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

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 (P03 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. (P0 14: 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 and Banbury Road at peak times. (P0 14: 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. (P02 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. (P01 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. (P01 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. The view from Warwick Castle will be one of 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. (P01 1 Historic environment, P015Green 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 Maims 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. (P018 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.

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Towns, in 2012 more than any previous time, need to remain distinctive and identifiable as separate entities. This is the challenge facing Warwick and Leamington together with outlying villages such as Old Milverton and Radford Semele.

Failure to heed this policy will lead to the 'conurbation effect' which is visible at first hand throughout the urban area of the West Midlands where once separate and distinctive towns have been 'connected up' so that today many residents have no idea which of the villages and small towns they truly belong to ( eg are we in Moseley or Kings Heath. ) The very real outcome of development west of Europa Way is likely to be an amorphous mass of housing in place of the green wedge which currently and most appealingly exists between the two towns.

It would also be directly contrary to the Council's own statements and aims in para 9.11 and para 9.13 of the earlier District Local Plan 1996 - 2011.

This endorsed the desirability of protecting areas of restraint which 'preserve open wedges that separate particular elements of the urban form' eg the west of Europa way wedge which uniquely provides an open corridor between the south Leamington urban mass and south Warwick. It is part of a longer corridor which has historically separated the two towns and helped them to maintain their individual identities ie the Avon valley past Rock Mill, the Edmonscote meadows, the Grand Union and the farmland west of Europa Way.

In para 9.11 of its Local Plan the Council itself observed that 'it is important to protect the areas of restraint from development proposals that could alter (their) predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate (one urban area from the next)'.

It's difficult to see how this could be better put. This is precisely the nature of the land west of Europa way. It is currently good farmland and serves as a cordon separating the towns of Warwick and Leamington making it possible for them to retain distinctive identities and loyalties.

In both 2006 and 2010 the Council rejected a proposal to remove the designation from this land using these very arguments.

In para 9.12 the earlier Local Plan observed that Government policy accepted the importance of protecting open space that contributes to the character and attractiveness of the urban areas. There is no good reason why the concept of 'sustainable development' should override this. The two objectives can be and should be compatible. If an area has been identified as an area of restraint this is because there is good cause. The related Structure Plan made it clear that areas of restraint such as this had a fundamental role in making urban areas attractive places in which to live.

One of the attractions of our District is the distinctive characters of Warwick and Leamington. Merging the two in to one urban mass will put this distinction in jeopardy. This area of restraint serves the 'fundamental role' outlined above.

It will be no surprise therefore that at para 9.13 the Council observed that, in defining and implementing Areas of Restraint, consideration had been given to the need to protect sensitive areas so as to ensure that the character and the setting of (existing) settlements is safeguarded.

In recent times therefore the Council have given consideration to the character and appearance of this very area and concluded that it should continue to be protected by an area of restraint. In the short time since that exercise, the force and basis of the arguments in favour of it being designated an area of restraint cannot have changed.

It is not as if there is no alternative which would not require the destruction of this separation belt. There is still space on the western edge of Warwick where development would not link up with any other historic entity. This land may already be allocated to non residential purposes but another business park is hardly a priority when there is so much empty space in existing ones. Some parts have been rezoned already and there seems to be no reason why the remainder cannot be treated similarly. Looking at the example of the Warwick business park where commuters living outside the town are 'bussed' from the station by their employers and to which commuting traffic travels right through the town centre it does seem that any new jobs provided may not so much benefit people actually living in the two towns (including any new housing) but people choosing to commute from further afield.

River Crossings and Road Access to Leamington and Warwick

There is another concern relating to the river crossings and the impact of large scale development south of the river on the amount of traffic routinely using them. The rivers Avon and Leam serve as a barrier between the southern districts and both Leamington and Warwick town centres.

From any development off Europa Way there are only two effective corridors, both of which are already heavily used commuter routes leading in to Warwick and Leamington respectively from the M40. Warwick is served by one river crossing and Leamington by the Princes Road and Avenue Road bridges. However the latter effectively share the same corridor as access to them is through the 'funnel' of the Princes Road Railway Bridge and the section of Princes Road bounded by the new Morrisons superstore and the retail units opposite. (If, as has been mooted, a traffic light controlled crossing is placed here to link the two, it can be expected that this 'funnel' will have even greater repercussions for the flow of traffic).

This is the reason why the Myton Road has extended periods of congestion already as traffic heads along it for one of the two north-south corridors. Anyone who regularly uses the river crossings at peak hours on weekdays or in the middle of the day on a Saturday will be aware of the high density of current traffic. Europa way itself is one long queue from end to end in the morning and evening peaks. The Ford (now Morrisons roundabout) already causes traffic to back up on both sides (along the Myton and Old Warwick Roads) largely because of the flow of traffic from and to Europa Way. At the other end of Myton Road commuter traffic using the Banbury Road in both directions (north towards Warwick or south towards the Business park) causes a similar problem

It seems extremely unlikely that there is scope for more bridge points linking north and south of the river, so we are left with what we have and the associated traffic queues generating as they do unsatisfactory levels of noise and emissions.

The development of this land will only make matters, particularly along Europa way and the Myton Road, a great deal worse both for the residents of those localities and those commuting in.

Traffic
The plans are going to grid lock Warwick, which is already gridlocked every morning. Building homes to the south of the town will only increase the pressure on the Myton Road/Banbury Road and due to the ancient bridge which cannot be made any bigger and the fact that Warwick School and Myton School contribute greatly to the traffic problems - something which is much better when Warwick School are on holiday you'll note.

Your asking us to pass judgement on plans that aren't fully worked up, there is no guidance on where any new access roads may be (Myton Road, The Malins?), we have to assume, therefore we can't give our backing.

Your response that some of the traffic problems can't be solved is ludicrous and is turning a blind eye to the potential problems in the future - people will end up moving away from Warwick altogether - that may well solve your housing crisis...

Schools
So you build more houses south of the town and the people that live there need their children to go to to school, the catchment area is Myton School so does that mean you will also be expanding the school - there is no detail regarding this. As above, you'll add to the already congested traffic problems with more people dropping their children at school - yes they may be bike lanes and yes it may be within walking distance but unless you put double yellows all the way down the Myton Road then this will still not stop parents dropping off the children. Warwick School should also re think their current access points - they are responsible for a lot of the traffic problems.

Community
You talk about community but in our experience 'new estates' are a stepping stone, they don't build communities, most people move on after 3/5 years - Hatton Park is a very well laid out modern estate, and we enjoyed living there - but everyone in our road either moved or has moved since we left in 2009, how can this build a community?

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Specifically I 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 irrevelant. 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).

I 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. In essence, none of these objections has been resolved.

I strongly object to any material increase in the number of properties in Warwick and Leamington until the traffic situation in West St, High St, Jury St and Smith St has been resolved. Any increase in houses is bound to increase the traffic in those streets which are already well over capacity.

I would make the following comments about the situation:
* We have very large numbers of vehicles passing straight through the town centre including HGV and large coaches. There is an existing 7.5 tonne weight limit but no attempt is made to enforce it and it is ignored by all.
* I live in a 300 yr old listed building on High St. The whole house frequently vibrates when large vehicles pass by. Adding even more traffic can not be the right way to look after our heritage.
* I have the impression that the vast majority of the traffic is passing straight through. Can the council sponsor some research on this.
* The council have recently taken out the pedestrian crossings and put in raised junctions in the name of pedestrian friendliness. This has made the area very hazardous for pedestrians because neither they nor the drivers seem to know what the rights of way are.
* The recent work in High Street and Jury Street was very poorly executed to the extent that the raised junctions are falling apart already and the new surface had substantially worn off with 48 hours of its installation. To choose one incompetent contractor is unfortunate, to choose 2 would seem to call into question the competence of the council team. If they cant get a simple thing like this right, what guarantee have we that they can manage the work around these proposed new estates.
I understand that most of the potential solutions would not be the responsibility of the district council but it would be irresponsible to allow further development until the county council has sorted out the problem.

As a resident of the district I am against any significant new housing development that will put an increased strain on the infrastructure, especially the roads. In the feedback on the plan options that the Council has gathered it is clear that the majority of residents do not support the level of housing that is planned. In theory at least, the Council exists to represent the best interests of the residents, so I fail to understand why the Council is ignoring them.

The proposed figure of 600 new houses per year appears like a rabbit out of a hat - I've failed to find where this figure comes from or how it's justified. In the Preferred Level for Growth, section 5.6, figures of 250, 500 and 800 are offered, and 90% of respondents were against more than 500, so where did 600 come from and why is it being considered when it is contrary to residents wishes?

Arguments revolving around population increase and increased housing are somewhat circular - the two are linked and neither drives the other. What drives the need for new housing is the desire for growth - the plan refers to the "Government's policies of encouraging local authorities to embrace growth and that housing growth would support economic growth". It is assumed that growth is good, and desirable.
But perhaps the community doesn't want this. I for one value less traffic, less noise, less pollution, less housing built on agricultural land, less water run-off causing potential flooding, less light pollution. This is already a prosperous part of the country, we need only minimal growth to support our existing population (PROJ 4 of the Warwick District Council Strategic Housing Market Assessment).

In relation to the proposed Gallows Hill developments of 2700 homes, while this is an obvious location for new housing (whilst of course, not agreeing that it's needed), the route into Leamington is at a standstill twice a day already, as is the Myton Road which I live near. I cannot imagine how much worse it will be as a result of this development.

I studied the Strategic Traffic Assessment - Modelling Results document. I noted that the input to the analysis (figures applied to all housing sites) was based on the housing distribution of the Cape Road development in Warwick. I'm concerned that the mix of housing types for this development does not reflect what would be found in out-of-town developments, specifically those at Gallows Hill. A quick calculation based on the figures given on page 7 of the report gives an average per-household trip rate of 0.39 (for both AMPeakHour &
PMPeakHour) - based on the housing distribution of the Cape Road development. However, for the proposed housing distribution for Gallows Hill, (based on information received from WDC Planning Dept) - then the average per-household AMPeakHour trip rate rises to 0.69, and the PMPeakHour rate to 0.79. These figures are an increase of 62% and 100% respectively over the figures used for the modelling exercise. When you take into account that this discrepancy applies to the largest development in the area, which connects to roads that are already at a standstill at peak times, it questions the validity of the whole modelling exercise and I would say renders it meaningless. I have sent these observations to the WDC Planning Dept.

Secondly, one thing I've not found in the whole traffic strategy is any sort of limit to the traffic on a road. The traffic modelling exercise seeks to minimise traffic queuing but places no limit on it.
I see queue lengths of 50 to almost 100 in the modelling results, but what does this mean? 1/2 mile queue? 30 minutes wait? There must be a point where the amount of traffic becomes unacceptable in terms of delay, quality of life, pollution etc, such that it would be irresponsible to put plans in place knowing that this limit would be exceeded. What is this limit? In the absence of such a limit, it would seem that new developments can generate new traffic in a completely unconstrained way, potentially to the point of gridlock. Such unconstrained growth would appear to contradict the National Transport Policy's goal "To improve quality of life for transport users and non-transport users, and to promote a healthy natural environment."

I wish to express concern over the plan to build 2700 new homes in the south
of Warwick (P04 Distribution for Sites for Housing: Location 2 and 3).

The intended creation of new employment opportunities towards Coventry
(PO3 Broad Location of Growth) will result in a greater number of vehicle
movements at peak times. Myton Road, Banbury Road and Europa Way are
already far too congested at peak times; there will also be increased pressure
upon the road layout of historic Warwick. (PO14: Transport). Given that the
bridge over the Avon (a Scheduled Ancient Monument and therefore without
scope for widening) and the traffic calming measures in the town centre already
constrain traffic flows, I am unconvinced that improvement to the Myton Road/
Banbury Road junction (PO14: Transport) would be effective.

I am also concerned about air quality, and in particular the likely increase of
Nitrogen Dioxide 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 even higher with the increased traffic volume resulting from the
Local Plan preferred options. (PO12 Climate Change; PO14 Transport). There
needs to be a radical plan to ensure the use of sustainable transport that does not
exacerbate the existing problems of congestion and pollution.

Warwick District population has increased by 12% since 2000, which is
approximately twice the rate of increase for Warwickshire; twice the national
average increase, and over 3x the increase for West Midlands. 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). Current infrastructure is at capacity; it remains to be seen whether
Community Infrastructure Levy will actually address the shortfall.

Development zone 2 to the west of Europa Way was identified as an area of
restraint at the time of planning the Warwick Technology Park, to create a green
buffer zone to separate Warwick from Leamington Spa, and to prevent the two
towns becoming one urban sprawl. In addition, the land West of Europa Way
provides valuable wildlife habitat and connectivity (PO15). The loss of this
buffer is highly regrettable.

Development on the area of restraint also threatens 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 then flows into the Myton School playing fields.
Properties in Myton Crescent were flooded when development was carried out
on the Trinity School site. Developing the Myton side of the site would threaten
houses south of Myton Road (PO18 Flooding and Water). It is unclear how this
threat will be mitigated.

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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.

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As scanned.

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Letter attached

Letter attached

Attached

PO1 Preferred Option: Level of growth
I consider that the proposed level of housing growth of 555 homes per year is not supported by all the evidence available. The mathematics of the calculations are not shown so they cannot be checked easily.
The baseline population on which the future need is apparently calculated is the ONS estimate of 138,670. Since those calculations the 2011 census has measured it at 136,000.
The initial stage of consultation gave a range of growth possibilities and the clear majority of respondents opted for the lower growth levels which would more reasonably reflect the inevitable organic growth in our population due to increased longevity, better health and changes in birth rates along with some inevitable inward migration.
Residents made a clear choice to accept lower infrastructure gains in return for limiting growth and specifically avoiding more growth in excess of local need.
Approximately 250 homes per year would appear to be more than adequate to meet these need if more adventurous use of brownfield urban sites was made..

PO2 Preferred Option: Community Infrastructure Levy
The current market conditions demonstrate that because developers are not confident in the ability of customers to buy, and sites that already have planning approvals are not proceeding.
CIL should be used on a local benefit to relieve effects of or immediately related to development proposal areas.


PO3 Preferred Option: Broad location of Growth
I supports the dispersal of additional housing that cannot be located on urban brownfield sites so there is a small effect on a number of places, rather than a large effect on a few. In general, this will reduce travel and demand for traffic improvements, use existing educational, health and other community facilities where there is available capacity to do so.
The NPPF para 54 requires that in rural areas, local authorities should be responsive to local circumstances, planning housing development to reflect local needs. In para 55, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.

PO4 Preferred Option: Distribution of sites for housing
Location 1 Sites within existing towns. This is the best option. If it were possible, all the housing required should be in existing towns and dispersed therein, to make the least demand on support infrastructure and reducing traffic movements.
Location 2 Myton Garden Suburb. No objection.
Location 3 South of Gallows Hill/West of Europa Way. This development must not take place. It is a criminal intrusion into the rural southern setting of both Warwick and Leamington with important implications for the setting of Warwick Castle and its parkland. It will create a natural infill area for later development until eventually all the area south of Warwick and Leamington id completely filled.
The additional traffic from the proposed 1600 homes plus employment on a road system that is already struggling will impose even greater stacking effects back through the village of Barford which already suffers enormous amounts of rat-running from commuters trying to avoid the daily J15/Banbury Spur commuter
The numbers show that it is not needed and the council needs to bold enough to decide to continue the Green Wedge through to Castle Park.
Location 4 Milverton Gardens. 810houses + community +employment + open space.
and
Location 5 Blackdown. 1170 houses+ employment +open space + community.
These two sites may well be cases where the Greenbelt policy could be relaxed with limited overall damage whilst providing essential housing land. There would be limited damage to the settlement separation intentions of the Greenbelt policy.


Location 6 Whitnash East/ South of Sydenham. 650 houses + open space and community facilities
No specific comment but is this really required?
Location 7 Thickthorn, Kenilworth 770 houses + employment +open space + community
Use of this as part of the policy for dispersal of the housing required is supported.
It is, better to use this site than land of rural, landscape and environmental value elsewhere in the district. It is the only contribution to the preferred option plan located in or near Kenilworth.
Location 8 Red House Farm, Lillington 200 houses + open space.
This would seem to be a reasonable site to utilise if numbers demand it.
Location 9 Loes Farm, Warwick 180 houses + open space
This would seem to be a reasonable site to utilise if numbers demand it.
Location 10 Warwick Gates Employment land 200 houses + open space.
No objection.
Location 11 Woodside Farm, Tachbrook Road 250 houses + open space
There seem to be merits in using this site as it extends previously developed land towards a natural boundary (Harbury Lane) and is hence self-limiting.

Location 12 Fieldgate Lane/Golf Lane, Whitnash 90 houses + open space
No objection.
Locations 13 &14 Category 1 & 2 villages Category 1, 5 villages at 100 and category 2, 7 villages at between 30 to 80 in each plus 8 category 3 villages within the existing village envelopes.
These are very significant increases for many of these villages! Do the category One villages really NEED to take 500 in total or 100 each. In Barford's case this will be an 18% increase in the number of dwellings, and that on top of a recent development of approximately 70 homes. I would suggest that the total Cat One numbers should be significantly reduced and that numbers should then be spread pro-rata over all the Cat one villages according to current house numbers of population number to give a more equitable spread and certainly to keep the increases at or below the district wide increase.
Considerable attention should be paid to the Sustainability Assessments included in the plan where it should be noted that Barford, a Category one village based on its facilities scores the THIRD WORST Sustainability score of all the villages assessed (Cat one, two and three) with only Rowington and Norton Lindsey scoring lower.

Furthermore despite having a very successful school there is considerable doubt about how such numbers could be accommodated and the amount of harm that would be inflicted on currently resident families and pupils of such increases.


PO5 Preferred Option: Affordable housing
I have considerable concerns that the 40% requirement is considerably in excess of the real need for "social housing" and as such will drive up the costs of market homes to such a degree that all homes will become significantly less affordable. It is perhaps appropriate to consider what is trying to be achieved and to review the way in which Affordable Housing need is actually measured - specifically it seems that those in need are counted before their need is actually validated whereafter the real need is actually considerably less and they are re-routed to more conventional housing sources.
PO6 Preferred Option: Mixed communities and a wide choice of homes
Regarding retirement housing of various sorts must be provided as part of a whole-life

PO7 Preferred Option: gypsies and travellers.
The Gypsies and travellers remain and always will be a problem. Most tax-payers are at a loss to understand why they must be treated differently to everyone else when they could acquire land and pursue the planning process just like everyone else.
The proposal to "provide sites" will bring out the worst elements of the NIMBY culture and blight certain areas.
It is my opinion that the problem needs solving by primary legislation not the current soft PC approach. This is a job for central government, no doubt through "Europe".

PO8 Preferred Option: Economy
Employment need only be provided/attracted to match our population. The previous stage of the consultation gave a clear indication that the majority were preferring to accept lower growth rates of housing, employment and infrastructure. That choice must be selected and a focus on consolidation rather than growth should be the watchword. We are a low unemployment area and any extra employment provision will bring with it a proportionate housing demand and inevitably more houses, which is not required.
The Gateway project may still materialise and this will make extra demands as some of the jobs will no doubt be attractive to our residents in addition to bringing in new workers. Provision should be made for housing local to that site and not for such workers to be subsumed into the wider WDC area.

PO9 Preferred options: Retailing and Town Centres
The support retailing and town centres is welcomed and should be vigorously pursued by both planning policy and fiscal incentives. There must be adequate town centre parking provision to support town centre businesses.

PO14 Preferred options: Transport

Access to services and facilities.
Clearly, it is essential to provide sufficient transport infrastructure to give access to services and facilities. The amount of work required is dependent on the level of growth selected. If the low growth scenario is chosen in preference to the current preferred option, then the infrastructure improvements will be much less and probably not much more than is currently necessary to resolve existing problems. This would be less costly and less inconvenient to the public than major infrastructure improvements.

Sustainable forms of transport.
The best way is to keep as much new housing provision as possible in existing urban locations because people are then more likely to walk, bus, bike to work, shops, school etc.


PO15 Preferred options: Green Infrastructure

The policies set out in PO15 are supported


PO16 Preferred options: Green Belt

The NPPF states that once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. I believe that it may be a proper time to review the Green belt to ensure that it is appropriate to the current situation and not merely being carried forward, just because it has always been so. Some relaxation within villages and on the edges of the major settlements would make massive contributions to the housing need whilst doing little harm to the concept of ensuring separation between settlements.

Removing Green Belt status from rural villages would allow currently unavailable infil land to make a significant contribution to housing numbers whilst improving the sustainability of those villages. Barford, not in the Green belt has had considerable infil in the past and as such is relatively sustainable whilst actually scoring poorly on the WDC conventional Sustainability Assessment scoring system.



PO17 Preferred options: Culture & Tourism

The preferred option of medium growth seems to be totally oblivious of the value of the approach road from the south to the Castle. It proposes to materially downgrade the approach past Castle Park by building housing along the length of the road from Greys Mallory to Warwick, a distance of about 2.5 km. The views across the rolling countryside to the east of the approach road are an essential part of the character of the district and county about which books have been written.

The low growth option makes that loss unnecessary.

PO18 Preferred options: Flooding & Water

Flooding: Development should take place where flooding is unlikely to occur. The low growth option would make it easier to select sites for development that do not carry this risk.

Scanned representation

As scanned.

See Attachments

On behalf of Barwood Strategic Land LLP and the landowners we write in support of their
respective interests at land 'south of Gallows Hill/ west of Europa Way, Warwick'. This site is
identified in the Local Plan Preferred Options as a location for growth delivering 1,600 dwellings
in phases 2 and 3 of the plan period along with employment land, open space and community
facilities.
Land interests within the proposed allocation are also held by William Davies and Hallam Land;
it is intended that all developers and landowners will work together to secure a comprehensive
masterplanning approach to the development of this site.
We respond to the respective policy areas and chapters below:
1. Part 1: Setting the Scene and Summary
- In setting the strategy, it should be made clear the time period that the plan is proposed
to cover. For example, at 1.2, there is reference to the next 15 years and only later in
the document is confirmed that that the plan period covers 2011 to 2029.
- It is noted that paragraph 4.2 makes reference to the fact that the District could grow by
as much as 15% over the next 15 years (from a current population of 138,800) - this
represents an increase of some 20,820 residents. We highlight that the 2008 based
household projections shows growth from 62,938 households in 2011 to 77,955
households in 2029. This represents an increase of 15,557 households. The 2006
based projections showed 17,110 households over the same period. The 2010 based
population projections show very similar population growth to the 2008 based projections
and although the latter remain the most up to date, it is expected that the 2010 based
CLG household projections will be very similar.
- Paragraph 4.10 should be revised to make reference to the need to ensure that Local
Plan meets the full, objectively assessed needs for market and affordable housing as
required by the NPPF.
2. Delivering Growth - Housing / PO1: Preferred Level of Growth
- The preferred level of housing growth is proposed to be 600 dwellings per annum
(totalling 10,800 dwellings) over the plan period, which when deducting commitments,
small SHLAA sites and windfalls results in a need to identify and allocate land for 6,986
dwellings. The Council have disregarded Option 2 (employment led growth and 700
dwellings per annum) seemingly solely on the basis that there is a lack of certainty that a
sufficient number of homes on strategic sites could be delivered within the plan period.
Using the Council's own calculations, delivering 700 dwellings per annum would result in
the need for an additional 1,800 dwellings to be found on allocated sites. Part of the
justification relates to the perceived lead in times for the delivery of the larger sites;
however the Council's own phasing programme is a self-fulfilling prophecy in this regard.
Phasing the larger allocations in Phases 2 and 3 (i.e. post 2019) could result in a
significant number of dwellings coming to the market at the same time and making it
difficult to therefore deliver an additional 1,800 dwellings in full within the plan period.
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We would suggest that the Council allows the market and the development industry to
regulate itself in respect of the phasing and the timing of the delivery of development.
To allow the larger allocations to make a start earlier in the plan period will ensure
steady delivery of housing over the life of the plan. It is not in a developer's own interest
to saturate the market however steady delivery on a number of sites over a number of
years will promote healthy competition and ensure sufficient time to allow such sites to
be built out in full. Furthermore, in doing this, there would exist the opportunity to
allocate land for the 'missing' 1,800 dwellings which would make a bigger step towards
meeting the Council's housing need.
- In addition, we highlight that the NPPF makes reference to development which is
sustainable going ahead without delay. It follows that in order for a site to have secured
an allocation in what will be an adopted Local Plan, that site must be sustainable and
therefore in accordance with the NPPF, there is no need for that site to be held back by
an arbitrary phasing policy.
- The Localism Act enshrines a Duty to Cooperate on Local Authorities when preparing
plans. In the event that Warwick District does not meet its own housing need in full, we
see no evidence of adjoining LPA's being prepared to take on and meet that need. The
District is bounded by the following LPA's:
- Stratford District: Latest draft Core Strategy did not propose to accommodate sufficient
growth to meet its own needs. No proposals to meet unmet need from Warwick District.
- Coventry: Latest draft Local Plan does not propose to accommodate sufficient growth to
meet its own needs. No proposals to meet unmet need from Warwick District.
- Rugby Borough: Adopted Core Strategy does not include any proposals to accommodate
unmet need from Warwick District.
- It is not therefore clear the way in which the Duty to Cooperate has been carried forward
or the way in which the District's housing need will be met in full, particularly given that
the household increase is projected to be closer to 15,557 households rather than the
10,800 households currently being planned for.
- Further justification for using lower housing targets is provided in paragraph 5.22 where
it is stated that using Option 2 would meet the projected change in employment between
2011 and 2031 as identified in the West Midlands Integrated Policy Model. However the
Council consider this to now be optimistic as it was carried out in 2010 and forecast an
increase in employment growth from 2011. We highlight however that throughout the
NPPF there is reference to the need to 'plan positively' and the need to stimulate and
secure economic growth. It would appear that the Council are revising their growth for
the period to 2029 (i.e. the long term) because short term growth has failed to
materialise. This cannot be said to be planning positively or assisting in securing
economic growth.
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3. PO3: Location of Growth
- The components of growth are reviewed below:
- Committed Housing Sites (1,224 dwellings): whilst clearly committed sites, we question
whether it is appropriate to include all of these sites and not include any allowance for
non-implementation. A 10% non-implementation rate is the industry 'norm' which we
consider should be applied here, thus reducing the commitments to 1,102 dwellings.
- Small Urban SHLAA sites (290): We seek clarification as to where these sites fall within
Table 7.2 of the Draft Local Plan (DLP).
- Other Windfall Housing Sites (2,300): Paragraph 7.25 of the DLP confirms that the
Council consider there to be a limited supply of land within the existing built up areas of
the towns. Windfalls can be included if the Council can demonstrate that such sites have
consistently become available in the local area and will continue to form a reliable source
of supply having regard to the SHLAA. The Council's SHLAA methodology confirms that
a minimum site size of 5 dwellings was used and that Officer's did not rely solely on sites
which supplied to them by developers or landowners but also conducted their own
research including reviewing areas currently in non residential use and looking at small
scale developments such as change of use of existing buildings. It would therefore
appear that the Council have had every opportunity to identify suitable residential sites
and include them in the SHLAA. With the removal of rear garden land from the definition
of previously developed land, we consider that the scope for new windfall development is
much reduced and that windfalls will no longer continue to make up a significant element
of future supply. Furthermore, under the banner of the NPPF and the requirement to
plan positively, windfalls should be seen as a 'bonus' rather than forming approximately
20% of the overall supply.
Land South of Gallows Hill
- The distribution of housing growth across the District is supported with particular
reference to Land South of Gallows Hill. It is noted that within the Council's Landscape
Character Assessment (February 2009), it is concluded that the study area is not suitable
and the rural character should be safeguarded from development. It is however clear
that this study has considered landscape character in isolation and this study should be
considered 'in the round' as is only one part of the evidence base underpinning the Local
Plan. The NPPF is clear that economic growth is a priority and that economic, social and
environmental factors have to be balanced against each other.
- The developers of this site will be commissioning technical and environmental work to
underpin the draft allocations; this will include detailed landscape and visual work to
demonstrate ways in which the site can be developed without adverse landscape impact.
- Whilst the developers will be working together to ensure a comprehensive approach to
the delivery of the site, we consider it important to recognise that within this should exist
the flexibility to ensure that each developer can bring parts of the site forward at their
own pace within an overall masterplanned approach. The delivery of large sites is often
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hampered by requirements to submit a single planning application which can cause
significant delays and is often to the detriment of the site itself.
4. PO5: Affordable Housing
- Whilst we do not object to the provision of affordable housing in principle, we do not see
any up to date evidence of the way in which the appropriateness of the target as been
assessed in terms of the financial viability of development in accordance with paragraphs
173 and 174 of the NPPF. Paragraph 7.43 of the DLP makes reference to a November
2011 document and an Addendum dated May 2012. The May 2012 document does not
feature in the Evidence Base on the Council's web-site and therefore we reserve the
right to make further representations in this respect upon publication of this document.
5. PO6: Mixed Communities and a Wide Choice of Housing
- We consider that sufficient flexibility should be included within any policy to ensure that
account is taken of up to date market demand in addition to the SHMA's. The latter can
become obsolete very quickly and clearly, if developers feel there is no demand for a
particular type of property then they will not build it, which can result in stalled sites and
lower rates of housing delivery.
- Lifetime Homes: there is no national policy which requires the provision of Lifetime
Homes and we see no justification which supports 25% provision.
- Homes for Older People: whilst the provision of extra care housing is supported, these
have very site specific criteria with operators having specific requirements in respect of
site location and suitability. A site which is suitable for market housing may not be
suitable for extra care housing and it is important to ensure that this policy is not applied
so rigidly so as to sterilise areas of land or stall sites.
6. PO8: Economy
- It is noted that the Council propose to consider allocating a 'proportion' of the site south
of Gallows Hill for employment. The provision of mixed use development is supported
although clearly further clarification is required on the definition of 'a proportion'.
7. PO10: Built Environment
- The Council's Garden Towns, Suburbs and Villages prospectus is supported.
8. PO12: Climate Change
- We have reviewed the Council's evidence base and do not see any case for the
introduction of a 20% climate change policy. We are also disappointed to see a
continued emphasis on renewable energy provision within new developments (when the
Council themselves acknowledge the disadvantages with some renewable technologies)
as opposed to the emphasis being placed on energy efficiency. If the overall aim is seek
a reduction in carbon emissions, we fail to see why this should be achieved through
renewable energy rather than energy efficiency measures.
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9. PO18: Flooding and Water
- Whilst the policy as a whole is supported it is noted that much of this replicates national
guidance and is therefore superfluous. Furthermore, the requirement that all new
developments include SUDS is unfeasible. There are some instances where SUDS
schemes are not feasible or viable and this should be recognised within the policy.
10. Draft Infrastructure Planning
- Whilst the provision of a draft Infrastructure Plan is supported to assist in providing
certainty to developers when bringing forward new sites, particularly in respect of the
larger strategic sites. We consider that further refinement of this plan may be needed.
For example, within Warwick and Leamington Spa, 6 new primary schools are currently
being considered at the same time as capacity in a number of existing schools is also
identified. It is noted that the NPPF advocates a CIL charging schedule being prepared
in tandem with a Local Plan if possible and we consider this may be appropriate in this
case to assist in determining the total cost of items identified in the Draft Infrastructure
Plan. This is of particular importance when reviewing the Strategic Transport
Assessment Overview Report which identifies a requirement of up to circa £5,000 per
property for transport infrastructure without taking into account any other infrastructure
requirements or planning obligations.

Attached letter

Letter attached