The New Local Plan (NLP) Preferred Option:Flooding and Water - PO18

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 PO18 ...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.

There are strong grounds for environmental concern regarding proposed development of the site.
The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies that:
* a part of the site falls within a flood zone 3A and implicitly should not be developed;
* it contains a Water Source Protection Zone and an area of Groundwater Vulnerability, which would require consultation with and permission from the Environment Agency before any encroaching development. We know from a past pollution incident from the Nuffield Hospital, and related correspondence, that the Environmental Agency view this Zone/area with extreme seriousness.
* it would result in the extensive loss of Grade 2 agricultural land which both contributes to a sustainable economy and to the character of the landscape.

Noted.

My thoughts are: -

Let's assume that central government want you to produce a plan, and your proposed number of houses are to be built in the area: -

1. We don't have the transport infrastructure to cope and the 'improvements' you suggest will be insufficient. We have the Rivers Avon and Leam moving east-west through the district with inadequate crossing points. Building off the Banbury Road Warwick will require more vehicles to cross the current and old bridge in the town centre. This would need replacing at6 great costs and inconvenience before any building can take place. The idea that each new development will have its own industry seems wonderful but in the real world people don't and can't move when they change jobs or can't afford to buy houses where they work. Some commute into Birmingham or to London but are unable to get to Warwick station by public transport so are forced to drive to Warwick Parkway where more land is to be lost to a tarmac car park. THE TRANSPORT STRUCTURE CANNOT COPE NOW. DO SOMETHING BEFORE THE BUILDING STARTS!

2. Building the housing estates that we have seen in UK over the last 50 years, invariably creates ghettos of soul-less and character-less housing in the same style. Such developments can be seen throughout the country where you, the planners, have failed to lead. Warwick should lead by allowing private individuals to buy plots of land and build their own houses within planning guidelines. This way we will not suffer from the uniformity of style that we face wherever we go. Look around the district to see what's considered good and what's considered bad - Kenilworth has lost its identity long ago by developments of similar properties that have no connection with the old. The High Street once the centre of the town is now dead! A good street is Northumberland Road with individual houses on a wide tree-lined road. SMALLER INTEGRATED BUILDING BY INDIVIDUALS OR SMALLER DEVELOPERS. CREATE SOMETHING THAT IS GOING TO BE PART OF WARWICK AND NOT AN UNSIGHTLY GHETTO THAT HAS NO CONNECTION WITH THE TOWN.

3. Warwick will get the bulk of the houses. The county town does not have a fire station, a police station, or a decent library. Planners have destroyed much of it over the years by taking part of Priory Park for WCC car parking. You now talk of Park & Ride schemes when these should have been set up years ago for WCC staff. PRESERVE WARWICK AND NOT LET IT GET TOTALLY LOST AS A SUBURB OF LEAMINGTON.

4. And i haven't mentioned the risk of flooding caused by more hard surfaces giving instant run off. Currently drains overflow as they have not been maintained. Nor mentioned the state of the roads - will increased road surfaces mean even worse maintenance and pot holes. Will WDC & WCC staff not report them and the road signs covered in moss that they MUST see as they drive to their free car parks when you require the public to pay.

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Thank you for your email dated 01/06/2012 inviting Warwickshire Wildlife Trusts
comments on the above development plan. The Trust welcomes the opportunity to
participate in the ongoing development of the Warwick District New Local Plan and
would like to submit the following comments and recommendations for your
consideration.
PO4. Site Allocations
Warwickshire Wildlife Trust believes that further information is needed to inform and
justify the preferred housing allocations detailed in the new local plan. We are
concerned that the current evidence base and assessment criteria has not fully taken
account of all ecological constraints and opportunities for each allocation and
therefore cannot identify and isolate those housing options that offer the greatest
benefits for, or least impacts on, the natural environment. We recommend that the
local authority undertakes the following:
Update the evidence base
It is recommended that the Warwick District Habitat Assessment is updated to include
the additional 3 sites that were not initially reviewed under the 2008 assessment.
These sites are the land at Blackdown, Warwick Gates Employment Land and a site
that forms part of the Thickthorn allocation. The habitat assessment should aim to
ensure that up-to-date information on habitats, local sites and protected species
considerations are available for these additional three sites at this stage of the
planning process so that the relative constraints and opportunities of all preferred site
allocations are available to inform decision making. The National Planning Policy
Framework (NPPF) requires planning policies and decision to be based on up-to-date
evidence about the natural environment of the area so that the sustainability appraisal
can 'consider all the likely significant effects on the natural environment'. Therefore,
without comprehensive data for all preferred site allocations, it will be difficult for the
local authority to justify the conclusions of the sustainability appraisal process and
thus the preferred options during examination in public.
The Trust is aware that additional habitat assessment is underway for the land at
Blackdown and the site at Thickthorn; however we also recommend this is extended
to the Warwick Gates Employment land. Whilst we acknowledge that this site has
been previously allocated as an employment site in a previous local plan, we believe
that the site is still a preferred option and therefore needs to be supported by, and
assessed against up-to-date ecological evidence to justify its inclusion in the local
plan.
Clarify the Sustainability Assessment Criteria
The Trust recommends that the Sustainability Appraisal (SA) includes greater
transparency about the criteria used to assess different options and site allocations.
At present, it is not possible to determine how each site allocation was scored against
the 16 sustainability categories, which in turn raises questions as to how these
conclusions were formulated. In particular, we are concerned that for category 6: To
protect and enhance the natural environment of the SA, almost all the site allocations
have scored either a negative or strongly negative scoring, implying one of the
following:
- All site allocations are highly detrimental to the natural environment, in which
case the preferred housing options are collectively not an effective strategy to
deliver sustainable development in the district
- The environmental gains and benefits that new development can bring to a site,
through for example the protection and enhancement of valued ecological
features, green infrastructure delivery or habitat management, have not been
factored into the scoring assessment.
- The current criteria used for the natural environment is not sensitive enough to
differentiate between sites that can, on balance, provide opportunities for the
natural environment and those that can't. This could have occurred for example
by strong weighting towards factors such as the loss of the green belt, which will
always score negatively where development in the green belt is proposed.
The Trust would therefore like to see more information in the SA to justify why the
preferred development strategy has consistently shown negative scores for the
natural environment and how this development strategy can in turn contribute towards
the pursuit of truly sustainable development.
We believe the SA should detail a standardised and objective criteria for which all site
allocations should be assessed. This will give relevant stakeholders the opportunity to
review and comment upon the factors that influence the scoring for each site
allocation; helping to differentiate between the sustainability of different sites and
giving greater weight to the SA process overall. Using this feedback, the local
authority can then be confident that their chosen strategy represents the most
appropriate strategy when compared to all reasonable alternatives.
We believe that any scoring criteria for the natural environment should be inclusive of
both constraints and opportunities. This would ensure a more balanced approach to
scoring the natural environment category as impacts of each site allocations can be
considered in the context of other benefits and wider contributions to ecological
networks and biodiversity targets in the district. This approach is also more consistent
with the NPPF which requires local authorities to plan positively for ecological
networks in order to halt the loss of biodiversity by 2020. Subsequently, when scoring
site allocations for the natural environment, we recommend that the following factors
are taken in to consideration.
- Does the site impact on statutory and non-statutory wildlife sites
- Does the site impact on Local Biodiversity Action Plan (LBAP) habitats and
species and other important ecological features such as river corridors.
- Does the site have potential to impact on populations of protected species?
- Is there an ability to provide ecological mitigation to avoid or reduce long-term
impacts
- Are there opportunities for habitat enhancement, buffering statutory and nonstatutory
sites or introducing a management plan for sites, features or species of
ecological importance
- Are there opportunities to create, link-up or restore biodiversity and green
infrastructure assets across the district?
The Trust recommends that the impact on natural resources and ecosystem services
should also be considered within category 5: to ensure the prudent use of land and
natural resources of the SA. Currently this category is understood to be scored only
on whether or not the site allocation is on greenfield or brownfield land. However, this
does not take into account impacts on soils, air quality, natural resources or
ecosystem services. Nor does it consider what opportunities are available to mitigate
and enhance current natural resources and ecosystem services within site allocations
and how proposals could contribute to national targets and ambitions, such as those
listed in Biodiversity 2020: A Strategy for England's Wildlife and Ecosystem Services
for maintaining healthy and well functioning ecosystems and restoring degraded
ecosystems services. The Trust believes the impact on natural resources and
ecosystem services is a significant consideration in choosing site allocations and if
inadequately assessed could compromise the ability to achieve key objectives in the
plan or even the effectiveness of policy provisions. We subsequently recommend that
the site allocations are reviewed accordingly to account for these points.
Review Conclusions of Sustainability Appraisal
In light of our concerns above, we believe the local authority should review the scores
and conclusions given for category 5 and 6 of the sustainability appraisal. To aid this
process the Trust has briefly summarised a number of factors which we believe
should be considered for each preferred housing allocation. This summary is included
in appendix 1.
PO8. Economy
Warwickshire Wildlife Trust believes that it will be important for the local authority to
explore the case for including the proposed Warwickshire and Coventry Gateway
development area in the local plan. We are broadly supportive of the approach
detailed in paragraph 8.33 of the consultation document to review the impacts of the
proposal and believe this work will be essential if it is to be a justified allocation in the
plan. The Trust also recommends that in reviewing the impacts of the scheme, the
local authority should also take full account of the environmental and social
implications of including the allocation in the preferred options so that the economic
incentives of the scheme can be considered in the context of wider sustainability
objectives for the district. The evidence base for the natural environment will therefore
have to be reviewed and updated in order to inform the sustainability appraisal for this
site and any other reasonable alternatives that come forward as part of this review
process.
When considering the implications of all potential employment sites it will be
necessary to consider both the constraints and opportunities for the natural
environment. Having engaged in discussions about the Gateway proposals so far, the
Trust has identified numerous adverse effects on ecological assets but have noted
that the site also offers opportunities to deliver environmental enhancements in
strategic areas for green infrastructure and biodiversity, such as the River Avon LWS.
We believe the local authority needs to acknowledge and balance these factors so
that the impact on the natural environment on all site options can be more accurately
determined and assessed within the sustainability appraisal. Criteria for assessing the
constraints and opportunities of employment scheme on biodiversity should therefore
refer to the detailed criteria outlined above for housing allocations.
Any policy that favours a potential employment site of regional importance should
ensure that the enabling provisions reflect and are supportive of other themes in the
new local plan. The allocation should therefore embody the principles of sustainable
development by ensuring it contributes to wider economic, environment and social
objectives jointly. This should include improvements to green infrastructure and the
natural environment that are equivalent to the site's strategic importance so that it can
be seen as an exemplar for sustainable design and construction within the plan. In
order to optimise the potential for high quality environmental improvements, the Trust
strongly recommends that the policy wording should seek enhancements in line with
the district's ecological and green infrastructure networks, LBAP objectives for priority
habitats and species and Water Framework Directive objectives.
PO10. The Built Environment
The Trust is broadly supportive of the preferred option for the Built Environment. We
welcome the acknowledgement of the need to protect, enhance and link the natural
environment and would further support policy wording that recognises and promotes
the benefits of incorporating green infrastructure and suitable features for biodiversity
in and around development proposals. We believe that including these provisions,
together with links to other themes within the local plan, will help to underpin the
delivery of the Garden Suburbs prospectus and thus secure the district's ambitions to
promote high quality and sustainable development through the local plan.
PO12. Climate Change
The Trust is supportive of preferred option PO12 and in particular the local authority's
commitment to include a policy that promotes climate change adaptation. We
recommend that in wording this policy, due consideration is given to ensuring
linkages to delivering green infrastructure, protecting and enhancing biodiversity and
ecological networks and supporting objectives for mitigating and enhancing flooding
and water quality as these will all support and provide a context for delivering climate
change adaptations through new development proposals.
PO15. Green Infrastructure
Warwickshire Wildlife Trust welcomes the local authority's commitment to protect,
enhance and restore the district's strategic green infrastructure (GI) network. We
believe that the supplementary work to identify the network and the subsequent GI
projects that have informed the infrastructure delivery plan, provide a strong context
for securing mitigation and/or contributions towards GI enhancement within the new
local plan. Acknowledging the linkages with other themes such as Flooding and
Water, Climate Change and the Built Environment, GI should be considered an
integral part of good design and so we recommend that this is reflected in the wording
of an overarching green infrastructure policy. This has already been reflected in part
under the 'Development Proposals' paragraph in PO15 which would in turn create an
excellent starting point for the policy wording.
The Trust is pleased to note Warwick District's intention to adopt the sub-regional
green infrastructure SPD. This provides an excellent opportunity to secure strategic
improvements to priority ecological networks throughout Warwickshire, Coventry and
Solihull which will in turn strengthen and compliment existing district wide and local
networks. Maintaining the reference to each level of the strategic green infrastructure
network will ensure that contributions to achieve these aims can be secured; thus
demonstrating the district's commitment to planning positively for networks of green
infrastructure. However it may be necessary to clarify how and when improvements to
the different networks will be sought and the mechanism that will be used to balanced
how these contributions are distributed between the local, district and sub-regional
networks accordingly.
Our concern with the preferred option so far is the coupling of a green infrastructure
policy with the protection and enhancement of biodiversity. Whilst we agree that sites,
features and corridors of wildlife importance do form an integral part of local, strategic
and sub-regional GI networks, we believe that a GI policy cannot deliver the robust
and objective protection for biodiversity assets that could normally be set out within a
specific biodiversity policy. The NPPF set outs a good criteria based approach for
protecting statutory and non-statutory sites. It requires policies to differentiate
between sites of national and local importance so that their protection is
commensurate with their status and the contribution they make to wider ecological
networks. For local sites this criteria based protection is essential as it clearly defines
the level for which it remains robust when challenged by development interests.
Conversely, the multifunctional nature of GI makes it difficult to specify a criteria
based approach for its individual components and so blanket protection must be
applied to safeguard all assets. Whilst in principle, absolute protection is an ideal; the
Trust recognises this is likely to be less effective as it makes it much more vulnerable
to challenges from development interests. Subsequently, whilst maintenance and
enhancement of ecological networks should still be pursued through a green
infrastructure policy, we believe that a specific biodiversity policy is also needed to
ensure a sufficient level of protection for sites, features and habitats of biodiversity
importance. Our policy recommendations for biodiversity are discussed below.
POXX. Biodiversity
Warwickshire Wildlife Trust strongly recommends that the preferred option includes a
policy to specifically outlining the protection of the district's biodiversity assets.
Referring to our comments above, we do not believe that a green infrastructure policy
in isolation can provide an adequate level of protection for individual biodiversity
assets within the district. A biodiversity policy, founded on the criteria based approach
detailed in the NPPF, is considered to be a more effective approach as it:
- ensures that protection is commensurate with the site or feature's status and
contribution towards wider ecological networks,
- provides greater clarity as to how impacts on biodiversity assets will be judged
therefore proving to be more robust when challenged; and
- can specifically promote the preservation, restoration and re-creation of priority
habitats, ecological networks and the protection and recovery of priority species
populations in line with national and local targets.
Ensuring robust protection for biodiversity assets should be considered as a priority
when planning positively for ecological networks. Statutory and non-statutory sites,
particularly Local Sites, provide the fundamental building blocks for establishing
ecological networks. With these sites only constituting approximately 3% of the entire
district area, it will be essential that these core features are effectively secured.
However, important biodiversity assets are not simply confined to these areas and so
it will be necessary to ensure that the policy outlines a degree of protection for other
important biodiversity features that do not benefit from a statutory or non-statutory
designation, such as wildlife corridors, LBAP habitats and species and linear features
such as hedgerows and watercourses.
The Trust therefore believes that the strong protection of statutory and non-statutory
sites and other features of ecological importance should form an integral part of a
biodiversity policy within the local plan. In order for this policy to be effective, we
support the criteria based policy approach detailed in the NPPF as this clearly
outlines the relative weight given to each site, feature and habitat so that protection is
commensurate with its status and the to the contribution it makes to wider ecological
networks. However, as the criteria must differentiate between national and local
designations we believe that the policy should include separate policy clauses for
sites of International importance (SAC, SPA, Ramsar), national importance (SSSI),
county importance (LWS, LNR) and features of district/county importance (LBAP
habitats and species, wildlife corridors).
Where impacts on features of nature conservation importance are identified, it will be
necessary to outline how impacts can be resolved to prevent a net loss of
biodiversity. Paragraph 118 of the NPPF provides a useful hierarchy of how impacts
should be dealt with in this instance. It requires that all adverse impacts on
biodiversity should be avoided first, then if impacts cannot be avoided, and the
reasons for the development demonstratably outweigh the nature conservation
importance of the site or feature, mitigation should be secured. Compensation should
only be sought as a last resort. The Trust would advise that this categorical approach
to dealing with biodiversity impacts is adopted into a biodiversity policy for the local
plan. We also believe that a reference to Biodiversity offsetting should be included at
this stage of the policy (As opposed to including it in the green infrastructure policy)
so that if compensation is sought for a development, then the district can demonstrate
that it has an objective mechanism for ensuring that the proposal will not result in a
biodiversity loss. References to the sub-regional and district GI strategies, together
with the proposals for a Nature Improvement Area or the results of any Biodiversity
Opportunity Mapping, should be included here to outline how the biodiversity
offsetting process contributes towards delivering strategic gains for biodiversity.
However, biodiversity offsetting is a means to quantifying biodiversity impacts that
cannot addressed on site and so it should be clearly outlined that this process is a
last resort where adverse impacts cannot be avoided or mitigation for on site.
The Natural Environment White Paper has outlined that the UK needs more, bigger,
better and joined places for nature to reverse the continual loss and decline of
biodiversity and essential ecosystem services. This policy should therefore form the
basis for securing biodiversity gains through the planning system in order to
contribute towards the Government's ambitious target of halting the loss of
biodiversity by 2020. To transpose these targets and policies in to the District's local
plan, it will be necessary for the biodiversity policy to also include some provision for
enhancing biodiversity as well as protecting it. This could be achieved, for example,
by promoting habitat creation, restoration, re-creation and/ or management of existing
features within all new development proposals. Whilst a green infrastructure policy
goes some way towards this provision, it is non-specific to biodiversity and cannot
guarantee that improvements to the network deliver these crucial gains for
biodiversity. The Trust believes a policy clause could be included in the biodiversity
policy as means to securing these aims.
Warwickshire Wildlife Trust would welcome the opportunity to input into, or comment
on, any policy wording that is developed for a specific biodiversity policy in the new
local plan.
PO17 Tourism and Culture
The Trust believes that policies that support sustainable tourism should be
encouraged providing that they truly reflect the principles of sustainable development.
New sustainable tourism developments should therefore be able to detail how they
safeguard and contribute towards the enhancement of biodiversity assets, the water
environment and green infrastructure whilst demonstrating high quality and
sustainable design and construction throughout. The Trust would subsequently
welcome a clause within a sustainable tourism policy linking it to wider themes within
the local plan to clearly define what 'sustainable' tourism should be expected to
achieve.
PO18. Flooding and Water
The Trust are broadly supportive of the preferred option for flooding and the water
environment; however we believe that PO18 is lacking in detailed provisions for
safeguarding and enhancing water quality and optimising opportunities to reduce
flood risk by linking with themes such as green infrastructure, biodiversity and the
built development.
The need for stronger controls on protecting and enhancing water quality is outlined
in paragraphs 18.12 - 18.14 of the consultation document. It details that only 11% of
water bodies in the district are at 'Good' ecological status and so the district must
employ an ambitious approach to tackling water quality issues within the local plan if it
is to achieve the objectives of the Water Framework Directive by 2015. Development
can contribute to towards improving water quality though a number of means such as
SUDS, buffering watercourses and reconnecting them with their floodplains, creating
new wetland habitats and retrofitting measures that assist with attenuating and
filtering surface water before it is discharged into water bodies. The Trust therefore
recommends that such measures are strongly promoted in all new developments so
that provisions to safeguard water quality are also pursued in tandem with
opportunities to mitigate and enhance them. Policy wording that would support this
approach would be strongly welcomed by the Trust
The Trust recognises and supports the district's commitments for preventing new
development within flood risk zones in order to reduce future flood risk issues.
However, we believe that this approach should be the minimum requirement for
reducing flood risk as there is also a need to mitigate against existing flood risks and
adapt to the to changes in river levels that are likely to occur as a result of climate
change. The Local Authority should therefore be planning positively for addressing
flood risk, promoting opportunities not only to incorporate SUDS but to reconnect
rivers with their natural flood plains and support the creation of new wetland and
riparian habitats thoughout the district. The Trust acknowledges and welcomes the
district's strategic green infrastructure proposals adjacent to the River Leam which will
ensure that contributions for new development can be strategically placed; however
these principles should be embodied into policy wording so that wider opportunities to
reduce flood risk can be pursued. Where possible, opportunities to reduce and adapt
to food risk should be included in the scoring criteria in the SA for flooding as well as
determining whether or not the allocations is within the flood plain.
I hope these comments are useful to you as you progress the development plan
through to the next stages. Please do not hesitate to contact me if you seek further
clarification on any of the above points.
Yours sincerely
Richard Wheat
Planning and Biodiversity Officer
Warwickshire Wildlife Trust
Appendix 1: Summary of factors that should be considered when scoring site
allocations against Category 6 in the Sustainability Appraisal
Site Name Summary of ecological comments for the scoring
criteria described above
Woodside Farm
(South of Whitnash)
The small section of broad-leaf woodland and the mature
hedgerows and trees are the key features of this site. However
there are opportunities to retain these features and enhance
them through buffering or new habitat creation which should be
reflected in the score for this site.
Whitnash East
(South of Sydenham)
Whitnash brook, which forms the eastern boundary of the site, is
an important watercourse and wildlife corridor that supports a
good variety of semi-natural habitats and connects to the
adjacent Local Nature Reserve in the north. The development
area also supports hedgerows which connect the feature to the
Railway cutting to the east which is a pLWS. The presence of
protected species will also need to be considered and so overall
this site could score unfavourably on these grounds. Scoring
should take into account that impacts on the brook could be
avoided and mitigated through a substantial buffer and the
hedgerows could be retained to maintain connectivity to the
adjacent pLWS. There is also an opportunity to extend the
existing LNR boundary south along the eastern boundary of the
site by buffering the brook and delivering further habitat
enhancement, creation and restoration on site.
Fieldgate Lane
(Whitnash)
Species rich hedgerows and the adjacent railway pLWS are the
key ecological features for this site. The grassland habitat that
constitutes much of the site contains ridge and furrow, but is
species poor and offers opportunities for enhancement. The site
offers excellent potential to buffer the railway pLWS and retain
the hedgerows which are confined to the site boundaries. It also
provides opportunities for habitat restoration and creation on
site.
South of Gallows Hill/
West of Europa Way
The linear belt of habitats following the Tach Brook is an
important and sensitive feature of the site. Some of these
habitats also form part of Nursery Wood pLWS and connect well
with New Waters LWS and so the site should score
unfavourably on these grounds. Numerous hedgerows and trees
are also present throughout the site, providing opportunities for
protected species such as otter. This will need to be reflected in
the scoring for this site. The Tach brook corridor with associated
semi-natural habitats could and should be substantially buffered
and maintained in order to retain this important connective route
throughout the site. Buffering along the Nursery wood pLWS
boundary to the west could also be achieved as part of any
landscaping proposals to maintain linkages. Hedgerows and
mature trees could also be retained although there is likely to be
some loss to provide access across the site. The site offers
good potential to deliver habitat creation, restoration and
enhancement particularly around the Tach brook area and
improve connectivity to surrounding sites, features and habitats.
Myton Garden Suburb
(North of Gallows Hill)
The presence of a biodiverse watercourse, veteran trees,
mature hedgerows, ridge and furrow grassland and a good
likelihood of protected species are likely to score this site
unfavourably. However, there are opportunities to retain
important hedgerows and trees and buffer and enhance the
watercourse as well delivering new habitat creation or
restoration on site. The watercourse could provide linkages to a
strategic wildlife corridor in the form of the River Leam
Loes Farm
(North of Woodloes)
The Veteran Oaks, watercourse and old semi improved
grassland with yellow meadow ants are important and unique
ecological features that according to the WDC Habitat
Assessment are a significant constraint to the development at
this site. As much of the site constitutes the old meadow it would
be impossible to deliver even small amounts of development
without adversely affecting these key features and so the site
should score unfavourably on these grounds. If impacts can be
minimised, there may be opportunities to enhance the
watercourse and the plantation woodland on site and improve
the current botanical diversity of the grassland
Red House Farm
(East of Lillington)
The Hedgerows are perhaps the key feature of the site, together
with the opportunities they provide for protected species.
However there are opportunities to retain the hedgerows as well
as potential to deliver habitat creation and restoration throughout
the site.
Land North of Milverton The brook corridor which is a tributary of the River Avon LWS,
the area of semi-improved grassland to the southeast and the
species-rich mature hedgerows and trees are all key features for
the site. The layout of the hedgerows would likely make it
difficult to retain the vast majority of these features and so
should be scored unfavourably on these grounds. Removal of
these features and the any associated mature trees would also
likely disrupt habitat opportunities for protected and noteworthy
species such as farmland birds and bats. Otters may also be a
consideration. There are opportunities to maintain and buffer the
brook corridor in the northeast of the site enhancing linkages to
the River Avon which is a strategic green infrastructure asset.
There are also opportunities for new habitat creation, restoration
and enhancement throughout the site.
Thickthorn (Inc Land
north of Thickthorn)
The section of Thickthorn wood LWS within the site boundary,
the adjacent Glasshouse Spinney LWS, the mature hedgerows
and trees and an area of semi-improved grassland are all likely
to be constraints to development at this site. There are
opportunities to retain and buffer these key ecological features
but there is a risk that infill development in this area will further
isolate or restrict connectivity to and between these features.
Scoring should reflect this cumulative impact. Opportunities for
new habitat creation could help reduce these impacts by linking
up the woodlands as well as contributing towards wider
enhancements to the Arden Landscape area.
More information is needed about the habitats north of
Glasshouse Spinney to provide a more comprehensive
summary for this site.
Land at Blackdown Up-to-date ecological data required
Warwick Gates
Employment Land
Up-to-date ecological data required

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2:2 - Why is the environment not listed as a key priority: without it, all manner of planning applications can be granted which are anti-environmental

Is leisure included in "Health and Wellbeing". If so, this should be made clear.

2:5 - As there is no way the economy can be predicted, there should be a commitment to responding to new opportunities and needs which arise

Can the areas mentioned as requiring regeneration be identified?

I am concerned about the second bullet point under Emphasis on infrastructure, as most areas of the countryside and of importance for wildlife need only a very light touch, if a touch at all. There should be a clear distinction between the approach to parks and managed open spaces, and to wilder areas (e.g. Welch's Meadow would be ruined by heavy handed management).

3:7 - there are elements referred to in this draft plan which need to be prioritised and policy made before March/April 2012; in particular a policy on the concentration of HMOs.

4:6 - the protection afforded to conservation areas should be strengthened, particularly as these cover apparently only 4% of the district

4:8, point 2 - It should be noted that one major contributory factor to the current lack of affordable properties relates to HMOs. The house next door to mine is an example of this. It was owned by an elderly lady who went into residential care. There was a large amount of interest in the property from people who wanted it as a family home, indeed so much interest that it was decided on sealed bids. Because the property needed some updating, and I met several potential purchasers who wanted to restore it to its former self, the highest bidder was, almost inevitably, a landlord who could easily find the finance and would easily recoup the investment by turning it into an HMO. I have seen this repeated time and again in my area of south Leamington where the gains from HMOs has pushed up prices beyond affordable for an individual or family: indeed a local couple I know has not been able to find an affordable small period house and, despite wanting to stay in Leamington, is having to move to Cheltenham to find such a property. In addition to the price problem, most often the conversion to HMO is the cheapest possible and degrades the period property.

4:10.2 - It is right to accommodate university students, but not at the expense of other "settled" residents. South Leamington is at a tipping point where the area could be completely dominated by students The advantages of a large student population tend to benefit the few - landlords and places selling cheap food and drink, whilst the cost and disadvantages are picked up by Council tax payers and local neighbours. It also means that businesses not directed at students tend to stay away. One south town resident recently pointed out that because Leamington is only a student dormitory town rather than a university town, we have generally ended up with all of the problems of a large student population and none of the advantages of the university culture which takes place on campus. I can see no reason why special consideration should be afforded to the University of Warwick in providing accommodation for its students.

4:11 - I agree with all these points, particularly endorsing numbers 7, 9 and 10. It is particularly important in any development not to let the developer be the tail which wags the dog, as the developer will inevitably want to take the easiest and cheapest route in contradiction to the area's best interests.

5-7 - Level of growth:
As forecasting population growth is a very inexact science, the Council should constantly monitor what is actually happening. If the expected population growth is not materialising, planned development should be scaled back accordingly. It makes sense therefore to insist on development of the brownfield sites before eating into Green Belt.

P04:D - Loss of green space should also be taken into account when assessing development of garden land. This space may not be directly accessible to the general public, but if it contributes to the overall feeling of green space which is enjoyed by the general public (e.g. with trees that can be seen from neighbouring streets), it is very important that it is maintained. It is also important for biodiversity and the environment, as gardens are now understood to be extremely important habitats for wildlife.

P06.D - It is most important to identify the locational criteria and to carry out a thorough survey of all HMOs and their residents, not just those which have previously had to get Council approval.

7.59 - We need this policy now!

P08 - We also need a firm policy now regarding the protection of existing employment buildings from change of use, as in my area I can think of several schemes either applyng for or already granted planning permission to change from commercial to residential use. The Plan already points out that f the area population is going to increase, then employment will need to increase as well and it is short-sighted to be allowing commercial property to disappear.

8:21 - Does the projection of additional job requirement take into account that the growth in the older population will automatically mean the release of the jobs these people were doing?

9: Retailing

It is a mistake to be led by the retail "experts" who push for constant retail development schemes in order to compete with neighbouring towns. There is a fine balance between having enough "High Street names" to serve shoppers and having so many that Leamington becomes indistinguishable from any other shopping centre - in which case, why would any non-residents want to come here? The success of the last major retail development - which seems dubious to me - (Parade to Regent Street) should be assessed before rushing into another similar development. Outside shoppers will travel to a shopping centre to find something different and it is this difference which needs to be identified and promoted. These major developments also seem to push up rents for retailers.

13: Inclusive, Safe and Healthy Communities

Developments should not be permitted which will downgrade and produce associated problems to an area, e.g. SEVs.

14: Transport

I suggest WDC promote a car sharing scheme.

P014: How can you plan a retail development in Chandos Street whilst aiming to maintain sufficient parking in town centres. Chandos Street is a much more popular car park than the multi-storeys.

15: Green Infrastructure

A relevant issue is that Network Rail is destroying, and has been for a long time, the natural environment and wildlife habitat along railway lines by felling all the trees and killing undergrowth every year with weed killer.

15:14 - Yes to urban tree planting; concern about messing with the River Leam borders unless already in a well-used managed area.

P017 - I agree with the continued support for the development of a cultural quarter

I believe that existing visitor accommodation should be protected from change of use.

18: Flooding

Planning permission should be sought by someone wanting to pave/concrete over a front garden, as I believe this trend has contributed to flooding problems.

Summary of major concerns

* Restrictions needed on HMOs
* Light-handed touch needed on non-parkland open spaces and riverside
* More creative study of retail demands and opportunities needed
* Although the Plan does seem to recognise this, the expansion of the district must avoid segregating areas into a single use, e.g. residential, employment, etc. Areas are much more interesting and attractive if they include a mix of residential, employment, cultural/leisure, etc. properties.

The County Council, under the Localism Act 2012, has a "duty to co-operate". The duty to co-operate requires councils to 'engage constructively, actively and on an on-going basis' on issues relevant to statutory plans. Therefore, we will assist in the plan making process and infrastructure planning on an on-going basis.

We welcome the vision and direction of the local plan to create sustainable communities and a quality environment for all those who live and work in the District.

As well as our statutory duties our view is also set out in the context of the County Council's vision contained in the "Going for Growth" paper approved in April 2012. The purpose of this paper was to identify how the County will embrace the coalition government's twin primary aims of reducing deficit and securing growth in this challenging period of public sector austerity. The "Going for Growth" paper sets out how we will assist in stimulating and influencing the business and economic environment (with the necessary educational, skill development and community ambitions) to deliver 'growth' for Warwickshire.

In respect of indicating support for any particular development Option: our view is that there should be a right balance of sites that support growth. Therefore, it is a matter for the District Council, to satisfy itself and strike the right balance, in respect of deliverability, viability and sustainability and supporting infrastructure required to deliver each option.

The planning issues and policies contained in the "Preferred Options of the Local Plan" will impact at differing levels on the County council's corporate responsibilities, particularly economic, transport, support for the elderly and extra care housing, library services public health, gypsies and travellers and education. The Director of Public Health has already responded directly to you on the consultation and evidence.

The key values contained in the "Going for Growth" paper are stated below in emboldened text and their implications for planning and landuse policy is explained in the embolden text below:

* Our social investment will contribute to a county where the will compare well to other British communities.

We will look for planning policies that support technological Infrastructure and in particular in rural areas. We will support the strategic employment sites of the strategy.

* With a sense of mutual ownership of public services (the Warwickshire Shareholder).

We will support positive planning policies that embed co-location of services with the voluntary sector, private sector providers and other public bodies.

* We will achieve a discernible reduction in inequalities in social, economic, health and well-being regardless of age disability or culture.

This applies to access to goods and services for local residents including adequate provision for gypsies and travellers.

Planning policies on extra housing and affordable is provided with the necessary long term supporting services. We will support proposals and policies for co-location of services.

* A vibrant economy will produce high quality job offers in Warwickshire, raising the skill levels in the overall workforce so that we are as productive and competitive as the best in the Country.
* Warwickshire will be a place which looks actively at the best practice from other places - international as well as national - to develop innovative and entrepreneurial solutions. Our economic well-being will be measured by international comparison not simply against "West Midlands" regional standards. Our urban town centres will punch above their weight when compared with similar sized English town centres and our rural infrastructure will be amongst the best in the Country.

We will support planning policies that support a competitive economy for inward investment.

Warwick and Stratford upon Avon are international destinations and make a significant contribution to the economy of the region and sub region.

Therefore, we will support planning policies that support and sustain the key town centres.

* Our growth plan will attract people to live and work in Warwickshire as a specific choice. There will be a strong brand image, underpinned by a recognition that this as one of the best places in the Country to live and work.

Our strategic policies contained in the Local Transport Plan and Growth strategies support the improvement and the provision of strategic infrastructure such as junction improvements to strategic highway network and provision of new railways stations.

* There will be a strong Health and Well-being ethos about the quality of lifestyle we are encouraging.....where the brand "Warwickshire" will be directly associated with a health-focussed lifestyle supported by the health infrastructure to match.

The National Planning Framework requires Local Plans to include policies for health and well-being. The County Council is also responsible for Public Health and we would seek overarching planning policies in the Local Plan that support health and well-being as part of new developments in the District.

We are committed to delivering the best possible health and wellbeing outcomes for everyone, helping people to live Warwickshire.

Planning for health is important not only from a legislative perspective, but
also in relation to costs. Promoting healthy lifestyles, avoiding health impacts
and tackling health inequalities throughout the planning process could result
in major cost savings to society. There is significant evidence on the effect that spatial planning has on community health and well-being and spatial planning policies can address local health inequalities and social exclusion. Some local authorities have adopted planning policies to promote the health and well-being of residents through development management. The Local Plan can contribute to health and well-being in the following way:-

* The quality and opportunities of the local environment is a contributory factor in shaping health.
* Transport and traffic, access to public transport, lack of open space and where we shop for food are just a few examples of how the built environment influences our physical and mental health.
* Planning can positively affect the health of residents by shaping and influencing the layout and the open spaces in between developments and securing investment for the public realm.
* For example, planning policies can include; design requirements for housing layouts to encourage safe and pleasant walking short distances to amenities and services.
Developer obligations can be used to build infrastructure such as healthcare facilities, parks or cycling routes. There should be an overarching policy that promotes health and welling for communities in the District area. Spatial planning policies can promote and provide opportunities for healthier lifestyles.

It is against the above background that the comments are made to the specific questions. This letter contains an amalgamated response from various services. Whilst we have endeavoured to bring together as many responses as possible to assist you in the development of your Core Strategy, please be aware that there may be other services that may have comments to make at subsequent consultation periods as the process moves forward.

We wish to make detail comments on the Infrastructure Delivery Plan by mid-September. However, our general comments are set out below:

Comments in relation to adult social care and specialists housing needs.

Preferred Option 6 (PO6) Mixed Communities & Wide Choice of Homes

Para 7.5.3.
C. Homes for Older People should also include homes that include the needs of local older people, adults and children with disabilities and other local vulnerable people who need care and support. Therefore, this policy should include provision for; extra care housing and supported living accommodation suitable for adults/children with disabilities.

Para 7.5.8.
The Local Plan should provide clarity on the difference Use class C2 and C3 Usage Class. All too often we are seeing the C2 Usage Class applied to individual dwellings, which seem to become institutional if they are providing independent living solutions to vulnerable adults, e.g. McCarthy Stone development in Southbank Road, Kenilworth.

Extra care housing and use class C2 and C3

There is currently some uncertainty about the precise the definition of the different care market sub sectors, including that of 'Extra Care'. Extra Care may be defined as a scheme where occupiers have their own self-contained apartment or living space(s), and generally do not wish to live entirely by themselves without access to care, but do not require either, constant care. Such occupants would have the option of purchasing, as their needs require or are determined varying degrees of domiciliary care.
In terms of which use class order Extra Care falls within, its widely recognised definition, particularly regarding the varying degrees of care provided to residents, has led to debate over whether it comes under C2 Residential Institution or C3 Dwelling Houses.

The issue here is that care homes and extra care housing - both offer long term care solutions - but the preferred model (and this is the view of older people) is independent living (use class C3) with access to 24/7 care rather than admission to residential care (use classC2). We are seeing the market over providing ie residential care homes delivered ahead of extra care housing. If the number of residential care beds introduced to the market hits the predicted number of overall required care places (extra care housing and residential care), planners are likely to argue that there is little need for extra care if the residential care market has already delivered the required/reported numbers

Housing polices within the Local Plan should, therefore, clearly set the distinction between the class uses and also address how those needs will be met.

Demand for Extra Care housing
Based on the 2001 census Warwick District Council will need to provide 1197 units of extra care housing of which 299 should be "social rented" extra care housing. The latter figure should be form about 10-15% of the affordable housing numbers for the District.

Draft Infrastructure Plan
4.4.1.
The first sentence could be re-written to read as "Adult Social Services are mainly concerned with adults and older people with physical and/or learning disabilities and/or mental health problems"

4.4.4.
The last sentence should read as "Residential care accommodation is..."

4.4.5.
May be better to refer to "older people and adults" rather than "...elderly and non-elderly people..."

4.4.6.
This needs to reflect the current 50/50 service model promoted by the County Council, i.e. a model where 50% of people who would normally go into residential care are diverted into extra care housing.

4.4.13.
The suggestion that "Housing accommodation...for people with learning or physical disabilities will be met as the need arises" needs to be clearer.

At present only a limited number of people with learning disabilities are afforded the opportunity to live independent and meaningful lives with choice and control over where and who they live with. Instead, many have their lives constrained by having to live in residential care where individual outcomes do not generally improve. With approx. 300 people with learning disabilities currently living in residential care in Warwickshire, the overall programme intention is to deliver no less than 200, 1 and 2-bedroomed apartments that are suitable for adults with learning disabilities, including an initial short term target of an average of 25 apartments per annum between 2011 and 2015 in line with the County Council's Transformation agenda.

There are about 227 people with learning disabilities in the Warwick District, some are living in extra care accommodation and the others with their main carer (this could be parents or partner). Some residents are living in "hard to let" properties and can be victims of abuse and hate crime. These specialists accommodation would provide suitable and safe accommodation for these vulnerable residents.

General comments:
The District Council needs to include both anecdotal and specific needs analyses from a range of partners, such as local GPs, CCG, NHS Warwickshire and WCC. All these partners directly support and commission services for vulnerable people with a range of health and social care requirements, and these factors need to be considered when looking at overall housing provision.

Development Management and the consideration of planning applications for Care homes.

It is the joint view of the South Warwickshire Clinical Commissioning Group and the County Council as the Public Health and Adult social care providers that the District Council should consider bringing forward a Supplementary Planning Documents ( SPD) to secure the proper distribution of housing and the implications the potential residents have for supporting care and clinical services.

We are therefore request that a moratorium on C2 applications placed. We also recommend that there should be an introduction of a two-stage process to assess planning application on behalf, i.e. a preliminary panel at Pre-Application stage. This could be made up of WDC, WCC, CCG (inc. local GPs) and NHS to consider any specialised accommodation, particularly as the District continues to attract interest from private developers who are seeking to provide specialised accommodation clearly geared to attracting the private pound and/or an imported population. This has implications for both Health and Social Care as follows:

1. NHS Continuing Health Care budgets are being used to fund services for an imported population rather than local residents. These new (and expensive) care homes or housing developments provide an attractive solution to meeting the needs of the private funder, however, we are still seeing those who cannot afford these prices being moved away from their local communities to where services are available. There will also be a drain on local GP and Nursing resources as these new and sizeable care homes come on stream.
2. Extra Care Housing delivery is complex and continues to struggle when reaching planning and enabling stages as it becomes embroiled in local policies. Therefore there should be planning policy guidance to create the proper balance of C2 and C3 housing for the District.

Subject to the input from the "specialist care and clinical services" panel, a development proposal could then progress to formal application for planning consent.

Heritage and Culture matters

We support the District Councils Local Plan direction in safeguarding and enjoyment of our natural and historic environment together with the district's rich heritage and visitor economy. Our specific comments are:-

Section 4, we would welcome specific reference to the interdependency between the district's tourist offer and the safeguarding of its natural and historic environment, and the provision of heritage and cultural activities and venues.

Section 7, we welcome reference to the need to maintain and develop the heritage and cultural infrastructure to support the needs of new residents and to support new communities in developing a sense of identity and social cohesion.

Section 10 tourism and the quality of the built and natural environment are linked, therefore, the contribution of the high quality of the environment should be specifically stated in any policy to maintain the role of towns as visitor destinations.

Section 17, we feel that the introductory list of cultural venues should include museums and archives. The paragraph on "Seeking contributions" should include heritage and cultural facilities; as communities grow, the cultural infrastructure and activities programme needs the opportunity and financial framework to grow accordingly.

Archaeology
We welcome the acknowledgement given to the importance of the District's historic environment in para. 11.1. However, archaeology and the historic environment in some cases should be joined up.

The document refers to the 'built and natural environment', (e.g. para. 4.11.7, 4.12.14, 10.4, 10.6, 11.2). 'historic areas' or the protection of 'historic assets', these terms appear to be used interchangeably. We recommend that the references to 'built and natural environment' throughout the document be re-worded to reflect that the historic environment is made up of a wide range of different types of heritage assets (including archaeological features, historic landscapes etc), rather than just historic structures.

Para. 11.1 describes the historic environment in terms of statutory protected, designated sites, such as Listed Buildings, Scheduled Monuments etc, and locally important historic assets. There are also a number of archaeological sites across the District that are of national or regional significance but may be undesignated and the local plan should also recognise this
There are also several instances where references to the protection of historic structures (such as the references in PO11 to the submission of nationally important historic assets for listing, and the bringing back of Listed buildings into use), could be expanded to take into account other, non-built, heritage assets. For example, PO11 could be expanded to include the putting forward of nationally important archaeological sites for protection as Scheduled Monuments, not just historic structures for listing.

Further clarification is needed in PO11 by "support the understanding of the significance of Heritage Assets, by: There should be provision for appropriate research for all applications relating to the historic environment".

Further clarification is needed about the reference to the Planning Authority undertaking research for all applications relating to the historic environment, or reference to requiring any planning applications relating to the historic environment to be accompanied by an appropriate assessment of the likely impact that the proposal will have upon the historic environment, as per para. 128, of the National Planning Policy Framework (NPPF). We recommend the re-wording of this section of the document and assistance from the County's specialists can be provided.

Further clarification is needed about the term 'locally designated historic assets' in PO11. It is not clear whether this is referring solely to designated historic assets such as those included on 'Local Lists', or whether this is also referring to historic assets recorded on the Warwickshire Historic Environment Record (HER). We would recommend that reference is made to appropriately considering (and protecting if appropriate) all heritage assets as part of the planning process, whether designated or not, and that reference also be made to heritage assets recorded on the Warwickshire HER. We would also recommend that this policy acknowledge that there may be as yet unidentified heritage assets across the District which may be worthy of conservation, and which may also require protecting during the planning process.

The terms 'heritage assets' and 'historic assets' are used interchangeably throughout the document. We would recommend that the term 'heritage assets' be used in preference to 'historic assets' as this is the term used throughout the NPPF and other policy documents.

We support the reference in PO11 to the use of Article 4 directions to help protect the historic environment.

PO11 proposes protecting the historic through the submission of nationally important historic assets for listing. Not all heritage assets of national importance are listable, some may be better protected by being statutorily protected as Scheduled Monuments or included on the English Heritage 'Register of Historic Parks and Gardens of special historic interest in England'. This policy should reflect this.

We also suggest that indirect impacts of development on heritage assets should also be added to any criteria based policy, for example, the impact that a proposed development may have upon the setting of a heritage asset which may be outside of the planning application site. Whilst there is reference to setting in para. 11.9, this is only referring to the setting of Conservation Areas.

Chapter 11, Para. 11.6 should read 'putting them to viable uses consistent with their conservation'

We also note the intention to draw up Local Lists of heritage assets (PO11); There should be clear methodology for identification of appropriate sites on the basis of our Historic Environment Records data. There should be acknowledgement throughout the Local Plan that open space can support conservation of the historic environment as well as the natural environment.

The list of areas of historic or environmental importance in the District should include reference to "41 Scheduled Monuments". We would also recommend that reference be made to the significant number of undesignated heritage assets within the District which are recorded on the Warwickshire Historic Environment Record.

We welcome that Chapter 15: Green Infrastructure makes reference to the Warwickshire Historic Environment Record (including the Historic Landscape Characterisation and Historic Farmsteads studies) (para. 15.21), however, it is disappointing that no reference is made to these within chapter 11, which specifically deals with the Historic Environment. It should be noted that whilst para. 15.21 states that the District Council has the Historic Environment Record

Proposed development sites
The Strategic Housing Land Availability Assessment (which has informed the choice of preferred development sites included in the proposed Local Plan) should also assessed the impact that the proposed development of these sites could have upon the historic environment.

Whilst the assessment has identified statutorily protected sites on and within the vicinity of the potential development sites, however these have not considered a number of known un-designated heritage assets which the Council may also wish to consider. . These undesignated, heritage assets are of national significance and worthy of conservation. The assessment should also consider the historic landscape character of these areas.

In addition, as noted in our previous responses to the earlier Options paper of July 2008 and the 2009 "Proposed Submission Core Strategy" consultation, there will also be archaeological sites as yet undiscovered which will not be recorded on the HER, and even in areas where no archaeology has been recorded, evaluation may be required to confirm the presence/absence of remains. Consultation on a site by site basis will remain the best means of identifying archaeologically sensitive areas on the basis of current knowledge, as well as areas where archaeological potential will need to be assessed through more detailed work.

Since the individual allocations will need to take account of the impact upon historic environment we recommend that further work be undertaken to identify the issues in respect of the historic environment.

The selection criteria for the major development sites should also include for a thorough consideration of Historic Environment, and proper appraisal is undertaken and allowance made where necessary for preservation of sites of national Importance (in the sense of the 1979 Ancient Monuments and Archaeological Areas Act and the National Planning Policy Framework). We perhaps need a separate meetings to work on a systematic assessment of potential sites being put forward.

Tourism policy - general comments
We support the tourism policy of the Local Plan. Tourism is a significant sector of the overall economy within Warwick District and is recognised as a strategic priority within WDC's emerging Economic Development and Regeneration Strategy, it is recommended that Local Plan polices. Therefore, the District Council should also consider to referencing tourism as part of policy no P0 8 Economy and vica versa.

PO 8 Economy
We support the preparation of the Economic Development and Regeneration Strategy to provide a clear direction for growing and sustaining the economic position of the District Council area.

PO 17 Culture & Tourism
Rural broadband policies and policies for Culture and tourism should be cross referenced to promote the quality of the offer in the District.

It is therefore recommended that an introductory statement along the lines of Weston-Super-Mare might be more suitable:

"The Council will work with partners to support the development and retention of new and existing tourism facilities, for both business and leisure markets and promote their sustainable expansion across the District, whilst maximising their co-locational and cumulative benefits to:

* assist in regenerating our town centres by supporting growth of their retail, evening and night time economies by offering facilities and functions that could encourage spending within the wider areas;
* assist with development of green infrastructure corridors linking destinations and attractions for the benefit of both residents and visitors;
* improve the range, quality and distinctiveness of the District's tourism destination;
* provide high quality hotels and serviced and non-serviced accommodation formats and conferencing facilities;
promote the image and reputation of the District to attract visitors and secure investment."
Town centre tourist accommodation
We support the "town centre first" sequential approach for the further hotel accommodation. To support this and as an alternative, it is recommended that the Council consider the following policy wording:

Within the existing urban settlements of Warwick, Kenilworth and Leamington Spa, proposals that would result in the change of use hotels and tourist accommodation will be permitted unless:
* the proposed use or uses would reduce the overall capacity and attractiveness of Warwick, Kenilworth and Leamington Spa as tourism hubs and result in the loss of an otherwise viable hotel or tourist facility which would consequently harm the provision of tourist accommodation;
* the proposed use or uses would be incompatible with the surrounding area and businesses and would harm the character of the town centre;
* there would be no clear, additional benefits from the proposal in terms of improving the character of the area, the vitality and viability of the town centre and the economic and, cultural and environmental impact on the town as a whole.
Applicants seeking change of use away from existing hotel or tourist accommodation use will need to submit detailed evidence relating to the viability of the business and details of how the business has been marketed.

Rural accommodation

We support tourism in rural areas and we recommend that the Local Plan should have a specific policy to address expansion and re-development of existing tourism accommodation and tourism facilities within the Green Belt.

Accommodation not in permanent buildings
The District Council may wish to consider an additional policy to cover accommodation not in permanent buildings (i.e. camping, caravan and chalet parks). This type of accommodation can be damaging to the character of landscapes, and in rural areas the added light pollution can be intrusive. It is recommended that small scale developments should be supported in areas of open countryside or next to small settlements provided they are not prominent in the landscape and have high quality landscaping. The policy may choose to exclude locations in sensitive landscapes and areas prone to flooding.

Ecological & Geological
We welcome and support the strategic direction outlined in the Preferred Options document in relation to the Natural Environment and would like to make the following suggestions:

4. Spatial Portrait, Issues and Objectives
4.7 - Sites of Importance for Nature Conservation are now referred to Local Wildlife Sites. It is suggested that Local Geological Sites are also listed. You may wish also to consider using the Habitat Biodiversity Audit and the State of Biodiversity Report to provide a Spatial Portrait of the District's Biodiversity.
4.8 - You may wish to add climate change as a pressure in bullet point 9

7. Housing
7.5 - You may wish to add within the important issues a reference to the natural environment such as "Maintain access to the natural environment in both urban and rural settings to reap social, economic and well-being benefits".
PO4 Distribution of Sites for Housing: (A) Allocated Sites - we are aware of the habitat evidence submitted for the previous work on the local plan, but would suggest that a new model has been produced to measure Habitat Distinctiveness and Connectivity throughout Warwickshire, Coventry and Solihull. This approach is placed at the heart of the National Planning Policy Framework as a way to indicate 'sensitivity' of habitats within potential allocated sites and how the site acts within the ecological corridors. We would recommend that this approach is investigated as partners to the Habitat Biodiversity Audit with the knowledge that the habitat data is current and sound.

PO4 Distribution of Sites for Housing: (C) Development of Brownfield Sites - we welcome the comment relating the development having 'no serious impact on the amenity and environment of their surroundings'. However, brownfield sites can be e very important ecological sites in their own right so suggest that this aspect is noted in the future policy.

8. Economy
There is no reference to the relationship between a healthy environment and the economy. It is suggested that this link is made in the introduction to add weight and substance to subsequent paragraphs within the policy such as 8.15. For example a statement could be, "There are proven links between the natural environment and economics (National Ecosystem Assessment, 2010) through an Ecosystem Services approach. It is essential that these links are maintained and enhanced through both the placement and setting of commercial activities coupled with the retention of agricultural and silvicultural practices." Further pictorial reference to explain Ecosystems Service can be found in the National Ecosystem Assessment documentation.

9. Built Environment
We support the 'Sustainable Garden towns, suburbs and village' design guide as well as the Relevant Issues and Strategic Objectives.

10. Climate Change
It is recommended that more be added in relation to Climate Change Adaptation within the introduction to support the last bullet within the box titled PO12 Climate Change.
12.25 - 12.26 These paragraphs outline the impacts and issues relating to Climate Change Adaptation, however, it is felt that this topic could be expanded upon within future documents, e.g. an addition Supplementary Planning Document or equivalent. This additional document could promote green roofs, green walls and other ways to promote urban cooling etc. WCC Ecological Services is able to signpost you to a couple of other Local Authority documentation on this topic.

11. Transport
It is recommended that reference be made to the Natural Environment White Paper (2011) and the importance of transport networks and ecological connectivity assets.

12. Green Infrastructure
In our opinion we suggest that this chapter is well balanced and support its approach. It is suggested that additional references to Ecosystem Services, the Warwickshire Biological Record Centre and the importance of using up-to-date ecological and geological / geomorphological data is used is the assessment of development proposals. These should be added to the future policy and the Ecological Services are able to assist you with this advice, subject to resources.
By the time the future policy is formed the Sub-regional Green Infrastructure Strategy will have been produced for consultation and can be more fully referenced as a mechanism to deliver your objectives outlined in this chapter.

18. Flooding and Water
In relation to ecology it is recommended that there is future referenced to the safeguarding or promotion of natural flood alleviation areas at strategic sites within the district as short, medium and long term aspirations to assist with flood risk measure. We are aware that this may form part of the Catchment Flood Risk Management Plan (18.9) or fall within the Sustainable Urban Drainage Approving Body's remit, but would suggest that these strategic potentials should be particularly noted within the future policy. These sites could then be potential delivered through the biodiversity offsetting metrics (15.16).

It is also recommended that a further discussion be held regarding the assessment of allocated sites using latest modelling of habitat data.

Comments regarding minerals safeguarding
Para. 143 of the National Planning Policy Framework (NPPF) requires that in preparing Local Plans, local planning authorities should define Minerals Safeguarding Areas and adopt appropriate policies in order that known locations of specific mineral resources of local and national importance are not needlessly sterilised by non-mineral development, whilst not creating a presumption that resources defined will be worked; and define Minerals Consultation Areas based on these Minerals Safeguard Areas.

The British Geological Survey's 'Guide to Minerals Safeguarding in England' (October 2007) provides the following advice:

"A district DPD could include policies that set out the general approach the district will take when determining proposals for non minerals development within or close to MSAs or existing mineral workings. Such policies should acknowledge the procedures for consulting the MPA on the existence and extent of mineral resources present and considering the case for prior extraction of mineral where appropriate."

In June 2009, the British Geological Survey (BGS) completed a piece of work to delineate Warwickshire County Council's Mineral Safeguarding Areas (MSAs)/Minerals Consultation Areas (MCAs). The BGS identified the extent of individual mineral resources in Warwickshire and these, in turn, were used to develop safeguard areas for each mineral. WCC would suggest that these MSAs/MCAs are either identified on WDC proposals maps and/or a link is provided in the Local Plan to Warwickshire's Minerals Safeguarding webpages. This will help to ensure that minerals implications are taken into account as part of decision making for District planning applications.

We would request that where certain applications may potentially sterilise minerals deposits within an MSA, the District Council consults the County Council. If the County Council concludes that minerals reserves may be sterilised, the applicant may be required to submit a Minerals Survey to establish whether the reserve is economically viable. In some cases, the County Council may insist that prior extraction of the minerals is undertaken prior to the non-mineral development being carried out. It is considered that the inclusion of this procedural information will improve the effectiveness and deliverability of the policy.

In assessing the Preferred Options, it is noted that there appear to be sand and gravel deposits under the 'Whitnash East', 'West of Europa Way' and 'South of Gallows Hill' sites - see attached map (appendix A). It would be beneficial if a minerals survey was undertaken by the developer to determine the quality and depth of the resource and to establish the feasibility of prior extraction.

Waste
Policies for the development of major residential development sites should include waste management issues as part of the overall design of larger residential/retail developments. For example, provision for waste recycling/composting on site will ensure that waste is managed in accordance with the principles of proximity, self-sufficiency and the Waste Hierarchy. Furthermore, there is a need to provide adequate waste facilities for flats and apartments - see WRAP's 'Good Practice Guidance - recycling for flats' WRAP, available at http://www.wrap.org.uk/content/recycling-collections-flats.

It should also be noted that policy CS8 of the Warwickshire Waste Core Strategy (due for Submission in September 2012) seeks to safeguard existing waste management sites. At this stage, it is considered that none of the preferred option sites are likely to prevent or unreasonably restrict any waste sites. However, if necessary the Council may object to other proposals which may sterilise important waste facilities (e.g. those delivering significant waste management capacity to meet the County's landfill diversion targets). To prevent this, WCC intends to supply each District/Borough Council with its latest waste site information, possibly in GIS format, so that the County Council can be consulted on any proposals within reasonable proximity (e.g. 250m) of existing waste management facilities.

Customer Services/One Front Door/services that support communities and families.

The County Council is open to co-location, co-access, and co-servicing of support services including support for the elderly, vulnerable adults, and families , however, these services should be located or are accessible to communities they serve. Further for new development these key services should evolve with the phasing for large developments. One solution could be providing lay-bys with " electric hook up points" for mobile services (including a mobile shops) this would build up sufficient demand before most of the dwellings are built. Consequently, make communities and developments sustainable.

Transport and Planning matters
The key transport strategies are contained in Warwickshire Local Transport Plan 2011-2016. The County Council is already working with the District Council to assess the transport impacts of various development scenarios as part of our Strategic Transport Assessment work and will be responding directly on this and other relevant transport matters. The key matters are access and sustainability of the pattern of development for homes and jobs.

We support the direction and economic strategy of the Local Plan and we need to undertake further work on some key matters ie transport, archaeology and ecology matters.

See attachment

The Parish Council support the Local Plan in principal; we have made reference as detailed below to the areas we feel directly impact our Parish.

The Parish Council would request the housing demand produced by the original survey be revisited to take account of the latest data available, such as the 2011 census results, the later figures from the births and deaths register and inward migration figures.

Also the Parish Council would like WDC to reconsider whether they have given sufficient weight to the unprecedented development in the area over the last few years, which, would make extrapolation of recent figures unreliable.

Comments on Preferred Options

P05 Affordable Housing
The Parish Council are unaware of any demonstrable need for local affordable housing, we do not have an infrastructure to support this type of development, such as public transport and community facilities, however, we are in the process of compiling a Parish Plan. With survey results from the local community imminent, we would wish to revisit our comments should results show otherwise

P07 Gypsies and Travellers.
The District Council has to identify a site for travellers within the district, which it has not yet done.
We currently have one unauthorised traveller site within our Parish, which is subject to an enforcement notice, the unauthorised site does not meet the specification laid down in the new Planning Policy Framework, nor does it meet any of the criteria set out in the Preferred Options. We need to emphasize this point so the Kites Nest site, does not become the default option for WDC in the absence of another site being identified. The Parish Council take the view that the whole area, including Coventry and Rugby, which currently have underused Traveller capacity, is taken into account in identifying potential Traveller sites.

P08 Economy
The Preferred Options has identified the old Honiley Airfield as an employment site; we would insist any new development be restricted to the existing planning consent - potential for currently 2,000 jobs.
We request WDC in analysing the need for employment development consider the recent changes at Haseley Manor, which as an employment site could not attract business to the area and is now in the process of being redeveloped as housing.

P01 Greenbelt
The whole of our Parish lies with in the Greenbelt and we would wish it to remain so, if appropriate we would also wish our Parish to be designated as a "green wedge", providing a significant buffer between the conurbations of Kenilworth, Warwick, Coventry and Solihull.
We have a myriad of extremely well used Footpaths, Bridleways and Cycle routes; we wish these to be preserved as an important area for leisure and recreational activities.

We do not wish housing development forced upon us with the removal and restructuring of the Greenbelt boundaries, but we would support some sensitive infill development within our existing settlements.

P018
As a Rural Parish, we do not have any provision of storm drains to alleviate excess surface water and local road floods. We would wish WDC to revisit their strategy on the maintenance of ditches and gulleys and to also ensure landowner responsibility is enforced.

See attachment

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.

Thank you for consulting the Environment Agency on the above Strategic document that was sent out for consultation in May 2012. We appreciate the opportunity to contribute to your emerging Local Plan.

Having reviewed the Preferred Options and supporting documents we have the following comments to make.

Summary
We welcome that the importance of Climate Change adaptation and especially flood risk are recognised in the preferred options and will form a key focus for the emerging Local Plan.

We have made comments based around the following other issues for Warwick:

* Water Quality
* Water Resources
* Flood Risk
* Waste

These key issues are all key components in dealing fully with the impacts of Climate Change and we support the Local Plan ensuring all these environmental issues along with Green Infrastructure as a whole contribute to Climate Change Adaptation within the District.

We would like to offer our continuing support in the development of the Warwick District Local Plan as it moves towards publication of the next consultation document. We are happy to engage with you on the issue of policy focus and specific wording after this consultation process is complete as you consider the responses move the plan making process forward. We can also assist you in identifying cross boundary environmental issues which would need to be addressed to fulfil the requirements of the Duty to Cooperate.

Objectives
We support the over-arching objectives of the emerging Local Plan in sections:
* 4.11 Carbon emissions and use of natural resources and adapting to the impacts of Climate Change in regards to flooding. We would also encourage the consideration of impacts on water quality in assessing the impacts of climate change.

* 4.12 We support the Plans recognition for the planning of the appropriate infrastructure in the District to support the desired level of growth and environmental protection with regards to water provision and waste water treatments as well as waste and linking these to making the District more adaptive to Climate Change.

These particular objectives provide a strong platform for the protection and enhancement of the environment and Climate Change mitigation and should clearly link the environment to promoting sustainable economic growth in Warwick District.

Climate Change
The National Planning Framework states that the Planning System should contribute to protecting and enhancing our environment and help to mitigate and adapt to climate change. We support the work undertaken by the council on mitigation and adaptation to climate change and the commitment to a climate change policy (PO12) which seeks to reduce carbon dioxide emissions and promote renewable and low carbon energy production. We also support this policy's recognition of Climate Change Adaptation in seeking to require that development is designed to be resilient to and adapt to the future impacts of climate change.

Climate Change Adaptation Strategy
We support the councils view that a policy framework be set in place to ensure all new developments and buildings are designed to be resilient to and minimise the future impacts of climate change such as heat and water stress, increased subsidence, flooding and extreme weather events. We would suggest that the factors summarised in the Local Plan from the Climate Change Adaptation Strategy by linked clearly to the issues which would be impacted upon directly. This would include flood risk, efficient use of water resources, the impacts of the urban heat effect and the protection and enhancement of water quality and biodiversity through the provision of well planned Green Infrastructure.

We have broken down our comments to the separate topic areas of Flood Risk, Water Quality, Water Resources and Green Infrastructure (including Biodiversity) but all inseparable from the over-arching issue of Climate Change.

Flood Risk
It should be noted that Climate Change could increase rainfall and river flows with increasing intensity and scale and so there could be an increase in both pluvial and fluvial flooding. We currently factor in an increase of 20% on currently flood modelling to account for the predicted impacts of Climate Change.


It is important to flag up that under the issue of Gypsies and Travellers (Page.31) there is no mention of the location of sites and pitches with regard to flood risk. Safety is paramount for these members of society and they can be vulnerable to the effects of flooding so allocation of these sites should be located primarily in Flood Zone1.

As a point of clarification, on Page 97 Para 18.5. the 2nd point reads - "To ensure that new development does not increase surface water flooding". We would recommend that this point should be amended to say "To ensure new development does not increase flooding from pluvial (surface water, run off) and fluvial (river) sources", as both types of flooding pose a risk to the District and wider catchment.

Looking at flooding on a catchment basis, development and defence strategies in Warwick District could have impacts on the wider Avon and other catchments. These impacts could be felt into Stratford and Wychavon Districts so a strategic view of flooding must be encouraged. By taking a more catchment based approach to the issue of flood risk, relationships with neighbouring authorities both upstream and downstream of the District will be identified and taken into account, therefore again supporting the Duty to Cooperate requirement.

Page 98 Para 018. 1st line reads, "new development will take place on sites outside of flood risk zones as far as practicable". We suggest that in line with the NPPF it may be better to amend the sentence stating that "no development in Flood Zone 3 unless it is water compatible." as Flood Zones 1 and 2 are developable subject to satisfactory drainage provision.

With regards to Para 18.10 and the description the role of the SuDs Approval Boards (SABs). They are still emerging after some delays, but they will be active in due course when the Lead Local Authority take on this function.

The Development Sites.
The development sites all appear to have avoided major flood risk issues as there are minimum sections of flood plain identified within them.

There are areas susceptible to surface water flooding identified for the majority of the sites but these should be identified and assessed in any site specific Flood Risk Assessments and these should consider all forms of flooding. We do not see any show stoppers associated with this aspect but in order to ensure surface water and flood risk is managed effectively in the District we recommend that surface run off be addressed in Policy PO18. We therefore suggest that PO18 where it addresses SuDs schemes should also include the commitment to ensure all new development achieves Green Field rates of surface drainage.

Water Quality
We are pleased to note that the issue of Water Quality and the implementation of the Water Framework Directive (WFD) are addressed in the supporting text to Policy PO18. However, we would encourage these issues to be fully addressed in Policy PO18 and suggest a policy be taken forward which insures no development should be allowed without provision of the necessary infrastructure to ensure no deterioration of local water bodies and such development should seek opportunities to make a contribution to the WFD objectives contained in the relevant River Basin Management Plan. Currently, PO18 makes no reference to wastewater, sewerage capacity and sewage treatment capacity at local treatment works.

We also suggest that the council work with Severn Trent Ltd and ourselves to consider the information in the sub-regional Water Cycle Study (March 2010) is still the most up to date and relevant to support the emerging Local Plan. It could be assumed that such a review should draw the same conclusion as the March 2010 document in that overall Water Quality is generally poor quality in terms WFD classification due to high phosphate levels, invertebrate/fish failures etc and these failures are caused from sewage treatment works and diffuse pollution from urban and rural sources. The majority of waterbodies are of poor - moderate status with only 4 waterbodies currently at Good Ecological Status/Good Ecological Potential (if heavily modified), Finham Brook and Radford Brook are two, the others being canals.

Infrastructure Delivery Plan
The supporting IDP states:
"As part of this funding cycle STW are currently making improvements to Longbridge sewage works (Warwick) to improve its efficiency and add further capacity and it is anticipated that this will be completed by 2014. They also have an existing ,discharge consent‟ to increase the capacity of Finham sewage works by 15%."

This statement needs to be confirmed with regards to the Finham works as this also serves Coventry as well as parts of Warwick District. Coventry has its own growth and development which could also impact on any free discharge and treatment capacity at the works. Both the Longbridge and Finham works ultimately discharge into the River Avon which means we strongly recommended that the council consider the whole Avon Catchment with regards to waste water treatment and WFD and this would also help the Duty to Cooperate requirement with regards to water quality. Finham STW is still a concern being a large STW with a Phosphorous removal consent limit already so it may be required that we have to Consent below 1mg/l in order to achieve no deterioration to the waterbodies for WFD.

Water Resources
Water conservation is addressed in Policy PO18 and we endorse the efficient use of water, especially in new developments, but we recommend that the plan includes specific targets, i.e. which level of the Code for Sustainable Homes and BREEAM ratings to be achieved. Specific water use targets would strengthen the policy and give a clear steer to developers. At the moment the CSH levels are recommended in the Draft Infrastructure Delivery Plan only and we would like the council to consider bringing these into Policy.

It is noted that in the Draft Infrastructure Plan (and WCS) it recommends CSH level3/4 as a minimum and that the Council aspires to achieve CSH level 5/6. To achieve level 5/6 developers may need to use rainwater/greywater harvesting systems. Since the WCS was published the Agency has published 'Energy and Carbon Implications of rainwater harvesting and greywater recycling' (August 2010) (http://publications.environment-agency.gov.uk/PDF/SCHO0610BSMQ-E-E.pdf ) which highlighted the high carbon emission associated with the use of recycled/ rainwater for anything more than outdoor use. This may influence the CSH level 5/6 aspiration. Our position statements on rainwater harvesting can be found at: Rainwater Harvesting Position Statement

If all cost effective water efficiency measures have been considered, rainwater harvesting and greywater recycling systems can be a useful means of reducing demand for mains water. It may be possible to make additional water efficiency savings from retrofitting surrounding properties with water efficiency devices and working towards water neutrality.

Each domestic rainwater harvesting (for more than just garden use) or greywater reuse should be examined on a case by case basis as their effectiveness varies considerably depending on scale, location and design.

As a guide, rainwater harvesting systems may be appropriate where:
* all feasible water efficiency measures are already in place;
* the planned system is cost effective (including ongoing maintenance costs);
* the planned system will be competently maintained and monitored;
* energy use and carbon emissions are minimised;
* they offer a more sustainable solution to manage surface water run-off than could be provided by other SuDS approaches.

The most recent and comprehensive guidance on rainwater harvesting systems is from BSI - BS 8515. On greywater it is BS 8525. Some case studies are available from:

Harvesting rainwater for domestic uses: an information guide (Environment Agency)
Conserving water in buildings, Chapter7: using greywater and harvesting rainwater (Environment Agency)
Greywater: an information guide (Environment Agency)
UK Rainwater Harvesting Association website
BSI British Standards: BS8515 - Rainwater harvesting - Code of practice and BS8525 - Greywater systems - Part 1: Code of practice

Waste
Development of additional housing and employment land will have implications for managing the waste arising from the new developments, both in terms of construction phases and during occupation. It is important that County and District work together to ensure waste is managed in a coordinated way, and if additional waste management infrastructure is required, the timing of new developments is phased accordingly.

As waste will arise during construction, and from new homes and businesses. There is an opportunity to consider the design of communities and supporting services to minimise waste arisings and encourage and enable waste to be managed in accordance with the waste hierarchy - reduce, re-use, recycle, recover, with landfill as the last resort. We support the comments in the IDP in that the council will ensure that sufficient infrastructure is in place to meet future demand for waste collection services in residential and commercial uses through the provision of household and commercial waste and recycling bins. We would recommend that in the design and layout of new housing incorporate waste recycling and collection issues such as by providing sufficient space for the collection of various waste streams.

Waste management should be considered alongside other spatial planning concerns such as transport, housing, economic growth, natural resources and regeneration, recognising the positive contribution that waste management can make to the development of sustainable communities.

We hope you find the above comments informative. If you have any queries, please do not hesitate to contact us

Attached letter

Attached letter

Whitnash Town Council respond to each of the Preferred Options in turn, and
make comments in respect of the Vision and Objectives.
Vision and Objectives
We broadly support the Vision and Objectives for the Local Plan, but reserve
our position on the level of housing supply, for the reasons set out in our
response to PO1 below.
PO1 - Level of Growth
In principle we agree that sufficient housing should be provided across the
District to meet future housing needs. However, we are unable to comment on
the proposed level of an average provision on 555 per annum on allocated
sites, plus windfalls, as housing numbers are an immensely technical issue.
Notwithstanding this, we are very concerned that Warwick District and
Coventry City Councils are failing to exercise their statutory Duty to Cooperate
under the Localism Act 2011 by not addressing the important matter
of cross-boundary housing need.
We are concerned that, in its current state, the proposed strategy will be
found to be "unsound" by the Inspector at the eventual Examination. This
could well result in additional housing provision having to be made, and this
would have clear implications for non-Green Belt areas, such as those
surrounding Whitnash.
We therefore urge the District Council to effectively exercise the Duty to Cooperate
with Coventry in respect of cross-boundary housing provision at this
WHITNASH TOWN COUNCIL
Franklin Road Town Clerk
Whitnash Mrs J A Mason
Warwickshire Email: jenny.mason@whitnashtowncouncil.gov.uk
CV31 2JH
Telephone and Fax: 01926 470394
2
stage, therefore preventing the danger of the Local Plan being found
"unsound" in the future and the Council having to consequently revise its
strategy and land allocations.
PO2 - Community Infrastructure Levy
We fully support the District Council in seeking to introduce a CIL scheme as
the Town Council considers it vital that full and appropriate infrastructure
provision is made, in advance of development wherever possible. It is
essential, however, that the funds raised are used to develop infrastructure in
the areas where the impacts will be felt, irrespective of Town and Parish
administrative boundaries.
We look forward to seeing and commenting upon the Infrastructure Delivery
Plan in due course.
PO3 - Broad Location of Growth
We support the strategy to make Green Belt releases to the north of
Leamington. For the first time in many years, this will allow a spatial
rebalancing of the urban form and provide for significant development in areas
away from the southern edge of the Warwick/Leamington/Whitnash urban
area.
Apart from relieving some of the development pressure on the south, it also
represents sensible planning practice by creating a more rounded and
balanced urban area, enabling greater accessibility, especially for the town
centres, and should enable more effective transport planning through
maintaining a more compact urban form with Leamington and Warwick Town
Centres as two central hubs.
Past development allocations had resulted in Leamington Town Centre
becoming increasingly less "central" to the urban area as development
extended to the south. The proposed strategy ends this practice and is
therefore welcome.
PO4 - Distribution of Sites for Housing
At this Preferred Option stage, we do not have detailed proposals for any of
the sites covering, for example, access arrangements, amounts of
employment land, types and forms of community facilities to be provided, and
such like.
Therefore, we wholly reserve our position in respect of objection to, or support
for, any of the sites and we will make strong representations in this respect at
the Draft Local Plan stage.
However, we have a number of concerns in respect of several of the sites. We
draw these to the District Council's attention at this stage so they can be
addressed in formulating detailed proposals.
3
Education Provision
A general comment we wish to make is that it is critical that detailed
consideration is given, up front, to the level and location of future school
provision, both Primary and Secondary.
In Whitnash we have suffered from the lack of provision of a Primary School
at Warwick Gates. The draft Development Brief included a school, but this
was subsequently deleted as the County Council, as LEA, took the view that a
better option was the expansion of the existing three schools in Whitnash. As
this was, in planning terms, "policy neutral", the District Council amended the
Development Brief accordingly and deleted the school site.
This has led to problems for the residents of Warwick Gates and we would
seek to ensure that such a situation does not arise again through this Local
Plan process.
Our comments on education more specifically related to individual sites as
follows.
Sites 2 and 3 - if these sites progress, these should be seen as incorporating
a possible location for a Secondary School.
Site 6 (Whitnash East) - we understand that access could only be achieved
through the Campion School site. We are concerned that the school should
remain viable and continue to be located where it is.
Site 10 (Warwick Gates Employment Land) - consideration should be given to
siting a Secondary School on this land, given its advantages in terms of
accessibility from across the south of the urban area. The opportunity should
also be taken to explore the siting of a Primary School on the site, to meet the
needs both of existing Warwick Gates residents and also the needs arising
from any additional housing, on the site itself or in the vicinity.
Site 2 - Myton Garden Suburb
Our concern in respect of this proposed allocation is that its development will
result in the coalescence of the three components of the urban area, Warwick,
Leamington and Whitnash. We consider that this will result in a loss of
individual identity for the three towns.
Site 3 - South of Gallows Hill
We raise the following concerns in relation to this site:
* The land is extremely prominent in the landscape and will be highly
visible when entering the urban area from the south
* The site does not represent a logical extension of the current urban
form. It is in no way "rounding off" and would constitute a "peninsula" of
development extending to the south
4
* It would have a negative impact upon the setting of Warwick Castle
Park
Site 6 - Whitnash East
We raise the following concerns in respect of this site:
* We are not convinced that access to the site is feasible. Our
understanding is that the South Sydenham development constituted the
maximum number of dwellings that could be accommodated off a cul-de-sac.
Given that access to the site via Church Lane or Fieldgate Lane is clearly not
feasible, access would have to be achieved via land within Campion School.
As this would involve relocation of school buildings, we are sceptical that the
number of houses proposed could fund the necessary works required to
achieve this solution
* Given the above issue, and our earlier comments on the wider subject
of education provision, we do not wish to see the future location of Campion
School prejudiced by this development
* There are, in the immediate vicinity of the proposed site, substantial
areas of both historical and nature conservation interest. Any development
must not have an adverse impact on any of these cultural, historic and natural
heritage resources
* In the event that the site is developed, we would wish to ensure that
sufficient community facilities are provided within the development and also
that adequate footpath and cycleway links are provided between the
development and the existing community of Whitnash
Site 10 - Warwick Gates Employment Land
We raise the following concerns in respect of this site:
* The site appears to be proposed for development at an extremely low
density. We make this observation elsewhere in respect of other proposed
allocations. We are concerned that, to accommodate the projected housing
need, land is allocated at appropriately high density, thus reducing the overall
level of new land that is needed
* This site is currently a high quality employment land allocation and we
understand that a reason the land has not been developed is landowner
aspirations, rather than demand for such a site. It is essential that the Local
Plan provides a balanced supply of employment land to meet all sectors of
demand, if economic growth and prosperity is to be fostered. There is
currently no other site in the urban area that offers this amount of land area in
such an accessible location. We are therefore concerned at its proposed
reallocation from employment to housing
5
Site 11 - Woodside Farm
We raise the following concerns in respect of this site:
* We fail to see how two access points could effectively be achieved to
this site. We do not consider access from Harbury Lane to be feasible due to
the existing road alignment. We doubt whether access could be achieved
from Tachbrook Road due to the proximity of the Ashford Road and Harbury
Lane junctions to the north and south of the site respectively. Construction of
a roundabout at the Tachbrook Road/Harbury lane junction would offer
potential for one access point, but we are concerned about the impact of such
construction on the important oak trees in the vicinity
* We also doubt whether the development could carry the cost of such
highways works. The option of gaining access via Landor Road is utterly
unacceptable due to the road alignment and lack of vehicle capacity.
Furthermore, it appears that physical access could only be gained through
demolition of existing buildings
* In the event that a single access point was sought, we consider that
this has the potential to isolate the housing from the existing community and
also lead to unnecessary and unsustainable vehicle movements
* The site would be highly prominent in the landscape - there is
therefore a concern about visual impact
* The presence of underground High Voltage electricity cables will limit
the site layout
* There is considerable local opposition to the proposed allocation of the
site. It is our duty as a Town Council to inform you of this high level of
opposition
Site 12 - Fieldgate Lane/Golf Lane
The raise the following concerns regarding this site:
* We consider there to be fundamental access problems and have
concerns about the capacity of the Coppice Road/Morris Drive and Whitnash
Road/Golf Lane junctions to accommodate the additional movements
generated by the development, especially at peak periods
* We are concerned that, at a proposed level of 90 dwellings, the site
density is too high. This would be a prestigious site and the proposed density
should reflect this. Our argument does not run contrary to that made in
respect of other sites, where we consider the density to be too low, as
provision needs to be made at varying densities to reflect different sectors of
the housing market. This includes provision of sheltered housing and singlestorey
dwellings on appropriate sites. This may or may not be the case at
6
Fieldgate Lane, but should certainly be considered across the portfolio of
proposed housing allocations
PO5 - Affordable Housing
We support the provision of appropriate levels of affordable housing but would
seek this to be distributed across all sites to ensure the development of
socially balanced communities
PO6 - Mixed Communities and a Wide Choice of Homes
We support the Preferred Option PO6.
PO7 - Gypsies and Travellers
Given that Whitnash has experienced particular problems through unlawful
traveller encampments in recent years, we support the principle of the
Preferred Option of proper site provision
PO8 - Economy
We support the principles of PO8. However, we reiterate our concern that
appropriate levels of employment land should be provided, in the right places,
and this should constitute a balanced portfolio of sites to meet as wide a
variety of needs and demands as possible
PO9 - Retailing and Town Centres
We support the principles set out in PO9
PO10 - Built Environment
We support the principles set out in PO10
PO11 - Historic Environment
We support the principles set out in PO11
PO12 - Climate Change
We support the principles set out in PO12
We will seek to ensure that any future development in Whitnash seeks to
reduce the Town's overall carbon footprint through the application of
sustainable development and design principles
PO13 - Inclusive, Safe and Healthy Communities
We support the principles set out in PO13
7
PO14 - Transport
We support the principles set out in PO14 with the exception of the section
relating to High Speed 2.
Whitnash Town Council neither objects to nor supports HS2
We urge the District Council to ensure that the final Infrastructure Delivery
Plan takes full account of public transport needs and the principles and
policies set out in Warwickshire County Council's Local Transport Plan 3
PO15 - Green Infrastructure
We support the principles set out in PO15
PO16 - Green Belt
We support the limited release of Green Belt sites as set out in PO16 as this
will create a more balanced and sustainable urban area and urban form
PO17 - Culture and Tourism
We support the principles set out in PO17
PO18 - Flooding and Water
We support the principles set out in PO18

As scanned

See attached

See attached representations.

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details:

Standard Response Representation Attached. Text copied below:

Norton Lindsey Village response to Warwick District Council consultation May 2012
New Local Plan Preferred Options
Sheet 1 of 1
Which document are you responding to? Preferred Options (Full Version)
Which part of the document are you responding to? Preferred Option 1 (P01)
Paragraph number I Heading I Subheading (if relevant) - 5.6, 5.10, 5.12, 5.13, 5.15, 5.18,5.22
What is the nature of your representation? OBJECT
Part 1 -Setting the Scene and Summary
P01 - Preferred Level of Growth
OBJECT
It is agreed that some growth will be required during the 2014-2029 period to sustain an
economic and vibrant economy. An increase in homes of appropriate tenures will be
required but the level of growth based on the economic predictions certainly over the
next five years seems excessive especially when viewed against the economic
backdrop. This comment is supported by Office of National Statistics data which reveals
that the rate of increase of Gross Domestic Product has been falling since mid 2010 and
has yet to show signs of recovery. On this basis growth has been downgraded to 0.7%
from 0.8%. Predictions from the respected International Monetary Fund have revised
expectations of growth of 0.8% down to 0.2% with a very modest almost "flat
lining"growth of 0.6% in 2013. Accordingly the base figures being utilised are over
stated.
We believe that the demand for further housing in Norton Lindsey is limited and can be
adequately met by windfall sites and as has been historically the case utilising previously
used land and buildings.
Changes to Preferred Option 1 -adopt a more conservative growth pattern to
reflect market conditions which are likely to prevail over the first half of the Plan
period.
Definitions:
NPPF-National Planning Policy Framework: WOe-Warwick District Council: SOC-Stratford upon Avon District Council
Agent's contact details: