Where this policy states *require new large scale housing development to provide levels of open space and provisions for sport to meet community needs and create inclusive communities. It will be important to maximise linkages and access to the wider countryside for recreational purposes for all.... we believe that in many situations esp in smaller developments it is more appropriate to require commuted sums for similar provision elsewhere within that community or parish rather than providing small and dislocated schemes that segregate rather than build community.

Young people have the right to access a full range of sports facilities and health care in a safe and healthy community. The importance of a healthy lifestyle is promoted in Kenilworth School and we need to provide additional faciities for a growing community.

This has not been the case with previous developments - local residents have had to fund and arrange the construction of community centres (eg, Chase Meadow) and playgrounds. Developers should be made to provide these amenities as part of the development, free of charge.

"Objection is made to the omission of a proactive,positive and collaborative approach to the development of schools.
Request the inclusion of a further paragraph to PO13 to include the following extract from the NPPF.
""72. The Government attaches great importance to ensuring that a sufficient
choice of school places is available to meet the needs of existing and new
communities. Local planning authorities should take a proactive, positive and
collaborative approach to meeting this requirement, and to development that
will widen choice in education. They should:
● give great weight to the need to create, expand or alter schools; and
● work with schools promoters to identify and resolve key planning issues
before applications are submitted."""

The New Local Plan (NLP) Preferred Options: Inclusive, Safe and Healthy Communities- PO13

I am writing to register my objection to the development of site identified as East Milverton within the proposed Warwick District Council (WDC) Development May 2012.

Whilst acknowledging the need for additional housing during the period 2014-2029 and the overall approach; the Preferred option in its current form, (i) goes beyond identified housing need at the expense of the
Green Belt, (ii) ignores national planning policy guidelines for development of Green Belt, and (iii) does not recognise other development opportunities that are better suited to development and more consistent with WDC's own stated sustainable growth objectives and evidence base.
Developing East Milverton is not consistent with NLP objective PO13. help the public access and enjoy open spaces, and support healthy lifestyles.

The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies North Milverton (L07) is a Green Belt site of medium value. Other assessment referred to within the Landscape Character Assessment for Land South of Leamington and Warwick show the North Milverton Green Belt as being of high value, in contrast, for example, to part of the Blackdown site adjacent to Sandy Lane (referred to as WL6a/b in this document and shown to be of medium value). The Milverton site is enjoyed by a wide section of the community, it is an important asset in supporting healthy lifestyles for residents and visitors of all ages - whether it be walking, running or cycling. The public footpath that transverses the site provides a valuable access point from Leamington to the Warwickshire country side and should be protected.

The children's play area in Norton Lindsey has been provided by fundraising by the villagers and is maintaned by volunteers from within the village. The prefered option states it will provide / require improvements to existing children's and young people's play areas. This seems an unreasonable request when the playground is unsupported by the council.

PO13 acknowledges the importance of maximising linkages and access to the wider countryside, a role which canal towpaths can and do fulfil, and which is worthy of specific reference, although it is important to also acknowledge that there is often a need to upgrade towpaths to cope with increased usage generated by development close to, or associated with, the canal network.

I think your proposals are an excellent idea - particularly in trying to provide sports facilities, play areas and facilities for young people.

I have read your booklet 'local plan' preferred options summary May 2012.
Could you please, advise me as to how you are going to allow all these housing builds to take place? Warwick A&E department cannot cope as it is, as on most nights, there is a 4 hour wait and most cases re sent to Coventry NHS Trust. Warwickshire fire and rescue service is now under its greatest stresses, due to cuts to retained officers. Warwickshire police cannot cope with the amount of incidents they are having to attend.
There is also a lack of schools and dentists.
As a council you cannot even maintain the roads to a reasonable standard. You need to get the town back to a standard so it is proud to call its self Royal Leamington Spa.
The bottom of town is known as the Bronx. Areas like Fallow Hill and Lillington are more important to make a community proud to live in. Stop letting the pound signs in your eyes ignore the deprived areas already existing.
This town cannot cope with the amount of new builds. You don't have any concern on how the cost of car parking has driven away no end of trade within the town with the rediculous car parking fees charged. In Coventry where I now choose to shop for most of the day, it costs me £1.50. You constantly ask the publics view, but take no interest in what they say and ignore there views. All you are interested in is how much as a council you can claim of the households. You have no concern on how the emergency services will cope or hospitals.
I suggest you look into this before agreeing to allow more housing builds. Are you going to consider, with the amount of houses you are planning to allow to be built, that there will be a large amount of children and youths who will have no where to go and nothing to do causing even more potential antisocial behaviour.
As a council, I have never known one to waste as much money as you do on the most ridiculous resources as you do, then complain you have no money.
It is widely recognised that a large percentage of council house tennants do not pay council tax, therefore leaving us taxpayers to make up the shortfall. As the majority of the community are taxpayers and non benefit claimants, we already bear the brunt of you're economic failures. What percentage of the residents of these new developments will not have put one penny into Britains economy but deem to meet your criteria

Policy PO13: Inclusive, Safe & Healthy Communities

Object
We are pleased to see the commitment in the fourth bullet point of Policy PO13 to protecting and improving the quality of existing open spaces. However we would like to see this policy support creation of accessible green space, such as native woodland, for quality of life benefits. This is strongly supported in the Warwick District GI Delivery Assessment February (LUC, 2012).

The Government's new National Planning Policy Framework (NPPF) states that: 'Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up‑to‑date assessments of the needs for open space, sports and recreation facilities an opportunities for new provision (DCLG, March 2012, para 73).

The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, paras 4.5-4.13) highlights the direction of national policy regarding the natural environment and health: 'Nature is good for human health. There is a wealth of evidence on the positive effect that spending time in the natural environment has on the health and emotional wellbeing of children'.

The Case for Trees: Forestry Commission (2010) sets out: 'The multiple value of trees for people and places - increasing greenspace and tree numbers is likely to remain one of the most effective tools for making urban areas more convivial', and lists those benefits (on p.10) as -
- Climate change contributions
- Environment advantages
- Economic dividends
- Social benefits.

The Woodland Trust believes that proximity and access to woodland is a key issue linking the environment with health and wellbeing provision.

Recognising this, the Woodland Trust has researched and developed the Woodland Access Standard (WASt) for local authorities to aim for, encapsulated in our Space for People publication. We believe that the WASt can be an important policy tool complimenting other access standards used in delivering green infrastructure for health benefits.

The WASt is complimentary to Natural England's ANGST+ and is endorsed by Natural England. The Woodland Trust Woodland Access Standard recommends:
- that no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size
- that there should also be at least one area of accessible woodland of no less than 20ha within 4km (8km round-trip) of people's homes.
Applying this standard in Warwick District, with a comparison against North Warwickshire DC Council and the West Midlands as a whole, gives the following figures (see table below). It shows that Warwick exhibits below average access in the smaller wood category. This presents an excellent opportunity for creating more accessible woodland to improve health & well being opportunities for sustainable communities and neighbourhoods. The data used can be supplied free of charge by the Woodland Trust both in map and in numerical/GIS form.
Accessibility to Woodland in Warwick using the Woodland Trust Woodland Access Standard
Warwick DC North Warwickshire DC All WM
Accessible woods % population with access to 2ha+ wood within 500m 12.5% 17.0% 15.4%
% population with access to 20ha+ wood within 4km 85.4% 92.3% 63.8%

Space for People' is the first UK-wide assessment of any form of greenspace - the full 'Space for People' report can be found at http://www.woodlandtrust.org.uk/en/about-us/publications/key-publications/space-for-people/Pages/space-for-people.aspx.

In addition, our VisitWoods initiative is an online woodland database of the UK's woods where you are welcome to visit, currently listing over 10,000 sites - http://visitwoods.org.uk/en/visit-woods/about/pages/more-information.aspx.

As an example of other Local Authority policies, the North Somerset Council Core Strategy Adopted April 2012 states -

'CS9: Green infrastructure
The existing network of green infrastructure will be safeguarded, improved and
enhanced by further provision, linking in to existing provision where appropriate,
ensuring it is a multi-functional, accessible network which promotes healthy lifestyles,
maintains and improves biodiversity and landscape character and contributes to climate
change objectives.
Priority will be given to:
.........
* the protection and planting of trees in woodlands and urban areas, particularly native
trees, for public amenity and climate change mitigation and benefits to biodiversity,
health and recreation'.


Proposal
We would therefore like to see the 4th bullet point of Policy PO13 amended (upper case) to read: 'protect and improve the quality of existing open spaces in the District AND EXPAND open space provision SUCH AS NATIVE WOODLAND as the towns
and villages grow over the plan period'.


Policy PO15: Green Infrastructure

Object
Whilst we note that Policy PO15 states that 'Development will only be permitted which protects and enhances important green infrastructure assets and positively contributes to the character and quality of its natural and historic environment through good
habitat/landscape design and management', we believe this policy is insufficiently robust to protect irreplaceable semi natural habitats like ancient woodland.

Ancient woodland, together with ancient/veteran trees, represents an irreplaceable semi natural habitat that still does not benefit from full statutory protection: for instance 84% of ancient woodland in the West Midlands has no statutory protection. This is particularly relevant as ancient woodland is still facing considerable threats - research from the Woodland Trust shows that in the last decade 100 square miles (26,000 hectares or 5% of the total amount of ancient woodland remaining in the UK) of ancient woodland in the UK has come under threat from destruction or degradation. Development threats associated with transport and infrastructure appeared to be the most significant (31% of cases), followed by amenity and leisure developments (14%), housing (10%), and quarrying and mineral extraction (6%). As Warwick DC's ancient woodland amounts to 2.64% as a proportion of its land area, compared to a national average of 2.4%, it is critical that no more of this valuable resource in Warwick is lost.

Warwick District also contains a number of ancient and veteran trees, and there may be more that are not yet formally recorded. The Woodland Trust and Ancient Tree Forum are running a national project - the Ancient Tree Hunt - to identify and map ancient trees (http://www.ancienttreehunt.org.uk/) so they can be protected and enhanced for the benefit of all. As a result a number of ancient trees have been identified, such as the ancient oak at Old Milverton.

Government policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The new National Policy Planning Framework clearly states: "...planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss " (DCLG, March 2012, para 118).

This NPPF wording should be considered in conjunction with other national policy on ancient woodland -

- The Government's policy document 'Keepers of Time - A statement of Policy for England's Ancient & Native Woodland' (Defra/Forestry Commission, 2005, p.10) states: 'The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland'.
- The Government's just published Independent Panel on Forestry states: 'Government should reconfirm the policy approach set out in the Open Habitats Policy and Ancient Woodland Policy (Keepers of Time - A statement of policy for England's ancient and native woodland).....Reflect the value of ancient woodlands, trees of special interest, for example veteran trees, and other priority habitats in Local Plans, and refuse planning permission for developments that would have an adverse impact on them.' (Defra, Final Report, July 2012).
- The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, para 2.56) states that: 'The Government is committed to providing appropriate protection to ancient woodlands....'.
- The new Biodiversity Strategy for England (Biodiversity 2020: A Strategy for England's Wildlife & Ecosystem Services, Defra 2011, see 'Forestry' para 2.16) states that - 'We are committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland site'.
- The West Midlands Forestry Framework (Growing our future, May 2010, Forestry Commission) Objective EB2 seeks: 'To prevent any further loss of ancient woodland and to enhance ancient semi-natural woodland and trees with new native woodland planting...'

In terms of compensatory measures, it is impossible to replace ancient woodland as this habitat has evolved over centuries and it is impossible to replicate hundreds of years of ecological evolution by planting a new site or attempting to translocate it.

An example of good Local Authority policy is provided by North Somerset Council Core Strategy Adopted April 2012 -

'Policy CS4: Nature conservation
North Somerset contains outstanding wildlife habitats and species. These include limestone grasslands, traditional orchards, wetlands, rhynes, commons, hedgerows, ancient woodlands and the Severn Estuary. Key species include rare horseshoe bats, otters, wildfowl and wading birds, slow-worms and water voles.
The biodiversity of North Somerset will be maintained and enhanced by:...
3) seeking to protect, connect and enhance important habitats, particularly designated
sites, ancient woodlands and veteran trees'.

The West Dorset DC and Weymouth/Portland DC Local Plan (submission draft: June 2012) states that -

'Policy ENV 2. WILDLIFE AND HABITATS
iv) Elsewhere, development that would adversely affect nature conservation interests,
including Sites of Nature Conservation Importance, Local Nature Reserves, ancient
woodlands, veteran trees and hedgerows, and key wildlife corridors will be
resisted'.

Proposal
We would therefore like to see Policy PO15 amended to reflect the precise wording of NPPF para 118 with a new separate bullet point specifically for ancient woodland: 'The Council will not permit any development proposal which would result in the loss or deterioration of ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss'.


Policy PO15: Green Infrastructure

Object
We would also like to see the 'Development Proposals' section of Policy PO15 reflect the strong message in the Warwick District Green Infrastructure Delivery Assessment (LUC, Feb 2012) and support the expansion of native woodland and tree planting in development situations, particularly in an urban setting.

The National Planning Policy Framework (NPPF) supports the need for more native woodland creation by stating that: 'Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', (DCLG, March 2012, para 114). Also para 117 states that: 'To minimise impacts on biodiversity and geodiversity, planning policies should:....promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan'.

The new England Biodiversity Strategy which makes it clear that expansion of priority habitats like native woodland remains a key aim - 'Priority action: Bring a greater proportion of our existing woodlands into sustainable management and expand the area of woodland in England', (Biodiversity 2020: A strategy for England's wildlife and ecosystems services, DEFRA 2011, p.26).

A reading of these new policies in the National Planning Policy Framework together with the England Biodiversity Strategy indicates that native woodland creation should form a high priority for this Core Strategy.

As the UK is one of the least wooded areas of Europe, with just 11.8% woodland cover compared to around 44% for Europe as a whole, the Woodland Trust is therefore working to achieve its ambitious aim of doubling native woodland cover over the next 50 years. The Woodland Trust believes that woodland creation is especially important because of the unique ability of woodland to deliver across a wide range of benefits - see our publication Woodland Creation - why it matters (http://www.woodlandtrust.org.uk/en/about-us/publications/Pages/ours.aspx). These include for both landscape and biodiversity (helping habitats become more robust to adapt to climate change, buffering and extending fragmented ancient woodland), for quality of life and climate change (amenity & recreation, public health, flood amelioration, urban cooling) and for the local economy (timber and woodfuel markets).

Woodland creation also forms a significant element in the conclusions of the Government's just published Independent Panel on Forestry, which states: 'Ensure woodland creation, tree planting and maintenance is part of the green space plan for new commercial and housing development' (Defra, Final Report, July 2012). It also recommends: 'Government to commit to an ambition to sustainably
increase England's woodland cover from 10% to 15% by 2060, working
with other landowners to create a more wooded landscape'.

A good example of Local Authority policy is afforded by the North Somerset Council Core Strategy Adopted April 2012 -

'Policy CS4: Nature conservation
The biodiversity of North Somerset will be maintained and enhanced by:...
5) promoting native tree planting and well targeted woodland creation, and
encouraging retention of trees, with a view to enhancing biodiversity'.

Proposal
We would therefore like to see the second bullet point under Development Proposals in Policy PO15 amended (upper case) to read: 'Development proposals should take a positive, integrated approach to designing green infrastructure on site, particularly urban extensions, utilising the Council's preferred approach to new sustainable garden
suburbs with enhancements to key landscape features INCLUDING NATIVE WOODLAND CREATION and the wider GI network.

Local Plan Preferred Options

Thank you for your email of 1 June consulting The Theatres Trust on the preferred options of the New Local Plan.

PO13 Inclusive, Safe and Healthy Communities
Paragraph 13.6 justifies the content of Preferred Option 13 in terms of sport and recreation but makes no mention of mental or cerebral well-being through indoor cultural facilities such as libraries, museums, cinemas and theatre venues which we assume is included within the term social and cultural well-being. However, we think there is a mixture of intentions in this preferred option of sport and recreation, green infrastructure, crime and safety, and design standards. We suggest these items should be included elsewhere in other more appropriate options as this particular option provides no specific guidance for its title and should be deleted.

PO17 Culture and Tourism
Thank you for these pages of support for cultural facilities. We have no comment to make other than to suggest that the strategic policy includes an item to protect and enhance existing cultural (other than visitor attractions), arts facilities and entertainment venues (where appropriate). This is stated in the Tourism section of PO17 but not the Culture section - you have quoted the NPPF on page 94 - Item 70 on page 17 of the NPPF states that to deliver the social, recreational and cultural facilities and services that the community needs, planning policies and decisions should plan for the use of shared space and guard against unnecessary loss of valued facilities. Also to ensure that established facilities and services are retained and able to develop for the benefit of the community - it would therefore be suitable to protect and enhance existing cultural facilities (other than visitor attractions) for the benefit of residents and visitors.

Please number or define all the bullet points for ease of reference.

Any large development should include "green channels" such as persists on the Woodloes park. As well as enabling rented apartments and local shops, to facilitate attractive areas to live in, a wide social mix and reduced environmental impact of shopping trips.

Warwick Town should encourage shops, whilst at the District level expansion by the BIG retailers should not be encouraged.

Existing wild places should be kept, particularly the river side walk between Warwick and Leamington. Potentially the path behind Tesco's could be enhanced from a mud track to a gravel path, similar to that in place where the path passes on the South side of the river by Edmondscote running track.

The plan has several areas shown as Confidential. This is clearly unhelpful from the point of view of commenting on specifics. If the land of or around Jephson Farm (between the river and Myton Road) is proposed to be developed this would be a significant diminution of amenity, and more "paving over of Warwick".

Whilst the plan proposes utilising the Regency Terrace opposite the old Council Courts in Warwick, there appears to be no plans for the Courts themselves? Surely there is scope for, say a Museum of Justice to keep these fine buildings and their historic interior, as well as adding to the vitality and attractiveness of Warwick.

Taking the sections in the plan:
P04: am surprised at just how far you plan to expand Warwick South! At this rate Warwick Castle Park will be a green island ? Assuming you are serious then it is behold that the Castle Park be available as an amenity, to enable the expanded population a proportional access to quality green space/park

P05: Affordable housing - agree.

P06/7/9/10/13/15: agree

P08: see earlier comment

P011: see earlier comment re: County Courts

P012: whilst agreeing climate change is real and has to be addressed, I'm unclear on what 20% reduction means. 20% of what ? will this be an annually revised value? (20% in year1, year2 = 20% of previous year etc, presuming each year is an improvement on the previous)

P014: use of public transport is as much a financial decision as access to it. If it's unaffordable to many it won't get used. By ignoring HS2, does that mean any costs associated with it WILL be met by Central Government then? I don't understand (and you don't explain) the risk of ignoring HS2 (or conversely) the risk/downside if you did plan for HS2.

In responding to the 2011 consultation, the Town Council indicated support for Scenario 1, which was to provide 3750 new homes on greenfield sites and to allocate 60 hectares of employment land.

This view was the preferred single option of those responding to the consultation, despite attempts to demonstrate evidence to the contrary, to allow for the District to put forward a much greater annual housing development figure.

In supporting Scenario 1 the Town Council accepted that the number of homes to be built would increase from 3750, to reflect the development of windfall and brownfield sites, but urged that the District Council should clearly identify the realistic population growth for the District and that an evaluation of housing and employment land needs, should be dictated by that appraisal.

Regrettably that approach has not been adopted by the District Council and the population projection for the Local Plan period is very close to that put forward in the Core Strategy. A figure of some 40,000 additional population, which was deemed to be unrealistic by the District Council.

Indeed, it was the Town Council's understanding that the District welcomed the government's decision, supported by our MP, to abandon the Core Strategy to allow for a Local Plan which would produce a blend of housing that would meet local needs, and especially the provision of social and affordable family homes, and reflect the aspirations and housing needs of local people.

The Local Plan would also need to recognise the existing shortfall in the infrastructure in the District, which had failed to keep pace with the high levels of development and population growth in the last decade, in addition to provision the infrastructure including transport, educational & health needs, roads and sewers to meet proposals within the development in the plan period.

The Town Council had suggested that in particular, to address the reliance on the car, with resultant issues of traffic congestion and pollution, consideration should be given to development in proximity to railway stations at Warwick Parkway, Hatton and Lapworth and given the planned new station, that Kenilworth should also be considered, including sites at Glass House Lane and Crewe Lane.

To avoid the creation of urban sprawl the Town Council also recommended that the greenfield areas between the towns should also be retained and such action would also retain the historic and natural boundaries between towns, thus preserving and distinguishing identities of the Districts communities.

Such a policy would meet local need, and equally importantly, avoid a disproportionate impact, on particular residents and communities. The policy would also serve to reduce the levels of infrastructure required to support large scale development, and avoid coalescence and the creation of urban sprawl.

The proposals now put forward by the District Council are not based upon a realistic population growth, and considerably exceed the population estimate forecasts put forward by Warwickshire County Council. Rather the figures are assumptions, adopted by the District Council to justify a level of housing development, which are as great as those put forward by the 'Core Strategy'. The proposed population figures, resulting from the assumptions, are dependent upon high levels of inward migration, based upon previous peaks, without any qualified analysis, and which at the same time accept that the past level of high migration, reflected and were dependent, upon the high number of houses being built in the District.

The sites chosen for development in Warwick were substantially rejected within the Core Strategy consultation and it is both disappointing and surprising that the District Council should have so little regard for community opinion that almost 37% of all development proposed in the District, during the plan period, should be allocated to Warwick and also on those sites rejected in the Core Strategy consultation. Such development, it is accepted will generate high levels of infrastructural needs, in respect of transport, including a new river bridge, education and health needs and roads & sewers. The development which will of itself further increase traffic congestion, creating even higher levels of nitrogen dioxide in the Town Centre, which currently exceed the levels approved in the Air Quality Regulation 2008. Thus, the Local Plan Option will increase traffic and create even higher levels of NO2 emissions, and in doing so will be contrary government policy with regard to air pollution.

The Town Council therefore seek to object to the Local Plan proposals on the grounds that:

1) The projected housing development over the planned period are based upon
assumptions of population growth, which are not supported by population estimates and which reflect the Core Strategy population figures, which the District Council have previously considered unrealistic.

2) The development sites are not spread throughout the District in order to meet local need, and concentrate development on sites previously rejected by local communities and very much reflect developer preference.

3) The Plan does not accept that the quality of life and the environment should be guiding factors of the Local Plan and not levels of growth which cannot be absorbed by communities.

4) The Plan does not allocate development to sites which have local support or distribute development proportionally throughout the District to recognise local need, thereby avoiding any single community or locality being subject to the disproportionate impact of development.

5) The proposals do not clearly identify infrastructure needed to support proposed development or avoid detrimental impact of large scale development
upon existing communities and areas of the District, and fail to recognise the existing infrastructure problems.

6) The proposals should reduce the development to levels which can be justified by local population increase and local needs, rather than seeking to maximise development to generate income levels and developer aspirations.

7) The Local Plan proposals do not seek to promote the development of brownfield sites to meet local need for social and affordable housing, but seeks to promote development to generate higher levels of inward migration.

8) The recommendations place a disproportionate level of development in Warwick, whilst not exploring sites elsewhere in the District.

9) The proposals ignore how properties yet to be built, within existing planning permissions, will contribute to housing provision in the period of the Local Plan.

RESPONSE TO WARWICK DISTRICT COUNCIL LOCAL PLAN PREFERRED OPTIONS

PO1: Preferred level of growth
I support the preferred option based on an average 600 new homes per annum, as being realistic against current demographic trends and economic growth projections. However, should economic growth trends change in future years the council should seek to respond flexibly as required.

PO2: Community Infrastructure Levy
This new system of raising funding from new developments to support infrastructure developments offers important new opportunities but also presents major challenges. It requires a new set of relationships between district council, county council and other local partners, to not only draw up and agree CIL-funded infrastructure development plans for the district but to create a long-term stable framework for them to be implemented over many years.

PO3: Broad location of growth
I support the preferred option, and in particular that Kenilworth should have its fair share of new housing development (770 homes per Table 7.2) within the total district target. I disagree with the stated view of Kenilworth Town Council that there should be no further development in the town. A vibrant, sustainable community requires some headroom to expand and develop. There is a clear need for a better housing mix in Kenilworth, especially for more starter homes for young people and opportunities for older residents wanting to downsize to smaller properties.

PO4: Distribution of sites for housing
I support the preferred option that Kenilworth new housing development should be concentrated on the Thickthorn site. Kenilworth Town Council has stated a preference for 700/800 houses to be distributed across the town, but has admitted that this cannot be done while meeting their own criteria. These mixed messages only serve to confuse local residents.
Concentrating new housing development in one Kenilworth location provides the opportunity for the right level of infrastructure development to support this - roads, walking and cycling routes, school and other community facilities. Piecemeal small-scale developments across the town, even if there were suitable sites, would be difficult to support through improved infrastructure, so putting further pressure on existing facilities and resources.
I support strongly the proposed designation of the Thickthorn site for employment use as well as for housing. There has been a long-standing shortage of suitable employment land in Kenilworth. I would not support just an office park however. What is needed is a good mix of employment opportunities, to include for example research and development organisations and light industrial units.
I support the proposed designation of Burton Green as a 'Category 2' village, provided that the Parish Council is fully consulted and involved in decisions about target numbers, types and locations of new housing.

PO5: Affordable housing
I support the proposed option. The proposed policies seem to be soundly based.
It is interesting to note that the Strategic Housing Market Assessment (SHMA) estimates the requirement for 115 affordable houses per annum for Kenilworth alone. This reinforces my earlier statement under PO3 that there is a clear need for a better housing mix in the town. The SHMA estimated need is greater than the total new housing allocation for Kenilworth over the 15 year period of the plan. Consideration should therefore be given to achieving a much higher figure than the minimum 40% affordable housing on the Thickthorn site, and also seeking every opportunity for more affordable housing in any 'windfall' sites that come forward for development within the town.

PO6: Mixed communities and wide choice of housing
I support the proposed option.
Regarding the Thickthorn site, for the reasons stated previously I see the priority within the housing mix being for starter homes for young people, and smaller units for older residents wanting to downsize but to stay living within the town. There could also be an opportunity to cement further the links between Kenilworth and the University of Warwick by the building of new student accommodation - something completely missing at the moment.

PO9: Retailing and town centres
I support the proposed option, in particular promoting the vitality and viability of town centres, and strongly resisting further out-of-centre retail developments.

PO12: Climate change
I support the proposed option, in particular ensuring flood resistance and resilience in all new developments through sustainable urban drainage schemes (SUDS). Well-designed SUDS are not only functional, but can enhance the natural environment of open space areas associated with new developments.

PO13: Inclusive, safe and healthy communities
I support the proposed option, in particular the importance of access to high quality open spaces and sport/recreation facilities for all residents.
In para 13.10 (2nd bullet point), I would like to see the words "pedestrian and cycling" substituted for "pedestrian". Policies should do everything possible to encourage the greater use of bicycles by all sections of the local community, both for healthy exercise and as a sustainable/zero carbon means of transport within our district.

PO14: Transport
I support the proposed option, in particular the strong emphasis on promoting sustainable forms of transport.
The importance of the K2L cycling route between Kenilworth and Leamington cannot be overemphasised, together with provision for bus lanes and bus priority schemes on this important route. I see these as the priorities for highway improvements on this route rather than increased provision for private vehicles.
Within the town of Kenilworth, there is a massive task to be done to improve routes and facilities for pedestrians and cyclists, and this should be the priority for infrastructure investment to support new housing development. I disagree fundamentally with the view of the Town Council that a multi-storey car park is required in the town centre. Policies should be seeking to encourage residents to leave their cars behind for short-distance local trips whenever possible.
Map 5 shows a proposed cycle route through Abbey Fields to link up two elements of the National Cycle Network. This has been the subject of considerable negative comment by some residents, community organisations and the Town Council, which has been reflected in other responses to this consultation I understand.
The council has a duty to balance these strongly-expressed views, i.e. that no cycles should be permitted in or through the Abbey Fields, with the needs of the local community as a whole. I would highlight some of the comments in the Draft Green Space Strategy document, in particular section 4.1.7 on page 19 of that document:
"The value of green spaces can be greatly enhanced by linking them together into corridors and networks giving safe, attractive access for pedestrians and, in some cases, cyclists.
"... enable people living in urban areas to reach the countryside .... provide a green alternative for journeys to work or school."
"By-laws prohibiting cycling and horse-riding in some green spaces may need to be reviewed to achieve this."
Through the development of the Connect2 Kenilworth (C2K) route, the town has gained a valuable green corridor linking it to the countryside, and providing an important new travel alternative for people working at the university, Policies should be focussed on making it more accessible from all points of the town, and there is no doubt that a cycle route through Abbey Fields would become an important link between the west side of the town and C2K. Currently no other options have been proposed which would achieve the same result.
There is also the fact that the Abbey Fields are an important destination in themselves for many local residents, including families with young children wanting to access the playground area, and yet at the moment there is zero provision for any residents wishing to travel there by bicycle. Residents lucky enough to live nearby are able to walk, but others have no alternative but to drive there. With the Abbey Fields car park already at saturation point and due to reduce its capacity shortly, the council must consider how it can encourage more residents to access the Fields by bicycle.
In terms of transport infrastructure to support a new Thickthorn housing and employment development, for the reasons stated earlier a high priority should be given to sustainable transport options - i.e. walking, cycling and public transport. However, this site also offers the opportunity to create an important new link road between the traffic island over the A46 by-pass and the eastern side of Kenilworth (joining Glasshouse Lane at a point near Rocky Lane). As well as serving the new development and ensuring it is fully linked into the rest of the town, it would help to alleviate current traffic congestion around the St John's gyratory - something which piecemeal development of eastern Kenilworth over many years has failed to address.

PO15: Green infrastructure
I support strongly the proposal for the development of a peri-urban park north of Kenilworth. This would build on the success of the C2K Greenway route in opening up this important piece of our local countryside to all sections of the local community.
I do not support the arguments so far put forward for the restoration of the Kenilworth Mere. The outline feasibility study conducted by Warwick Business School MBA students showed that any viable scheme could have a massive impact on a large area of precious countryside adjacent to Kenilworth Castle, almost certainly involving commercial developments such as hotels, apartments etc.

PO16: Green belt
I support the re-drawing of green belt boundaries to the east of Kenilworth and around the village of Burton Green in order to permit the developments proposed in this Local Plan, and for no other reason.

PO18: Flooding and water
As stated previously, I support the requirement for SUDS schemes as part of all new developments.

Providing sustainable levels of growth :
The levels of growth envisioned are not sustainable- in that the level of infrastructure, its
distribution, housing location and jobs, do not match the population growth forecast.
A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause
immense damage to the the character of the County Town
Level of Population Growth and demand for housing assumptions:
These are flawed because:
Given that more than 50% of national population growth has been from immigration over the
last two decades, and the government has publicly stated it wishes to greatly reduce this
future net immigration, why is Warwick District planning for an even greater level of growth
over the next 15 years, than has been experienced in the recent past?
* Housing demand growth in England is from a combination of net immigration and
changes in household demographics towards smaller households.
* However the impact of a prolonged recession which the Prime Minister says could last
another decade, will impact on the ability of individuals to afford housing.
* This is manifest in the rapidly rising age of first time buyers and the profound
demographic change since 2008 in more young adults living at home with their parents
for much longer than in the past.
* So why is the plan still assuming a rapid increase in demand for single occupancy
households; when the actual demographic trend is away from this?
* Is the modelling based on current data, or is it simply looking at the demand during the
decade of rapid growth and easy availability of mortgage loans pre the 2008 crash?
* This in turn could mean that in fact far less individual units are required for the District
as a whole, but a greater emphasis should be given for multi generational living , with
semi independent adults?
Distribution of housing within the District
The plan talks about the need to distribute housing across the entire District , but then in fact does
not do this!
A starting point should be that EVERY ward has the same level of housing growth during the plan,
i.e. A 20% across the board increase.
* It appears that most housing will be again concentrated within Warwick and parts of
Leamington Spa, with very little in the large villages or in Kenilworth
* This is curious, as it also points out the lack of affordable rural housing but then basically
ignores any provision for it!
1
6 Hampton Street, Warwick, CV34 6HS
* The inexplicable lack of housing growth in and around Kenilworth is most odd given that the
job growth is likely to be around the University and Coventry Airport, and the town already
has a lot of facilities.
* 830 houses over 15 years in the villages is clearly inadequate to meet their housing needs
or the lack of affordable housing, this is only 55 houses per year spread across a wide
geographical area.
* I suggest as a minimum 2500 of the 10800 houses in the plan be developed in the
village areas spread evenly across the district.
* This provision WOULD meet the need for affordable rural housing projected, at 55
per year if 33% was "affordable".
I suggest two areas which have been overlooked for large scale housing provision are Radford
Semile and Lapworth.
* Both are ripe for large scale "garden suburbs", supported by business parks. This would
support and make more viable their existing shops and schools.
* I suggest that at least an additional 1000 to 1500 houses are considered for each ward, and
therefore the significant benefits of population growth extolled by this plan are met, coupled
with local affordable housing and retail provision
* I note they both have existing primary schools, and good proximity to public transport and
roads, and Lapworth has a commuter railway station.
* There is also the opportunity in Lapworth to build a business park to tap into the proximity
to Solihull and at Radford Semile to build a business park dedicated to engineering to tap
into the expertise and supply chain associated with Ricardos.
* This in turn would mean much smaller developments around Milverton and Warwick would
therefore by required.
Transport
For the plan to be actually sustainable, there needs to be a lot more vision for integrated public
transport.
Cycle ways:
It would be a good objective to work with the County Council to ensure that EVERY community is
served by a dedicated cycle way, especially within the urban areas, where short lengths of cycle
way often just stop.
This should be funded by developers of the new housing as a priority via the Community
Infrastructure Levy
Commuter Rail and Bus Routes:
The plan envisions much new low cost housing, yet this is concentrated mainly around Warwick,
and the new job provision is in the north of the District.
HOW are those in low paid jobs who will presumably be the beneficiaries of the "low cost" housing,
be able to commute to where the jobs are if they cannot afford their own cars?
For the plan to be sustainable surely it would be better to have more smaller housing
developments within walking/ cycle distance of the new job provision; i.e. small estates near small
business parks?
* IF this is not possible a commitment to provide and subsidise long distance inter nodal
commuter bus routes is essential.
* Low paid workers will need to be able to commute quickly and cheaply to where the jobs
actually are!?
* This can be achieved, by developing inter town express bus routes to link together;
2
6 Hampton Street, Warwick, CV34 6HS
Warwick, Leamington, Stratford, Coventry, The University, Nuneaton, Rugby, Kenilworth
and the larger villages; integrated with mini bus services which will THEN serve the local
housing areas. Funded by the Community Infrastructure Levy.
* NOT the farcical situation as now when it take between 90 and 120 minutes each way to
get between towns , which IF a direct town centre to town centre route could be achieved in
20 -30 minutes, (existing buses take very circular routes).
* This lack of effective public commuter transport compounds inequality and creates greater
dependency on state subsidies, as those able and willing to work cannot afford the
transport to get to the jobs, and the bus services are simply too slow and too infrequent to
be a viable alternative.
* Similarly regular local new commuter train services linking together ALL the major
Warwickshire Towns and Coventry should be a priority, funded by the Community
Infrastructure Levy,.
* The "virtual" park and ride scheme, seems like a lot of hot air political spin. Does it
effectively mean NO park and ride , but a slightly extended bus route?
Air Pollution
Parts of WDC already do not meet the Nox emissions EU Directive, including large parts of the
centre of Warwick.
This is likely to be tightened up in the near future with harder targets and lower permissible
emissions, possibly wit fines for non compliance.
It therefore seems curious that the large-scale housing developments on the edge of Warwick are
suggested with a likely 40% increase in the town's population, over 15 years.
This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?
Historic Distinctiveness
* I believe the plan should do more to promote good design in housing.
* It is should also seek to unambiguously protect the historic buildings in the area and their
settings, as this is one of the major "draw" factors for population growth and economic
vitality
* The plan has some very vague and bland statements, it needs a clearly articulated
"heritage vision", backed up with detailed planning guidance and then an appetite for
rigorous enforcement.
* Our towns are special, BUT only if the key historic and architectural elements and values
are protected, otherwise they risk becoming a sprawling new town reminiscent of Milton
Keynes.
* The existing open spaces, sports fields, allotments and parklands should unambigiously be
protected from development, including their settings.
Definitions of affordable Housing
I suggest that the definition of what is affordable housing needs broadening.
The plan highlights the need for housing for the elderly and the growth of the elderly as a % of the
population.
One solution to their needs and the obvious trends in semi independent adults living much longer
with their parents because they cannot afford to get on the housing ladder, would be to classify
"granny flats" or semi separated apartments within houses as going towards the "affordable
housing" targets.
Multigenerational living should be encouraged as it meets housing need, is sustainable and reflects
changing land-use patterns. There is the opportunity to boost this by incorporating it into the plan's
3
6 Hampton Street, Warwick, CV34 6HS
housing targets and helps meet the need for "mixed" housing.
Gypsy Site:
I suggest the land adjacent to the Junc 15 of the M40 might be a suitable site.
There is little nearby existing housing, but a public bus service and good road access
Employment Land
I support the use of green belt land to expand employment opportunities on well designed business
parks at Stoneleigh and around the University. BUT there must be good public transport links to
allow potential workers to access these jobs from the existing WDC Urban areas.
HS2
HS2 could open up significant advantages for the West Midlands by improving links to London &
Heathrow, but more importantly Northern English cities and direct rail links with northern Europe.
I support HS2 and would suggest that rather than opposing a strategic transport plan which cannot
be blocked by WDC due to existing legislation, the Council concentrates in obtaining maximum
benefit for the District, by getting subsidies for improving the transport links to meet the HS2
stations.
Conservation Areas and Historic Environment
* WDC must commit to protecting the existing listed buildings, open public spaces and
conservation areas, from encroachment by development.
* Particularly as most development needs - as defined by this plan-will be met by building on
greenfield and brown field sites, there is therefore less pressure to damage the existing
historic town buildings?
* I suggest the English Heritage Guidance published in May 2011 in "Seeing History in the
View" should be incorporated into the plan.
Climate Change
Flooding and SUDS. Given the recent patterns of heavy rainfall and the long history of local
flooding, great care should be given to the sitting of all new developments.
Claims of 1000 year flood modelling should be treated with extreme scepticism as reliable data
only exists for the past 90 years.
Especially in existing urban areas a conservative approach should be given to any large new
buildings and their impact on surface water drainage.
Consideration should be given to more local flood defences and helping individuals to flood proof
their homes.
Fear of Crime
* No sex clubs or night clubs should be allowed near housing- they should only be built in
non residential areas.
* No new pubs, bars or hotels should be built or change of use in areas of predominately
residential nature, to protect existing residential amenity.
* There should be the presumption that in residential areas new businesses will not increase
the background ambient noise levels. If this cannot be achieved these businesses should
4
6 Hampton Street, Warwick, CV34 6HS
be located in designated areas such as retail or business parks.
Good Design:
The plan highlights good design and sustainability, this should be supported but defined
All new housing should be built to Parker Morris standards
http://www.singleaspect.org.uk/pm/index.php
* These standards are based on ergonomics of the minimum space needed to meet "a
functional approach to determining space standards in the home by considering
what furniture was needed in rooms, the space needed to use the furniture and move
around it, and the space needed for normal, household activities."
As these were the minimum set for UK 1961 social housing it is not unreasonable that they should
be the very minimum acceptable in WDC for the next 15 years. OR we run the risk of creating
housing that CANNOT meet the needs of the occupants and risks becoming dysfunctional or
slums, which by definition is hardly "sustainable".
Public Space:
Existing open space, sports and recreational buildings and land, including playing fields, should
not be built on !
Any new developments should have additional public space.
Tourism
* Any new visitor accommodation -over a small number of bedrooms- should be examined to
see if it would have a negative impact on the existing providers locally as a material
planning consideration.
* Small independent providers of accommodation tend to support far more local jobs and
have a bigger local economic impact by their use of local suppliers.
* It is desirable to have a diversity in type and location of accommodation providers.
* New budget chain hotels which have a similar impact on existing hotels and guest houses,
to that of supermarkets on independent retail traders. They should only be permitted where
it can be demonstrated there is an unmet demand or capacity need. And there will not be a
detrimental impact on existing buisnesses.
Green Wedges
This seems to be a meaningless concept.

The three most important issues in Warwick are:

- all the empty buildings in the centre of Warwick
- traffic congestion
- need for sporting facilities for all

Park and Ride

To make any impact on congestion in Warwick there needs to be a Park and Ride on all 3 roads into Warwick.
- Birmingham Road, Banbury Road and Stratford Road.
- One Park and Ride into Warwick is not enough

If these 3 Park and Rides were in situ then all school children being taken by car to the private (in particular) and state schools should be encouraged to take the Park and Ride. Consultations need to take place at all the schools.

There is always so much talk about the traffic in the centre of the Warwick and anyone who lives in the centre of Warwick knows that the main cause is the school run.

Northgate Street

Old county education offices converted into luxury apartments with parking spaces. I think there are many older people in particular who would like to downsize from their large family homes into the centre of Warwick but they want to move into spacious and luxurious accommodation. It does not need to be sheltered accommodation.

On the county court side I would like to see this developed into a hotel. Warwick needs a good hotel in the centre.

One of the old courts could be converted into a new Registry Office for marriages. The present Registry Office leaves a lot to be desired. On busy Saturdays the guests are queueing up on the busy High Street. When you enter the present building the first sign you see is "Relate" for marriages in trouble. Hardly appropriate when you are about to get married.

Old Lugg and Gould Building, Fire Station, Leper Hospital, Masters House, Old Printing Works in Bowling Green Street

All empty and all need to be converted to houses/offices in the centre of Warwick.




Sporting Facilities in the New Plan

An Ice Rink built in the district for skating, ice hockey teams, curling teams etc. This would seem to be a good opportunity to put this in the Local Plan which would be of benefit to the whole of the Warwick District.

Tennis courts/netball courts - free to use - incorporated in all the proposed housing developments. Money to be set aside for an organizer/coach for coaching/playing activities for after school/school holidays and daytime activities for young children and adults/retirees.

We wish to respond to the proposed Infrastructure Plan - Draft as follows:-

1.
Section 4.2
Para 16

Preferred Options (Full Version) section 4.12 Par 11 is supported as enabling organisations to provide community infrastructure such as schools, and particularly in respect to future schooling needs.
NPPF Item 72 states regarding choice of schools that "Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement" and "work with schools promoters".

NPPF Item 72 also states that The Government "attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities"......."development that will widen choice in education".
This is witnessed to in the Government's current support for Free Schools.

Such organisations clearly include "Faith schools".

A request is made to include a reference to "Free Schools" in this section.


2.
Section 4.5

There are many items that could be included in the infrastructure and as an organisation responsible for the provision of Gospel Halls we are concerned that there is no reference to places of worship.
NPPF Item 70 shows that to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should: plan positively for the provision......(of)... places of worship.
NPPF Item 171 Under Health and well-being states that "Local planning authorities should work with public health leads and health organisations to understand and take account of the health status and needs of the local population (such as ........ and places of worship).
Places of worship included at national level should be sufficient warrant to require specific inclusion at local level.
It is vital that this spiritual "well being" can be extended and made freely available throughout the whole community.
Every man has a responsibility to answer to God. "Thou shalt worship the Lord thy God, and him only shalt thou serve" Luke ch 4 verse 8.

NPPF Item 38 addresses "larger scale residential developments" and the need for "key facilities" within walking distance.
Representation was made to include Places of Worship in The Warwick District Local Plan 1993 and the following wording was amended and included:-
"It is of great importance that new development is of the highest quality and makes proper provision for such elements as infrastructure and community facilities, including places of worship. To this end, detailed development briefs will be prepared for all major housing allocations, prior to Outline Planning Permission being granted. The brief will be adhered to closely throughout the process of development of each site"

NPPF Item 28 also shows that places of worship contribute to a prosperous rural economy.

Places of worship are a vital part of the infrastructure and should be specifically included; without which this document is incomplete .

Thank you for your email of 1st June 2012 re the above subject. The Councillors of Baginton Parish Council
have considered the Preferred Options documentation. We have also attended the WRECF meeting of
28.6.12 and the WDC Proposed Development Forum of 2.7.12. We have debated these issues at various
meetings. We have also attended the Gateway Developers presentation at Baginton Village Hall of 19.6.12
where we gained written feedback from many concerned residents.
This letter sets out our opposition to the Gateway proposals, as presented to residents on 19.6.12, being
included in the Local Plan Preferred Options. It also puts forward our preferences regarding housing need for
the area based, on our current Parish Plan. Whilst the majority of the proposals are satisfactory, in our view,
we are alarmed and concerned by tentative proposals to include the "Gateway" in the proposals, as
illustrated in the Preferred Options documents. We write asking you to consider all our comments below
when making your judgement:-
1. BPC oppose Preferred Options 8.15, 8.18 and 8.42 abstracts of which are in Appendix 1 of this
letter. BPC opposes the inclusion of the Gateway shown in Map 3, an abstract of which is shown in
Appendix 2 of this letter. The Gateway proposals are not appropriate development and should not
be included, for reasons as set out below.
2. The NPPF calls for Protecting the Green Belt in section 9. See abstracts of section 9 in Appendix 3
of this letter. Baginton Parish borders with Coventry City. There is a vital need to prevent the
unrestricted sprawl of Coventry into Rural Warwickshire, safeguard the countryside from
encroachment and preserve the setting and special character of our village, with its Roman Fort,
Castle and Grade 1 listed church amongst other things. The gateway proposal is contrary to these
fundamental requirements of the NPPF. The development encroaches on previously undeveloped
Green Belt fields which provide a vital buffer between rural Warwickshire and Coventry City. It is
essential that this buffer remains. BPC believes that WDC have an ideal opportunity to prevent the
urban sprawl of urban Coventry into rural Warwickshire. WDC should not therefore support the
Gateway project, which must be removed from the Preferred Options and local plan. The
development is in the protected Green Belt with no very special circumstances to justify its
existence. The openness of this Green Belt land must be maintained.
3. The environmental effects of the Gateway proposal have not yet been considered and there are
many reasons why such a proposal is unsustainable development adversely affecting the
environment and contrary to the requirements of the NPPF. There is no need for such a
development, which should be omitted from the local plan.
4. The proposal significantly affects the nationally significant Highways Agency Tollbar improvement
scheme; the affects which need to be clearly annotated in the local plan.
5. The Gateway includes a "smart card" system for allowing Baginton residents access to Rowley
road, but with no details of how this would be run.
6. It is noted the large industrial units are envisaged to have 24/7 operations, yet the environmental
effects of 24/7 HGV operations on local rural and other communities has not been considered.
7. The proposals are unsustainable as they fail to comply with fundamental tests in the NPPF. The
proposals are to develop Green Belt land but with no very special circumstances to warrant such
development. It is both necessary and essential for WDC to consider all other developments with
extant planning permission in the wider area. There are many such developments in the locality and
which are suited to developments of this nature, e.g. (but not limited to) the huge sites at Ansty and
Ryton, both with infrastructure already in place. Preferred Options, section 8.42 (Section 8.33 of the
draft Local Plan) specially refers to the Coventry Gateway project, it specifically states 'To
demonstrate that there are not any other preferable and suitable sites'. The above clearly
shows that there are alternative sites available with extant planning permission within the subregion,
and further afield, which provide more than adequate development opportunity, so there is
no need for this development. It is essential that the Local plan includes a requirement to review all
existing developable land in the sub-region and further afield, to ensure the proposals are robust.
BPC demonstrates that there ARE other preferable and suitable sites, so the Gateway should be
excluded.
8. There is no need, either economic or otherwise, for the Gateway proposals to be included in the
local plan. There is no case for releasing land in the Green belt for the Gateway development.
9. The development to the north of the A45, in Coventry, can be developed without destroying the
Green Belt to the south of the A45, providing 4000 jobs for the benefit of the region. There is no
need for the Gateway development south of the A45.
10. The provision of "up to" 14000 jobs is inaccurate and misleading. Given that 4000 of the 14000 jobs
quoted are for development north of the A45, within boundary of Coventry, already with planning
permission granted to another developer (Whitley Business Park), it is wholly inaccurate for the
Local Plan to headline up to 14000 jobs. Of the remaining 10,000 jobs, it is highly likely that these
will not be newly created jobs, but in the main taking jobs form elsewhere in the sub region and
further afield. These jobs can and should be created using the vast acreage of sites in the sub
region, and nearby, which are already available, or have infrastructure already in place, or have
extant planning permission, or which are otherwise far more suitable to gain planning permission.
The local plan should quote a realistic level of job creation, within WDC only, accounting for all
other sites.
11. The closing of the Bubbenhall Road and Rowley Road to the general public will destroy the many
local rural businesses which thrive in Baginton Parish, e.g. Baginton Village Store, Hong Kong
House, Smiths Nurseries, Russell's Nurseries, Oak Farm, The Old Mill, The Oak Pub, British
Legion Club and many others. Each would be adversely affected and forced to close with the loss
of jobs, adversely affecting the local sustainable community, contrary to the NPPF. It is absolutely
essential that the Bubbenhall and Rowley Roads be maintained as a pubic right of way with the
present alignment between Baginton and Bubbenhall, to maintain the sustainability of local rural
businesses hence comply with a fundamental aspect of the NPPF.
12. BPC are also concerned that the provision of a new road west of the runway could be put into a
deep cutting which would pave the way for future runway expansion. It is absolutely essential that
the Bubbenhall Road be maintained as a pubic right of way with the present alignment between
Baginton and Bubbenhall, to prevent the Airport from runway expansion in the long term. See old
proposals from September 2002 in Appendix 4 of this letter. BPC acknowledges this is not part of
current proposals but BPC are most concerned that the proposed Bubbenhall Road alterations
could facilitate the opportunity to allow such development in the future. This must not be allowed to
be facilitated, by ensuring the Bubbenhall Road stays as it is and the proposed alterations shown
on the Preferred Options are omitted from the emerging Local Plan.
13. The documents presented do not adequately correlate the requirements of the NPPF with the
proposals for the Gateway. The proposals are not therefore robust in the view of BPC, so the
proposals should be omitted.
14. There is an excellent "Green Infrastructure" opportunity to maintain the undeveloped green belt
green fields which lie to the South of the A45 and which will be adversely affected by the Gateway
project. Instead of the Gateway WDC should give consideration to developing this area under the
Green infrastructure scheme. This will have the advantage of ensuring that the surrounding areas,
such as Baginton Parish, do not suffer from urban sprawl and maintain important opportunities for
Flora and Fauna to flourish. The planted buffer zone to the urban sprawl proposed for the Gateway
is insufficient compensation for the loss of the undeveloped green belt green fields which presently
act as a natural buffer between urban Coventry and rural Warwickshire. It is also far to close to the
Lunt Roman Fort. The Gateway should be omitted from the Local Plan.
15. BPC are very concerned that the Preferred Options summary leaflet makes no mention of the
Gateway development, only showing "highway improvements as per abstract from the summary in
Appendix 5 of this letter, which are as per Map 5 of the preferred options.... This is
misrepresentative of the developer's intentions. The public are not therefore being afforded the
opportunity to see the true extent of the proposals in the summary leaflet, so are not being afforded
the opportunity to comment. This must be rectified by modifying the summary document to include
the developer's true intentions. These are not highway improvements but will destroy public
highway rights of way which are essential for the prosperity of the many rural businesses which
thrive in this area and which will be destroyed by the Gateway development. These are not
improvements but will serve to develop a huge area of green belt land and create urban sprawl,
contrary to the principles in the NPPF. It is essential that these proposals be omitted from the
Local Plan
16. The 12.3.12 WDC map entitled "unrestricted natural and green corridor greater than 2Ha" doesn't
show the green space south of the A45 which forms a natural barrier between Coventry and
Warwickshire, and is undeveloped Greenfield Greenbelt land protecting Baginton from urban
sprawl. The map should be amended, the area recognised as such and the area not allowed to be
developed.
17. Councilors believe that the Gateway proposals, by a private developer who also owns the Airport
and who is also past and proposed Chairman of the Local Enterprise Partnership promoting the
development, are foisting an unwanted and unnecessary development on Baginton village which
will ruin this rural village community, destroy essential Green Belt and destroy its local amenities
and businesses. The quality of life of Baginton and Bubbenhall residents will be significantly
adversely affected by the Gateway proposals. The proposal is against resident's basic human rights
under the Human Rights Act, due to the traffic and operations noise from huge warehouse logistics
development which will run 24 hours per day, seven days per week, with especially adverse effects
at night and weekends. Cllrs anticipate significant HGV traffic movements all night which will be
particularly disturbing to residents.
18. The Gateway development in not sustainable compared with other nearby developments with
extant planning permission, which are sustainable.
19. The proposed smart card access system for local residents and businesses is impracticable and
unworkable, with no one willing to operate it, certainly not Baginton PC. It is understood alternatives
are under consideration but based on what BPC are aware of at this time these proposals are
damaging to the village and must not be allowed to proceed.
20. The proposals put into jeopardy the construction of the Highways Agency Tollbar Island proposals
due to commence early next year. The proposals will not facilitate major improvements to the road
network not already covered by the HA proposals, but will only add to the traffic in this area.. In
addition, the proposals will only add to the traffic in this area, so will not facilitate improvements
over and above what is already proposed by the HA, so the statement must be removed from Para
8.33 of the draft.
21. It is noted from the presentation on the Local Plan by WDC of 28.6.12, at Baginton Village Hall, that
there is 23 hectares of business development land proposed within WDC boundaries separate to
that of the Gateway. Noting that many commercial premises within the sub region, and slightly
further afield in Solihull, lie empty and unused at this time, the additional 23 hectares of business
development land is more than sufficient to satisfy the need for economic growth without the
Gateway project. There is no need for the Gateway project and this must be omitted from the
proposals
22. BPC believes it is entirely inappropriate for WDC to support the C&W Gateway proposals, which
are against the fundamental principles of the NPPF, adversely affects the environment, adversely
affects Parish residents human rights to peace and quiet, will destroy rural businesses based in
Warwickshire, will develop on high quality green field Green Belt with no very special
circumstances, will create urban sprawl and which will jeopardise industrial development elsewhere
in the local area which already has planning permission or has been previously developed and will
destroy the openness of the area, amongst other things. The Gateway should be removed from the
Local Plan
23. Councillors believe there is a clear conflict of interest between the LEP, which we understand is to
be once again chaired by the Owner of both development companies, Sir Peter Rigby, and the
broader requirements of the residents of WDC. BPC Cllrs reinforce the need for WDC to be
independent and not compromise its integrity through the forced will of a developer who is intent on
ruining our unspoiled corner of rural Warwickshire for financial gain. It is wrong therefore to refer to
the LEP within the Local Plan.
24. WDC should modify the proposals to state that its preferred option is to utilise to the maximum
capacity all sites in the sub region with extant planning permission prior to developing any further
site on Green Belt Land. WDC should review all existing developed land within the sub-region. It is
vital that WDC explores and justifies the case for releasing land within the Green Belt when existing
Brownfield and other sites with extant planning permission exist within the sub region remain underutilised
and unoccupied.
25. BPC observes that the Gateway proposals do not protect the character and scale of the village, nor
the openness of the rural countryside around the village, so should be omitted.
26. BPC has already gained written feedback from almost one hundred residents, all of whom believe
the Gateway proposal is damaging to Baginton and there is no justification for ruining the Green
Belt. All wish to see the Green Belt protected. It is essential that WDC takes account of the wishes
of all local residents and excludes this development from the local plan.
27. All the above demonstrates that the Gateway site, which is stated in 8.18 as being "identified as a
site of regional importance for employment to serve the regeneration needs of the Coventry and
Warwickshire sub region" is fundamentally incorrect, fundamentally unnecessary and fundamentally
against most requirements of the NPPF, so should be omitted from the local plan.
Regarding housing policy, Baginton has a Parish Plan and requests that the deliverables in this document be
accounted for by WDC in formulating the Local Plan. In particular please note the below comments:-
28. BPC supports modest sustainable increases to housing in accordance with our letter L075A to
WDC of 8.1.12, a copy of which is enclosed as Appendix 6. This is based on the output from the
Baginton Parish Plan. The Local Plan should include opportunity related to small scale sustainable
development of this nature, to retain the nature and character of the village and help to support the
many local rural businesses in the village. Please note in particular that in all cases any housing
shall be wholly in character with the village, be sympathetic to the amenity of existing
properties/people and shall not interfere with the Green Belt. BPC opposes the Gateway
development on the Green Belt to protect the rural nature of our village, to protect the openness of
the area and to protect the surrounding area from urban sprawl.
29. BPC objects to the classification of villages generally. The Local Plan must not dictate the type of
housing development to villages, but rather should take into account village desires under the
Localism act and in the case of Baginton, our Parish Plan. In this respect we again ask WDC to
account for our letter L075A as point Nr 28 above.
In conclusion, BPC consider that the proposed gateway is entirely inappropriate and ill considered
unsustainable development, contrary to fundamental requirements of the NPPF, with no need given the
significant size and number of underutilised employment creating developments which already exist with full
planning permission in the Coventry and Warwickshire sub region area and further afield. There are no very
special circumstances to develop on the Green Belt, rural businesses need to be protected, urban sprawl
must be prevented and the openness of this Green Belt land must be maintained.
BPC oppose all Gateway development south of the A45 and recommend that the Gateway be omitted from
the Preferred Options and excluded from the Local Plan, with any development limited only to that shown to
the north of the A45, which is within the boundary of Coventry City Council, utilising Ansty, Ryton and other
existing suitable sites for any economic development over and above the 23 hectares already allowed for
within the Preferred Options and emerging Local Plan. Housing policy should follow our recommendations in
Appendix 6 herein.
Please confirm you will consider all the above and confirm you will omit all aspects of the damaging and
unsustainable Gateway development from the emerging Local Plan, within the boundary of WDC.

New Local Plan Preferred Options Consultation
1. Thank you for your consultation dated 1 June 2012, which we received on the same date. Thank you for allowing additional time in which to respond. This enabled our submission to be compiled with the benefit of some input from locally based colleagues.

2. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Overview

3. There is much to commend within the consultation document in terms of protection and enhancement of the natural environment. We have relatively few comments to make but would like to raise a small number of potential areas of concern and possible improvement.

4. We assume the numbered preferred options presented in the mauve boxes foreshadow policies content rather than representing proposed policy wording. For that reason have not recommended any detailed changes to text but have confined ourselves to broader observations.

Detailed comments

Section 2.5 Strategy for the Future and Sustainable Prosperity of Warwick
District

5. We support the fourth bullet under "environment" and second bullet under "emphasis on infrastructure" which pick up on the importance of protecting and enhancing of the natural environment. It is important that the final version of the plan follows through on these important components of the vision. In line with the NPPF requirement (paragraph 157) that

Section 4.12 Enabling the district's infrastructure to improve and support growth

6. We welcome the reference (objective 14) to enabling improvements to be made to the built and natural environments which will help to maintain and improve historic assets, improve habitats and their connectivity, help the public access and enjoy open spaces such as parks and allotments, reduce the
risk of flooding, keep the effects of climate change (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles. This should help to translate the requirements of the NPPF into practice and is welcome recognition of some of the multiple ecosystem and other benefits that the natural environment and green infrastructure delivers for communities.

PO2: Community Infrastructure Levy

7. Natural England recognises that CIL has a part to play in providing the infrastructure that new and existing communities will need. Green infrastructure is a part of the essential necessary to support growth and we trust the Council will ensure that the need to make provision for key green infrastructure

PO3: Broad Location of Growth

8. Natural England is concerned that the overall level and spatial distribution of growth should be informed through detailed environmental testing. From that perspective we welcome the Sustainability Appraisal work undertaken so far and the fact that the allocations have avoided direct impact upon statutory biodiversity designations.

9. We do note that a number of preferred allocations (e.g. Whitnash East) incorporate, or are bounded by, Local Wildlife Sites and/or Local Nature Reserves and would encourage the Council to ensure that sufficient safeguards could be incorporated before confirming these allocations.

10. Similarly, a number of the preferred allocations (e.g. West of Europa Way) lie adjacent to Warwick Castle Park . This site is not subject to any natural landscape or biodiversity designation but is the subject of a Higher Level Stewardship agreement to maintain and improve its environmental value. We would like to ask whether the Council will consider the potential for indirect impacts on the Park (e.g. of increased recreational pressure) and degree to which these can be moderated before confirming these allocations?

PO10: Built environment

11. We welcome inclusion of the intention to protect, enhance and link the natural environment through policies to encourage appropriate design of the built environment. We also welcome the intention to set out a framework for subsequent more detailed design guidance to ensure physical access for all groups to the natural environment. The natural environment and access to it are important aspects of urban design that have been overlooked in some areas in the past.

PO13: Inclusive, Safe & Healthy Communities

12. The third and fourth bullet points are supported, provided a proportion of the new open spaces provided as part of new development are made up of accessible natural green spaces with all the associated health and wellbeing benefits. Natural England promotes an Accessible Natural Greenspace Standard1 that we encourage local authorities to adopt.

PO12: Climate Change

13. Natural England welcomes measures to tackle climate change which is the greatest long term threat to the natural environment. None the less, we look to plans to take full account of the local natural environment to accommodate such infrastructure. In particular, we encourage plan makers to identify areas for different forms of low carbon energy and to ensure that designated landscapes are fully protected.

14. The intention to require that new development is designed to be resilient to and adapt to the future impacts of climate change in welcome. We particularly support the reference to the use of greenspace and vegetation, (such as street trees) to provide summer shading and allowing winter solar gain.

PO15: Green Infrastructure

15. We support the preferred option relating to green infrastructure, which is consistent with the NPPF (paragraph 114). We particularly welcome the recognition that this exists and can be supported through planning at a variety of spatial scales.

16. We would expect the final pan to include more specific detailed policies on certain aspect of green infrastructure. For instance, we trust that policies for biodiversity will extend beyond offsetting to cover the landscape scale approach, net gain, ecological networks, designated sites and priority and protected species.

17. Similarly, the references to geology, soils and ecosystem services are welcome and we would expect that these matters will translate into robust policy content within the final plan.

PO16: Green Belt

18. We support the reference to positively enhance the beneficial use for the Green Belt, such as looking for positive opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity or to improve damaged and derelict land. This is an aspect of Green Belt that has not always been afforded an appropriate degree of attention in all areas.