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

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

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

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

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

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

The scale of proposed development is appropriate for the location.

I object to 540 houses being built on Woodside Farm, Warwick Gates and Fieldgate Lane. These sites have not been earmarked for the provision of community facilities, i.e. a school. Warwick Gates' sense of community, already poor, will be further diminished.
The plan specifies "that new housing neighbourhoods have close access to a range of key facilities either within the development or within a short walk (e.g 15 minutes)". It would take 30mins or more to walk to the existing schools from the proposed Warwick Gates Development Land. Whitnash cannot take more houses without a Warwick Gates School.

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

Provided the Council can demonstrate that development is economically justified on the edge of town, this area represents a natural and organic growth opportunity and IS NOT GREEN BELT

Warwick Gates Employment Land. Under Policy PO4 it is proposed that the committed employment site at Warwick Gates (9.77 hectares, SHLAA) is developed for housing (200 dwellings), and that this site is brought forward in Phase 1 of the plan. In the 'Economy' section we are informed at Para 8.29 that the Council believes that the employment site is in the wrong location and that a compensatory provision of employment land located in the vicinity of WTP would have a number of advantages. However we have not seen any evidence to back the advantages claimed and wish to contest each here:

o Support the clustering of industries and expansion of knowledge based sectors.

It is our considered view that the Warwick Gates employment site is, in terms of its proximity to WTP, well located to encourage both the clustering of industries and expansion of the knowledge based sector. This view was shared by the Inspector at the last District Local Plan Inquiry who, in his response to proposals for additional employment land opposite WTP, stated in his Report that "In terms of synergy with the adjacent Warwick Technology Park and the HTC [High Technology Corridor], I am satisfied that sufficient committed sites [Warwick Gates/Gallagher Park] are available nearby of such a quality as to accommodate those needs without expansion into the adjacent rural area" (para 10.3.48). Although our clients' site sits adjacent to WTP, there are no existing pedestrian or vehicular links between the two and, given existing development on WTP and local topography (WTP sits in a 'bowl'), no prospect of any being established in the future. Therefore we strongly disagree with the suggestion that having employment on land north of Gallows Hill/west of Europa Way would better than the existing Warwick Gates site in supporting the clustering of industries and the expansion of the knowledge based sector.
We acknowledge that the Warwick Gates site has sat undeveloped for many years but do not believe that this is because it is in the wrong location to be attractive to the market. The site lies in a prominent position on the main southern route into Leamington and is within easy access of the M40 - a 'premier location' according to the Council's Employment Land Review. The reason why the site has not yet been developed is most likely the result of one or more of the following factors:

* Current economic climate

* Ineffective marketing
At the time of the last District Local Plan Inquiry the Inspector remarked in his report (para 10.3.46) that he believed that the Warwick Gates employment site was not being marketed aggressively. In the Council's Employment Land Review - Final Report (April 2009) the authors of the report state that the site is "possibly being held back for future residential use" (para 2.90).

* Existing planning permission
The existing planning permission on the site is for a mix of businesses uses; B1, B2 and B8. For this site to attract the kind of companies which are now found on WTP, then the site should be reallocated for employment under Use Class B1a and B1b. Doing so should help provide confidence to the market that investment in the site would not be undermined by incompatible neighbouring industrial uses.
o increase opportunities to utilise existing infrastructure

It is unclear what the Council's is referring to here. The Warwick Gates site is clearly already well placed to take advantage of /utilise existing infrastructure, and that it would be the case that providing an 'alternative proportion of land' would in fact require new infrastructure to open up and service the site.

o support the development of new infrastructure to serve the needs of businesses such as a Park and Ride.
While we see some possible benefits of providing a Park and Ride facility to the south of the urban area, including less congestion and reduced CO2 emissions, we do not support proposals for such a facility in the area depicted on Map 5 in the Preferred Options. The term "Park & Ride" (P&R) refers to remotely located car parking linked by an attractive public transport service with the key urban or other high demand centre(s) it is designed for. Therefore we cannot see how a P&R located adjacent to or actually part of an employment development within the urban area can serve the needs of business in the area (nor potential users of the service generally). To have any chance of being effective, a P&R needs to be located either on the very periphery of the urban area/ or beyond it to capture 'customers' before they are caught in the very traffic they wish to avoid (please also refer to separate comments on P&R proposals under Policy PO14: Transport)

Whilst we object outright to the proposed allocation of housing development on the Warwick Gates Employment Land site, we also object to the allocation being identified for 'release' in Phase 1. Having regards to its location, the site would be poorly served by community infrastructure and given its size would not provide the critical mass to support service on site. With specific regard to secondary education, the development would fall within the catchment of Myton School and the likely take up of places at that school as a result of the new development may have negative consequences for how much development could be brought forward at the same time on the Myton Garden Suburb site in Phase 1 if there are insufficient secondary school places available locally.

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

It is unclear why this site is being reallocated as a housing site when a new site proposed on Europa way is partly allocated as employment land. What is the rationale for this change of designation?
Whilst it has been previously allocated as employment land. There is not sufficient evidence to show that this rural site is needed for new housing. My representations in 7.1 and 7.2 cast significant doubt on the rural land needed for new housing. A given the signicant brownfield opportunities, there is no justification for this rural land to built on in phase 1.

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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

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.

See Attachments

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