place to
protect it.
770 dwellings equates to about 1770 people which is almost a 10% increase in Kenilworth's
population in an area which is quite detached from Kenilworth and is not likely to make its
inhabitants feel a part of the community. The town centre should be in the middle of the town. Far
too much development is on the east side and it should now be the turn of the west, if the Green
Belt has to be sacrificed, where there is no risk of it merging with other towns and which would be ~
short walk to the centre of town without cars needing to be used.
THICKTHORN.
How was the Thickthorn site chosen?
Surely not because it abuts the A46 which is noisy both day and night. Was a site visit made to see
just how noisy it will be for all the inhabitants? Were decibel readings taken at various points up the
hill to ascertain the suitability of this site? The noise is particularly bad on a hot sunny day with the
prevailing south-west wind. What about HS2 whose boom will be heard at Thickthorn as it passes 18
times per hour in both directions on the EAST side? This estate will be on the flight path of Coventry
*
International Airport where there is no restriction on night flights and jets scream right over the
proposed development land and at a very low level on their way to Baginton as they have to avoid
the Birmingham flight path, (which is also noisy) as this is the crossover point of the two flightpaths.
It would be a very selfish decision to commit people to a life of misery with all this noise even
through double glazing. This is not the same scenario as the Woodloes where houses abut the road,
which at that point is 4 lanes instead of 6, where there the A46 is the other side of the natural sound
barrier of Primrose Hill. At Thickthorn noise is impossible to stop owing to the contours of the land
which is a basin causing the noise to be trapped and sweep up the hill towards dwellings. The noise
is incessant both day and night. It is an ideal location for the sports fields which are already there,
where people can go away at the end and not have to endure it 24 hours a day. Office buildings
along it will not dissipate the sound.
TRAFFIC
Having 1200 cars discharging from the estate each morning will be a nightmare and cause even
longer queues up Birches Lane and into Glasshouse Lane. It will be a worse effect than the horse fair
there every day of the year. Updating St Johns gyratory presumably means traffic lights which will
cause long tailbacks into the town centre as they have priority under the give-way scheme.
I cannot understand how a dual carriageway between Kenilworth and Leamington will help as all the
traffic will have to funnel in at either end and will just result in 4 lanes of slow moving traffic instead
of 2. Creation of bus lanes will in any case limit traffic flow to one lane in each direction to speed up
a bus every 10 minutes if you're lucky, and nothing will be gained in terms of traffic build up.
There are no points wide enough along Glasshouse Lane for the junction of a spine road, as the
corner with Rocky Lane is on a dangerous bend. In any case, Glasshouse Lane is a unique and
attractive feature of 1930s period landscaping, a Kenilworth gem, which should be preserved and
which junctions along its length will destroy.
NUMBERS
Where do these figures come from for 10,800 houses?
It is in the interest of the District Council to have as many new houses as possible, as they receive 6
times the Council Tax from the New Homes Bonus Scheme for every new dwelling completed and
more than that if they are affordable housing.
This plan is not led by suitability but the interest of landowners to sell off their land for housing.
These are not sufficient grounds for this massive increase in population concentrated in a small area
as the plans make little use of rural area development. Lots of villages need regenerating. Radford
Semele has had no growth since the 1960s and has a school in place already. It has good transport
links to the M40, Fosse Way and Leamington Station and IT IS IN A WHITE FIELD ZONE. If such a large
number are needed, they should be put in the South Leamington area on white field sites as
Leamington already has all the amenities (parks, department stores, nightclubs, cinemas) jobs to
support it. This is a Warwick District Council plan not a Kenilworth plan and there are plenty of other
places where housing could be built.
WHAT ARE YOU, OUR TOWN COUNCIL, DOING?
Old Milverton and Blackdown Parish Council are sending a formal objection on behalf of the area.
Where is the formal OBJECTION from our town council on behalf of its 23,000 residents? Our town
should be protected from losing its identity.
Offices are not needed -lots are available to rent. St Johns next to Jet garage, old Pottertons site.
Industrial land is not needed as Archery Fields is empty with fountains and wasteful landscaping at
the entrance.
You cannot make people live and work in the same place. These ideas don't work. Kenilworth is not
an industrial town and should not strive to be such.
THE A46 WAS PLACED WHERE IT IS TO KEEP IT AWAY FROM THE POPULATION.
Why were these ideas devised secretly without asking the people who voted for you their opinions
before consulting the district planners?
CONCLUSION
Population figures should be challenged.
Green belt should be protected.
Consideration of the effect on the HEALTH of people living alongside a motorway with NOISE and
POOR AIR QUALITY owing to constant fumes and directly under a flight path with NOISE due to very
low flying aircraft should be made.

New Local Plan

Please accept this letter as my formal objection to the "New Local Plan" document dated May 2012.

The specific areas I object to are, the housing proposals on:

1) Land at Europa Way and Gallows Hill (1600homes)

And also:

2) Land South of Sydenham and east of Whitnash
3) Land at Woodside Farm, north of Harbury Lane, Whitnash
4) Land west of Europa Way, Warwick

My objections are based on the following:

* On the Understanding that we need further housing I can appreciate that the land on Europa Way and Gallows Hill (Myton Side) and the end of Harbury Lane could be used this would create basically another Warwick Gates Causing some serious infrastructure problems i.e. Roads Schools etc but to then add a further 1600 homes into the mix is totally unacceptable. This would lead to such infrastructure problems that people would start to leave the area as they could not stand the hassles which is the complete opposite of what is trying to be achieved (in creating a nice environment to live in)

* An additional 3000 houses on the south side of the town creates an imbalance to the area as it would mean that with Warwick Gates and the proposed additions there would be around 4400 houses in that area with only 2 roads to get in to town? Taking an average of 2 cars per family that would me there would be an additional 6000 cars to add to the 2800 already in Warwick Gates. This is an wholly unacceptable and unfeasible suggestion and myself would look at moving it already takes me 25 minutes some days to get from my house to the Coventry road in Warwick.
* Large estates lack social cohesion which leads to anti social behaviour and poor education performance. This proposal is the same size as Warwick Gates, Chase Meadow and Hatton Park all put together; what kind of community is likely to be born as a result of this development? Especially as 40% will be social / council housing in an area with poor transport links to the areas that give the most support to the under privileged i.e. the town centres.

* We think that such a number of new homes contradicts the vision that Warwick District Council has, "providing a mix of historic towns and villages set within a rural landscape of open farmland and parklands".

* Utilities, Services (Police, Dentists, and Doctors etc.) are all stretched to the limit now. With both the major hospitals only accessible across congested bridges over the river Avon, we fear for how long it will take emergency cases to get the medical resource they need. Siting the vast majority of the Housing still fits this problem and increases it.

* The huge increase in traffic arising from at least 8000 new cars in this area will result in pollution and add to existing air quality problems in Warwick and Leamington town centres. At peak times the traffic along Europa Way (even as far as the J14 M40), Gallows Hill, Tachbrook Road and Tachbrook Park Drive are grid locked, your proposed development is situated right along these roads, simply adding to the congestion already experienced. So far you have failed to fix the current problems and there is no evidence on your part to suggest that you will, even for when this proposed development is complete.

* We see no sense in carpeting our green spaces with housing for a mobile population to travel elsewhere. Our remaining agricultural land should be preserved to feed future generations.

Why did you decide not to create a brand new settlement within the district (like Norton Lindsey) maybe below the A46/J15 inter-change where direct links to the road network are very easily accessible? A new town there would have fantastic access to Dual carriage ways and the Motorway network a new schools could be planned including Secondary Education as most schools are full already

I do believe that some housing maybe needed for organic growth within individual communities; however, I feel this should be decided at a local level with the support of the local people not imposed from the Government in a top-down approach as it is at the moment and certainly not to the numbers you are suggesting.

We urge you to rethink the development placements radically; to look again at regeneration possibilities in the towns, to work with owners and developers on imaginative schemes to bring forward brown field sites and possibly a new village/town in a rural position for housing developments.

Submission Attached.