See attached letter

Attached letter

As scanned.

As scanned.

See attached email

See attached letter

See attached

See attached

See attached

See attached

See attached

See attached

As scanned.

See attached

See attached

See attached

See attached.

See attached

Attached letter

I wrote to the Development Officer earlier, 14 July 2012. In the meantime I have consulted with others and as a result of this have additional concerns which I wish to draw to your attention. Please see letter in pdf format as an attachment which refers.

At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became apparent that the Preferred Options Plans, nominally open for consultation and discussion were nothing of the sort. The strong impression given in the presentation was that in the minds of the presenters, the 'only option' open is the one presented, even though the key argument for what constituted the justification for the Green Belt Land Grab was not made. Insult has been added to injury in freely admitting that the 2009 consultation, presumably based on sound 'Planning Criteria' is replaced by the 2012 consultation which clearly is not. The principle of 'Equalising the Misery' is scarcely a sound basis for planning.

This meeting has prompted me to make further comment, particularly when at the end of the meeting the Chairman Jonathan Lander encouraged those attending to make written submissions to WDC and copy their MPs if they felt there was merit in this course of action.

This was made the more poignant when Michael Doody immediately stood up and stated it was in no one's interest to copy the MPs, as there was a risk of repercussions and Local Government loosing control of planning decisions. He elaborated on this theme but found no support for his assertions.

Bill Hunt (Deputy CEO Warwick District Council) gave the WDC presentation at the Church meeting and also present were :

Councillors J.M.Lander (in the Chair), Mrs.A.Kelsey, J.McDonagh, L.J.Sant-Cassia and M.A.L.Tansey; County and District Councillor M.Doody; District Councillors J.S.Hammon and N.Pratt; and Mr. Bill Hunt, Deputy Chief Executive of Warwick District Council; together with some 150 members of the public, including Councillors Margaret Cashmore, David Cox and Peter Delow of Cubbington Parish Council.

There is also the matter of the WDC website, where 'contributors' are encouraged to force their submissions into 'boxes'. This looses the personal touch and is in danger of a total loss of context; the practise is certainly inhibitive. There is no satisfactory substitute for free form written letters ! To give an example of the anger and frustration this sort of thing can cause I refer you to the decision to ask for questions to be submitted in writing at Trinity School 'consultation' meeting, failing to address those questions at the meeting and providing only a summary of responses to 'subject areas raised' did not endear WDC to those taking the trouble to attend the meeting and try put a stop to this apparently politically motivated charade.

The handling of the change of plans to the newly 'Preferred Options' is certainly not in the public interest; and all those I have spoken to, have been greatly irritated by this lack of courtesy and consideration. A significant lack of trust certainly appears to have been generated.

This poses the question When and How do WDC propose to make available copy of letters of comment, objection and support in order to assure the public that letters/submissions are being properly addressed and the content properly taken into consideration; and enable interested parties to see the nature of submissions just as WDC do routinely for the more private and delicate subject of Planning Applications. I should be grateful for your written reply.

Letter detail

When I came to Old Milverton 35 years ago, L.Spa enjoyed an enviable reputation as a
Shopping Centre and was recognised as having a thriving 'community spirit'. Latterly,
much of this has been lost. Independent retailers appear to have lost confidence in
trading in the town. In places empty shops and offices show a town in decline.
By implementing the plans now proposed, the two plots of sequestered Green Belt land in
the Parishes of Blackdown and Old Milverton are set to become 'housing in isolation',
which will result in a 'Dormitory Development'; some say a 'ghetto'. The outcome can only
be a feeling of isolation and a huge increase in unnecessary commuting across L.Spa,
adding to the existing congestion at well known bottlenecks which so far WDC have found
impossible to resolve.
This is particularly pertinent as there is no detail admitted of the proposed infrastructure
intended to service this development. It might not even materialise - for example, if the
sale of the housing proposed founders; a not unlikely outcome in view of the land value
and expected high market value of the new housing in this area. If on the contrary, a
major and inspired infrastructure component is built in and it is successful, it can only be to
the detriment of L.Spa town Centre as shops, offices, services and places of work are
dispersed away from the Town Centre.
By developing a transport hub based on the Railway Station and the commercial/
recreation and services already in place to the south of the town; and locating new
housing development as laid out in the 2009 plan south of the town, it may still be possible
to retrieve much of what has been lost. To develop at Old Milverton & Blackdown can only
have the reverse effect. Our political representation appears to have completely lost sight
of this important consideration.
Why has it not been possible for Warwick District Council to take a grip and reverse the
deterioration experienced in Leamington Spa and exploit the many assets and advantages
associated with the existing infrastructure, services and trading opportunities south of the
town. Significantly, in the first instance, build Affordable Housing where they are needed,
upgrading the empty/derelict buildings and return the many houses originally built for
families to live in but no longer in family occupation.
In summary, It seems the social and cultural life of L.Spa is about to be finally
ripped out of the town and be dispersed into isolated units on the northern
periphery. WDC should be regenerating L.Spa by concentrating its development
from the town centre to the south and not fragmenting it by developing to the north
of the town. What a prospect for legacy !
At the Parish Council Meeting held in Old Milverton Church on Monday 16 July it became
apparent that the Preferred Options Plans, nominally open for consultation and discussion
were nothing of the sort. The new plans have been presented as the 'only option' even
though the key component of what constituted, 'Very Special Circumstances' for the
justification of the Green Belt Grab, was not made. It was agreed even by the DCEO that
the plans lack this very necessary robust argument.
Robert Solt demonstrated further weaknesses in the case for the Preferred Options Plans
by explaining that the numbers did not add up, on several counts. Mainly that the model
used was outdated and most of all, the input data was flawed being based on earlier
projections which are no longer valid, resulting in a very considerable overestimate of
housing need. No allowance appeared to have been made for the recent changes in the
nature of the local work force from manual to blue and white collar and a very significant
increase in numbers of professionals and academics.
It follows that a contemporary detailed audit is outstanding and is required to quantify
housing need, specifically to include the changes outlined above. An audit of similar rigor
is required to establish the total availability of development options to include all sites
Whitefield, Brownfield and Windfall (for which a particularly rigorous assessment is
needed and with inducements offered up to encourage this process). An explanation for
the 'apparent loss' of development sites since the previous assessment (see 2009 plans)
would not go amiss.
Missing from the report is a statement covering the impact of changes which must be
taken far more seriously such as the austerity measures and other significant events in
process, including the fate of the Euro and our EU member States and our Trading Status
as a nation committed to the practice of a disproportionately large scale Food Importation
Policy. Food Security has simply not been considered. In large conurbations this could
become the single most important consideration for Local Government.
If Climate Change and an increasing demand for western living standards are to be
aggressively pursued by Indians Chinese and Africans etc., we have the makings of 'the
perfect storm' in the ability of these countries to feed their own people, let alone export.
The UK is one of the more densely populated countries, at least in the EU and perhaps the
one at greatest risk from global food shortages. A consideration not to be taken lightly
when seeking to destroy Green Belt and good quality Agricultural Land.

Attached

Following a presentation of WDC's Local Plan in Bishop's Tachbrook, I have several objections and suggestions regarding the Housing Preferred Option and other matters.

Housing:
With reference to the map P04 Preferred Option sites for expanding housing include sites numbers 2,4,10, 11,12 & 6. These sites will provide land for a proposed 3800 homes. Extrapolating the number of people that will live in these new homes there will be an additional 14 to 15000 more people living South of Leamington and Warwick. These extra people will put a massive burden on the infrastructure such as roads/bridges to gain access to the Town Centres' and emergency services. The Bridge in Warwick and Leamington are already at maximum usage during rush hours and in my opinion would be overwhelmed by this massive increase in population. According to the Preferred option on transport infrastructure there is no provision to build more bridges over the Rivers Leam and Avon. What's more the entrance to Warwick from the south via the Banbury Road will be blighted by such a massive housing estate and will have detrimental effect on tourism.

Furthermore the development (Woodside Farm, Bishop's Tachbrook; area Number 11 on the Preferred Option map) would have a high adverse visual impact as it is prominent ridge and would impair the visual approach to Leamington.

The lack of infra structure provision was also a major objection to the last Preferred Option in the previous spatial framework housing plan. I agree there are now fewer houses envisaged 3800 as against 4500 but the same criticism applies Ie. the excessive strain on existing facilities.

Alongside new housing must be provision for upgraded infrastructure. When previous housing expansion took place, namely Warwick Gates, we in Bishop's Tachbrook, suffered lack of water pressure and problems with sewage because no pumping station was built for a number of years. Road infrastructure too was overlooked causing major problems at the
Tachbrook/Harbury Lane cross roads. Ditto the exit from Gallows Hill onto the Banbury Road. Improvements to these road junctions took many years after the houses and business park were built. Major expansion of the factories at Gaydon has created a huge traffic increase with consequent problems (and fatalities) by vehicles trying to exit Tachbrook on to the Banbury Road. In addition there is also a problem at rush hours caused by vehicles using Bishop's Tachbrook as a rat run.


The decision not to build a new infants school at Warwick Gates caused and still creates major problems with bus access to the school in Kingsley Road (Bishop's Tachbrook) because children have to be bussed here from Warwick Gates.
Infrastructure is either neglected all together or takes many years to implement; meanwhile existing residents have to live with the misery.

The new Preferred Option I believe will cause major problems owing to the bridge bottlenecks in Leamington and Warwick and lack of concrete plans to enhance infrastructure to cater for the increased population.

If more housing is required there must be adequate infrastructure built in parallel with housing construction. The proposed Developer Infrastructure Levy will certainly not pay for new bridges or better health provision etc. And waiting for the increased population tax revenues to pay for it will take far too long, leaving existing residents to suffer severe curtailment to the quality of their lives.

I would also question the need to build 555 houses per years from 2014 -2029. The ONS and economic projections based on historical growth rates do not take into account the envisaged stagnation in economic growth throughout the UK for the foreseeable future plus the negative growth effects of an ageing demographic. Apart from Jaguar Landrover at Gaydon most of the envisaged commercial expansion is planned for the Gateway area around Baginton/Ryton. This would entail commuting again from South of the Rivers to the North, further compounding traffic problems over the aforementioned bridges. Therefore it would be better to build more housing nearer the Gateway Area

Also there is a "Green" imperative that demands fewer commuting miles by car in order to reduce emissions etc.

In addition, building more houses attracts more people i.e. it is a self-fulfilling strategy, not based on projected growth grounds alone. As Leamington/Warwick is an attractive area more people will move here to take advantage of the new housing and the increase in population would in turn diminish the attractiveness that created the initial demand and further increase commuting miles out of the area to other centres of work.

If more housing is required (the number should be far less than the projected 555 per year) it would be best to maximize all available brownfield sites in the suburban areas. It was a great pity that yet another supermarket was granted permission to build a giant shed on the old Ford Foundry site when this entire area could have provided an admirable housing development.
Brownfield sites that would provide excellent housing are:
1. The old telephone exchange in Leamington
2. Garage opposite Covent Garden multi story (Leamington)
3. Quarry Street Dairy Milverton
4. Linen Street car park (Warwick)
5. Police station Warwick
6. Fire station (Leamington)



Housing continued...

Further sites
Land could be released for housing at Bubbenhall and Baddesley Clinton if they were classed as Category 1 or 2 villages


GREEN WEDGE
The proposed Green wedge stretching from Radford Semele, between Harbury Lane & Bishop's Tachbrook to Banbury Road should be extended Southwards to encompass Oakley and surrounding area.

In addition, I would like to reaffirm opposition to any plans to revive development between Harbury Lane and Bishop's Tachbrook as was proposed in the previous Preferred Option

Scanned representation

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 submission

Scanned Representation

Scanned representation

Scanned representation

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the Local plan.
This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists.
The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.
The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. It
Prevents the unrestricted sprawl of Leamington to the north
Prevents the merging of Leamington and Kenilworth
Helps safeguard the countryside from encroachment
Helps preserve the setting and special character of Leamington (a historic town)
Helps urban regeneration, by encouraging the recycling of derelict and other urban land
There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.
The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.
Please reconsider your Preferred Options.

I am writing to object to the District Council's plan to develop on Green Belt Land as described in the 2012 Proposed Preferred Options plan.

The National Framework requires there to be 'very special circumstances' for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. These ' very special circumstances' are not proven in the proposals-

* The Warwick District Council '2009 Core Strategy' has already identified non Green Belt Land suitable for development closer to existing infrastructure and employment opportunities.

* The planning assumptions on the need for growth at the same level as the 'boom years' need to be questioned. The town can thrive and be prosperous making a different set of assumptions and without the large contingency number of houses in the plan.

* The bank of the River Avon north of the River Leam junction has already been defiled by the foundations of uncompleted blocks of flats. The potential of this partially developed area needs to be factored in along with the other identified non Green Belt sites.


The proposals will reduce the 'Green Lung' between Leamington and Kenilworth to less than 1.5 miles encouraging the merger of these two towns with the loss of their separate identities.

The Green Belt to the North of Leamington is heavily used by walkers, cyclists, runners and riders of all ages. This makes a direct contribution to the physical and mental well being of the population, The cost and other benefits of this have not been factored into the equation.

To deprive future generations of this Green Belt land would be unthinkable. We should ponder what sort of town we wish to bequeath to our children and seriously reconsider these proposals.