Objection to development on this site

We purchased our house in September 2011, after looking for a semi-rural location near Warwick. Our property backs onto farmland, part of the site demarcated as a potential 'preferred area' for the development of 1600 dwellings along with other facilities. We have concerns that this potential development will hugely adversely affect the area and ourselves, and while we fully accept that new development is necessary, we believe this development would be far more suitably placed elsewhere, for the following reasons.


1. This wedge of green land forms a 'partition' between Leamington Spa and Warwick, helping the two towns to maintain their distinct identities. This is a factor which was highlighted in the document 'Core Strategy Preferred Options: Report of Public Consultation', published in February 2010. Seven hundred out of 756 responses in response to this site being hallmarked for development were objections. It is fairly difficult to comprehend that, given this overwhelming majority of people not in favour of developing this area, the council now believe it is a good idea. Other objections raised in this document were:
* Inadequate infrastructure to serve development
* Environmental impact - loss of habitat & arable land; increased pollution

2. The access to this site would cause enormous inconvenience while the site was being developed. The road into Warwick (Banbury Road) is already awful at rush hour, and construction traffic is just going to make this worse. The traffic commuting to and from Warwick Technology Park has already been signposted to use the Banbury Road, and the volume of traffic on this road would increase hugely. There have been a number of accidents including two at the Barford junction and one involving a lorry at the M40 junction roundabout in the last 6 months alone.

3. Once completed, the enormous increase in volume of traffic, even with new traffic measures such as signals, would mean our commute to work would be made longer, and more expensive, which was a reason for choosing to live in this area in the first place for us.

4. There is no mains gas or sewerage to this area: We have concerns as to how these would be implemented without significant noise and disruption to those living nearby.

5. Our property currently benefits from a beautiful view over the Warwickshire farmland to the rear. We find this extremely beneficial, and this is one of the major reasons we chose to purchase a house here, as the rear green is safe and peaceful for children to play in, as we anticipate to start a family while living here. This would be ruined by a view over a large development. The presence of a large development backing onto our garden would hugely adversely affect our quality of life, due to noise, being overlooked, traffic etc.

6. The value of our property would be adversely affected if this area were to be formally planned to be developed. As mentioned before, one of the main reasons for us buying this property was the location, and if we'd wanted to be overlooked in a suburban area we would not have bought this house. Resale value will be massively affected if this is to go ahead, meaning that we will stand to lose a substantial sum of money, which, especially in the current economic climate, could have a devastating effect on us.

7. Warwick is a beautiful town, and is just that; a town. It should not have its historic and country feel taken away by sprawling estates in areas which are currently adding to its rural appeal. Tourism would be adversely affected by this choice of site, as it would be visible from Warwick Castle and its grounds, and severely detract from the otherwise beautiful setting it currently enjoys.

As an resident of Warwick Gates since it was built, I echo the sentiments
relating to traffic congestion & concerns about safety.

Additionally the construction of further homes in this location will only
add to the pressures on existing infrastructure, the result of very poor
planning for Warwick Gates. Disjointed schooling, poor recreation
facilities, a stretched medical centre and basic amenities - have you tried
parking by Whitnash or Warwick Gates shops & community centre? - are
already unacceptable.

Most importantly this has led to a lack of a fundamental community focus &
poor cohesion between residents, reflected e.g. in anonymity & anti-social
behaviour from those 'no-one recognises,' that will be simply exacerbated
by the construction of additional homes.

This is not just a numbers game, it's about creating healthy communities,
and existing residents are being failed, let alone new ones.

Lack of easy access to Warwick or Leamington via existing bridges and consequent traffic chaos such as we already have on this route.

Lack of easy access to Warwick or Leamington via existing bridges and consequent traffic chaos such as we already have on this route.

Road congestion in this area is already unacceptable at peak times.
Further pressure on already strained local services.

Housing allocation to the south of Leamington would be appropriate given the better transport links on this side of the urban area. The identification of the site as being appropriate is supported by its previous inclusion as a site in the Core Strategy Preferred Options.

The Joint Parish Council objects strongly to this proposal on various grounds - The housing numbers are excessive for this location and can only make the traffic issues which currently exist through our villages much worse given that a significant percentage of the new households will add to the traffic flow into Leamington/Warwick at peak times, despite proposed improved access to the M40.
Building the whole of the area will have a deleterious impact on Warwick Castle Park and the approach routes to both L/Spa and Warwick.
There will be unecessary loss of good agricultural land and important rural landscape.
The shape of the site "projects" inappropriately into the rural area and creates further future infil opportunities.
If this area is to be included at all it should be held back as long as possible and only utilised if the level of demand materialises.

Whilst I understand the attractiveness of some aspects of this site (proximity to the M40 etc) the volume of proposed growth seems excessive. It is impossible to see how a development of this size will deliver WDC's stated vision to "make Warwick District a Great Place to Live, Work and Visit" for those in the vicinity, for example the Warwick Gates development. I can see only negative outcomes for those living in the area, particularly increased traffic congestion and reduced house values.

Development of this site will increase Urban sprawl and intrude into present open space. Traffic from this site to Stratford will travel through Barford and increase the congestion in High St and Church St which are already gridlocked at peak times.

The existing congestion in this area is already an issue with those commuting into Leamington from the motorway. Changes have been made to the Gallows Hill junction to ease this congestion but to the detriment of those on the Banbury Road heading into Warwick which now builds up past the Barford turning every day at peak times.

Development of this site will create growth which will intrude into the space dividing Leamington and Warwick from the villages of Bishops Tachbrook and Barford which could eventually lead to existing settlements merging in direct contradiction of PO3.
The effect of developing this site on the boundary of Warwick Castle Park will change the rural nature of this area and impact on this important District asset.
Additional traffic from this area will use existing busy roads into Warwick and Leamington and create more congestion. Traffic travelling North and going to Stratford will cause additional problems in Barford on the already overloaded narrow roads of High Street and Church Street.

creates urban sprawl - roads in the area are already cogested -brownfields sites should be used before agricultural land

Rather than extend to agricultural land and to prestige areas round Warwick Castle, extend areas that are nearer to recent housing expansion sites and nearer to established areas of employment and where there is good road access as proposed in earlier attempts to create a Local Plan.

PO3 refers to the avoidance of 'growth which could lead to existing settlements merging'. (Local Plan Summary pp 4 - PO3 paragraph 1). I am referring here particularly to the area alongside the old Banbury Road (A4100) which will bring Warwick urban area much nearer to Barford.

We have been advised to write to you re New Objections to the Core Strategy Plan.

We wish to object to the expansion plan to build 2700 new homes in the south of Warwick (P04 Distribution for Sites for Housing: Location 2 and 3).

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

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon bridge, constrained road layout and traffic calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times. (PO14: Transport).

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

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

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

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

We wish to object specifically about the development zone 2 to the west of Europa Way. This area had been identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.
Furthermore, the land West of Europa Way is rich agricultural land which has been under the careful stewardship of the Oken Trust and Henry VIII Trust. There are also wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc. (PO11 Historic environment, PO15 Green Infrastructure).

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the run off is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road . (PO18 Flooding and Water).

We object to the fact that the area of restraint is one of the first to be developed under the proposals, and should with immediate effect be designated as the last site to be developed so as to protect this area until a viable alternative is found.

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

Therefore further development should be concentrated in areas where road improvement is possible, air quality is not already in breach of regulation, access to A46, M40 and rail links are direct so commuting traffic is not funneled through Warwick's congested urban centre.

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

I believe the development of this site would be detrimental to the setting of Warwick Castle and the approach to Warwick from the south, which would also adversely affect tourism. Also even with road improvements the increase in traffic, combined with that from the development North of Gallows Hill, would lead to more congestion on the roads into Warwick because there is only one bridge over the river and all the facilities including the hospital are north of the river.

Building on this area will create serious difficulties in the traffic on the roads particularly the Europa Way/Myton Road/Princes Drive junction. Traffic is already at stationary/stop-start conditions 3 times a day. The building of 2 new supermarkets around this junction will create even worse traffic congestion. The roads cannot take all this traffic.

Developement of this area will agravate further the traffic problems in the area, particularly through Barford.

Please see attachment relating to Policy PO4 Distribution of sites for housing and objections to pargraphs 7.24 to 7.33 and:
1. Scale of Green belt release north of Wrawick and Leamington;
2. Proposed Allocation South of Gallows Hill/West of Europa Way, Warwick
3. Proposed new alternative allocation south of Harbury Lane, Warwick

All sorts of objections: urban sprawl, aggravation of traffic problems entering and leaving Warwick over its only bridge, loss of countryside, etc. Also, it projects so far out of Warwick that it seems bound, in the fullness of time, to lead to the "coalescence of settlements" which is, according to your paragraph 7.7 (PO3), to be avoided.

I object to change of use of this land from farming to housing. It will cause immense traffic congestion for the surrounding roads and be very visible when entering or leaving Warwick or Leamington from the south.

Concerned at the level of houses proposed along an already congested area - bigger roundabouts will not solve much heavier traffic flow.

South of Gallows Hill/ West of Europa Way.

The proposed allocation of 1,600 in this location is not supported. It is our considered view that an allocation of this scale, in this location would result in an un-sustainable form of development. The proposed allocation, as graphically shown on Map 5, does not encourage a compact urban form but instead would result in a linear form of development stretching out into open countryside. With no existing services within a reasonable walking distance, and prospects for viable new or improved public transport services in the area considered limited, we believe that the allocation would encourage car based journey with resultant negative impacts on existing local highway infrastructure and traffic flows, in particular, those along the A452 (Europa Way).

It is interesting to note that this site was previously submitted to the Council for housing development as part of the preparation of the Core Strategy. However, based on an assessment of the sites availability, achievability and suitability as a housing site, it did not make it on to an 'Amber' list of potential sites to be considered as part of the Strategy. The Amber list was further whittled down to a list of 'Green' sites which was taken forward and included in the Preferred Options version of the Core Strategy.

This development must not take place. The road from Greys Mallory into Warwick, from the M40 (north & south) & local traffic, is most impressive, through undulating country, crossing watercourses and woodland around Castle Park so that almost the first thing that the tourist visitor sees is the bridge over the Avon and the views of Warwick Castle. That is the Warwick Wow Factor and attracts a constant stream of photographers. The approach depends on views across the countryside, which this year, were particularly spectacular with many of the fields in flower with Oil Seed Rape. To cover this with 1600 houses is wrong. It is part of the Castle approaches.
Tourism is a large part of our local economy that WDC is trying to promote and destroying this route in would be completely counterproductive.
The proposed Green wedge, an excellent move, will protect the Tachbrook valley up to Europa Way. Why destroy it at the point where it approaches New Waters put a mass of housing between it and Castle Park.
Additional traffic from 1600 homes plus employment on a road system that is struggling now does not bode well for traffic flows whatever traffic flow models say.
The pollution risk to the Tachbrook, that crosses the land from east to west, feeding into New Waters that drains into the Avon, is unacceptable.
The farming land is Grade 2 agricultural land. Demand for land of this quality for food production is rising, which just for reduction of food miles alone, is an environmental imperative.

This proposal would severely harm that last remaining rural appraoch to Historic Warwick.
There is not sufficient evidence to show that this rural site is needed for new housing. My representations in 7.1 and 7.2 cast significant doubt on the rural land needed for new housing.

As already stated in objection to PO4 [The possible negative impact your proposals will have on the Warwick Gates community.]

Scanned Letter

I have been advised to write to you re new objections to the Core Strategy Plan.
I wish to object to the expansion plan to build 2700 new houses to the south of Warwick.
Warwick District population has already increased in the last eleven years by more than twice the Warwickshire and the national average.
This development will considerably increase the traffic "flow" in Warwick, which is already at a standstill at peak times. The proposal to modify the island at the Banbury Road / Myton Road junction will not improve this flow as the problem is in the historic town, where it has recently been further slowed by the traffic calming measures in the town.
Considerable work will be required to the infrastructure as water, sewage, drainage etc are already at full capacity.
This development to the west of Europa Way would be in the supposed untouchable green buffer zone which was supposed to separate Warwick from Leamington Spa, to prevent it being one urban sprawl.
I would therefore ask Warwick District Council to reject this proposal.

Housing Allocations.
We are concerned at the inclusion of Map 2 in the full document, which appears to include land not shown in the preferred options Map 4. Does this mean that sites shown on this map could potentially be reconsidered as development options?

South of Gallows Hill, west of Europa Way. Option 3.
This site bounds Warwick Castle Park along much of its eastern perimeter.
Development up to Banbury road would be extremely detrimental to the Grade I registered Warwick Castle Park. You will be aware of the history of Warwick Castle Park. The new line of Banbury Road, from the Asps into Warwick was constructed in order to enlarge the park, to enable the construction of the much larger lake, New Waters, which actually extended across the new road, but finally, it was part of the design of the park itself. The second earl, who was responsible for the enlargement of the park was working on his design for the approach to the castle from 1777. Instead of the town and castle coming into view all at once, as it had formerly done, the alignment and landscaping of the road produced a progressive unveiling, beginning with the spire of St Nicholas church which appears in the centre of the line of the road. Gradually parts of the town appear, and then the explosion of the view of the castle from the bridge. This magnificent effect would be irreparably damaged if development were permitted on the scale indicated and so close to the road. This is the setting of the park, the castle and of the town itself.

The eastern verge of the road is well treed over much of this length, but the views between the trees are long ones, as the land is comparatively high. The Technology Park is itself a regrettable but moderate intrusion and the recently constructed access to a caravan park which actually sits on part of the park, and about which we were never consulted, is visual vandalism. However, the existing small suburbs emerge discretely from the landscape and do not offer the visual competition that a mile of sprawling suburb on elevated ground would bring.

We therefore strongly recommend that this option be withdrawn or the boundaries be reconsidered, allowing the immediate view from the road to be rural in character and so respect the setting of the park.
Designating the edge of the development as "amenity" land would not be an acceptable alternative, as this would create suburbia just as much as houses would.

Loes Farm. Option 9
We observe that this proposed allocation has been reduced from the original, presumably to avoid inclusion of the registered landscape of Guys Cliffe. However, the setting of the landscape is wider than the designated area. Contrived views within and out of the gardens are a major characteristic of the landscape. The Register description enumerates the land acquisitions made by Bertie Greatheed in order to create small areas of parkland. Loes Farm was bought for this purpose from the Earl of Warwick in 1824. It gave him control of views to the west of the house, including of the Como Pit, and to Gaveston's Cross. The buildings of Loes farm are mentioned in the register description as an incident in the view.
The development of this part of Loes Farm would therefore have a detrimental impact on the historic designed landscape. It would impinge on important views, and would bring development right to the walls of the kitchen garden, which dates from before 1786.

We are therefore strongly opposed to the inclusion of this site within the preferred options for development.

Other sites
We hope to see more information about the proposals for infill sites in the towns and villages. As the proposals now stand there is the potential for damage to the character of neighbourhoods and adjacent sites. Examples are the well-treed Riverside House site which contributes substantially to the character of New Milverton, and the vague nomination of a hundred houses for Barford, where the locally registered landscape of Barford House is already under siege by a development proposal. We hope that this land will not be assigned for part of the allocation.

There are likely to be similar sites in the other named villages also exposed to damage. It is important that there be design guidance for the development of some infill sites in the towns and in the villages in order to achieve the best outcomes.

Policies
We are pleased to see the intention of excluding garden land from development.

We are also pleased to see the intention expressed in PO 11 to provide policies to protect the historic environment, though we are alarmed that the failure to include draft policies in the present consultation document may result in hasty and imperfect drafting at the next stage.

We hope that the policies that are produced will be at least as strong as those which currently apply. We appreciate that the present recommendations for integrated protection of heritage assets will require considerable re-drafting of the current policies. We also hope that adequate provision will be made for the inclusion of built structures in the local listing regime, as this could give protection to some garden structures which are currently vulnerable.

Scanned Letter

Introduction

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

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


The Preferred Options (PO1 to PO18)


PO1 Level of Growth

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

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

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


PO3 Broad Location of Growth

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

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


PO4 Distribution of Sites for Housing

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

Sites:

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

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


PO5 Affordable Housing

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


PO7 Gypsies and Travellers

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

PO10 Economy

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

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

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

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

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

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


PO11 The Historic Environment

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

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


PO14 Transport

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


PO16 Green Belt

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




The Key Issues


1. Vision and Growth

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

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

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

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

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


2. Sustainability

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

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

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

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


3. The Projected Housing Requirement

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

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


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

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

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

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

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

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

3.3 We have other major concerns about the population projections.

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

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

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

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

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

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

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


4. Proposed Locations for Housing


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

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

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

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

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

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

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


5. The Green Belt.


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

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

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

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

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

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

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

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



6. Employment Land Proposals

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

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

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

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

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

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

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

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

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

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

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

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

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

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