It should be recognised that other sites may come forward through the planning application process and these applications should be considered on merit irrespective of whether the need for sites has been achieved.

And I would like you to re-raise the issue of there being no public meetings held in SWWarwick, yet it is the greater concentration of potential sites.
You list Warwick Gates, Baginton (Coventry), Sydenham, Bishops Tachbrook, Kenilworth (where there are no potential sites), North Leamington (again where there are virtually no sites), and Whitnash.
None of these provide an opportunity for the residents of SWarwick yet we have in one case four potential sites within 1000 metres of a large area of housing. Thus an unfair and biased process as we have no way of voicing opinion/ objection.
How biased is that?
There must be due and proper consultation. The plan you have for the public meetings does not provide this.

An intention to avoid areas where there could be adverse impact on important features of the natural and historic environment is to be welcomed (para 7.3) as this echo's the requirements of the NPPF.

The following brief observations relate to those sites with the potential to be inconsistent with this objective. Further more careful assessment should be considered to understand how the proposed G&T sites relate to the significance of the heritage assets affected and whether the G&T developments would harm that significance. As I have been unable to consider whether any undesignated assets of importance or wider historic landscape matters are affected (Warwickshire Historic Landscape Characterisation, WCC) you should consider such matters when/if assessing the sites further.

GT03 Roman settlement close by at Windmill Hill. Issue of setting and potential for related archaeology.
GT05 Circa 17C barn. Impact on significance?
GT06 Adjacent to Grade 1 Castel Park (please refer to my comments to you re RDS July 2013).
GT07 Adjacent to Baginton Castle, associated settlement remains, ponds and mill sites.
GT09 Close to Warwick Castle Park; and includes West Lodge and Greys Mallory listed buildings
GT10 Potential for undiscovered archaeology relating to Oakley Wood Camp.
GT12/16 Setting of Barford Conservation Area. Potential for undiscovered archaeology.
GT15 Consider historic association with Castle Park.

I look forward to a refined version in due course. Please do contact me to discuss further if that would help.

Dear Sir

I would like to make the following observations with regard to the consultation document that has been produced in respect of the provision of pitches for Gypsies and travellers.

Section 7 of the consulation document makes reference to certain criteria that have been used in determining the suitability of the sites. I would like to question how strictly these criteria have been adhered to in arriving at the choice of possible sites:

1 several of the sites could not be considered as being close to local facilities, they being in rural areas where such facilities could only be accessed by vehicle.

2 several of the sites are situated on busy roads where issues of road safety would arise.

3 several of the sites, if developed would without doubt have a severe impact on the character of the area and to develop these sites would surely be at odds with the criteria that requires integration into the landscape.

4 Warwickshire is a county that is constantly at risk from urban encroachment and the siting of any development outside urban areas could adverseley affect the remaining natural and historic environment.

Agriculture is an important part of the economy of Warwickshire and the impact of siting such developments in close proximity to existing farm enterprises should not be under estimated.

Whilst appreciating the this consultation will raise some very emotive issues I am concerned that the policy criteria have not been adhered to in identifying possible sites.

In your Final Interim SA Report, the consultancy employed by the council defines sixteen objectives for each site which are then 'rated' according to their potential suitablility for each site. This process does not appear to have been executed with due diligence and my first question is therefore:

1. Why have some appraisal summaries in the report been carried out giving inaccurate information, and others been left incomplete or with a question mark, when the information is readily available and could have been used to give a more sensible and useful conclusion?
2. Item #16, Crime, in the Final Interim SA Report , is given a ? rating for each of the 20 sites. Why has this objective been itemised on both the report and the response forms on which local residents are invited to make their comments and what does it mean by 'crime'?
3. As I understand it, comments in opposition from local residents which mention fear of an increase in crime on any response forms would be indicative of racism and therefore unacceptable, despite the fact that this is a factor defined by the council as an 'area of concern'. Please could you clarify this issue.
4. Please could you identify which beautiful traveller site is featured in the photographs from your expensive brochure, paid for by local taxpayers?

I look forward to your urgent response to the above questions bearing in mind the imminent closing date of this consultation.

see attached

Dear Sir/Madam,

Please find below my various representations with regard to the proposed site options.

In line with the report I wish to make representations on a number of points as detailed below.

1. Introduction

No comment

2. Background

No comment

3. Who are Gypsies and Travellers?

No comment

4. What are the Issues?

No comment

5. Policy Background

SUPPORT

National policy is correct in advocating that (1) local planning authorities work together to identify sites and (2) that decision-taking protects Green Belt from inappropriate development and makes enforcement more effective.

On Point (1) it is therefore extremely worrying that Warwick District Council (WDC) is no longer working with other authorities to consider plans on a cross-authority basis, which it has a duty to do under the 2011 Localism Act. On point (2) WDC makes no distinction between Green Belt and non-Green Belt sites in its policy criteria so again contradicts national policy.

6. Evidence Base

No comment

7. Local Plan Requirements

OBJECT

The policy criteria listed by WDC are sensible.

However they omit crucial aspects of national guidance including (1) that plan-making and decision-taking should protect Green Belt from inappropriate development and (2) sites must be in appropriate locations. Why?

There is also the fact that WDC is no longer working on a cross-authority basis to provide sites. Again, why when much of WDC is covered by Green Belt (80%)? Surely by definition travellers are nomadic and the requirement for pitches should not be restricted to Warwick District?

8. Identification of Potential Sites

OBJECT

Section 8.1 is inadequate. WDC should list all sites within it's ownership and explain why it considers each site to be unacceptable.

Section 8.3, in which WDC is seeking to identify sites itself is a total dereliction of its duty under the 2011 Localism Act. WDC contains a high proportion of Green Belt and the Council should be looking to share supply of sites in appropriate locations with other authorities.

Site listing criteria should distinguish first whether locations are appropriate according to national and local planning policy. This is a planning document and land ownership (and willingness to sell) should not be a concern due to CPO powers.

9. Sites for consideration and comment
10. Table of Sites

GT01 Land adjacent to the Colbalt Centre, Siskin Drive

No Comment

GT02 Land abutting the Fosse Way at its junction with the B425

No comment

GT03 Land at Barnwell Farm

No comment

GT04 Land at Harbury Lane, Fosse Way

No comment

GT05 Land at Tachbrook Hill Farm

No comment

GT06 Land at Park Farm, Spinney Farm

No comment

GT07 Land at Stoneleigh Road

No comment

GT08 Depot to the west side of Cubbington Hill Farm

No comment

GT09 Land to the north east of M40

No comment

GT10 Land at Tollgate House and Guide Dogs National Breeding Centre

No comment

GT11 Land at Budbrooke Lodge, Racecourse and Hampton Road

No comment

GT12 Land north and west of Westham Lane (area of search)

No comment

GT13 Kites Nest Lane, Beausale

OBJECT

Kites Nest Lane, Beausale is totally inappropriate as a site for this purpose because:

1. It is a greenfield site in the open countryside within the Green Belt and any use for this purpose (or residential etc) is inappropriate development. The National Planning Policy Framework protects the Green Belt from inappropriate development.

2. Adopting it as a possible site would legitimise the long-running unauthorised applications to impose this illegal use at this site. WDC has rightly objected to such applications (although achieved nothing in removing the illegal settlement) and allowing development through this process would set an extremely damaging precedent in this and other areas that will attract significant public disapproval. National policy supports effective enforcement against unauthorised developments.

3. Access to local services is limited.

4. Its rural location means that this use cannot be integrated in the landscape without harming the character and amenity of the area in terms of aesthetic appearance and noise.

GT14 Warwick Road, Norton Lindsey

No comment

GT15 Land east of Europa Way

No comment

GT16 Land to north of Westham Lane and west of Wellesbourne Road, Barford (small site)

No comment

GT17 Service area west of A46 Old Budbrooke Way

No comment

GT18 Service area east of A46 Old Budbrooke Way

No comment

GT19 Land off Birmingham Road, Budbrooke, Oaklands Farm

OBJECT

Land at Oaklands Farm, Birmingham Road is totally inappropriate as a site for this purpose because:

1. It is in the Green Belt and any use for this purpose (or residential etc) is inappropriate development. The National Planning Policy Framework protects the Green Belt from inappropriate development.

2. Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.

3. It is adjacent to the Grand Union Canal running locally between Warwick and Hatton offering views of Warwick Castle and St Nicholas Church.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

This is a very popular towpath for boaters, walkers, runners and cyclists alike whose amenity will be greatly impacted by the occupation/development of this site.

Its location will further impact on the visual amenity of the Grand Union Canal.

4. The site may be prone to flooding due to its location next to a water network.

GT20 Land at Junction 15 of M40

No comment

Do you have any other suggestions for land within this district that you think would be suitable for use as a Gypsy and Traveller site?

No comment

I look forward to receiving your comments and trust that the Council will make a well informed and well researched decision when it comes to sites to be considered in greater detail.

Dear Sir or Madam,

1. I write to object to the proposals to allocate sites for Gypsies and Travellers set out in the Gypsy and Traveller Site Options document (June 2013). In particular options GT19 (land adjacent to Shell Petrol Filling Station, Birmingham Road, Budbrooke, Warwick) and GT14 (Kite's Nest Lane Beausale).

2. The Preferred Option (PO7) to help meet the needs of Gypsies and Travellers set out in Warwick District Council's Local Plan Preferred Options document (May 2012) sets out the criteria to be used to bring forward sites for Gypsies and Travellers:

* Convenient access to a GP surgery, school, and public transport;
* Avoiding areas with a high risk of flooding;
* Safe access to the road network and provision for parking, turning and servicing on site;
* Avoiding areas where there is the potential for noise and other disturbance;
* Provision of utilities (running water, toilet facilities, waste disposal, etc);
* Avoiding areas where there could be adverse impact on important features of the natural and historic environment; and,
* Sites which can be integrated into the landscape without harming the character of the Area.

3. Para 8.5 of the Sites for Gypsies and Travellers document (June 2013) states ..."The Council has considered where the most sustainable sites for this purpose would be given the criteria listed". However, no evidence that the sites satisfactorily meet these criteria is given. I do not consider, therefore, that this is a fair, transparent and accessible consultation.

4. I do not consider that the options offer convenient access to a GP's surgery, school nor public transport and I have concerns over the safe access to the road network particularly in relation to option GT19 given the additional trips and type of trips/movements that would be generated by this option.

5. Policy B: Planning for Traveller Sites, para 11(f) of Planning Policy for Traveller sites (March 2012) states that Local Planning Authorities should ensure that traveller sites are sustainable economically, socially and environmentally and that Local Planning Authorities should, ensure that their policies avoid placing undue pressure on local infrastructure and services.

6. Warwickshire is experiencing a significant growth in pupil numbers and demand for places is currently outweighing availability. Notably, in 2012, there was a consultation on proposals to increase the Published Admission Number (PAN) of The Ferncumbe CE Primary School from and to re-allocate the Hatton Park development across the priority areas for Budbrooke Primary School and The Ferncumbe CE primary School to help the Local Authority to meet its statutory duty to ensure a sufficiency of places. Without these changes, children from the Hatton Park development could have to travel some considerable distance to secure a school place and a large number of 'in-area' children will be unable to secure admission to their priority school.

7. I consider that the options will, therefore, place undue pressure on local infrastructure and services - particularly local schools and the road network and particularly when there is an additional 70-90 additional dwellings on Hatton Park proposed in Warwick District Council's Revised Development Strategy (June 2013).

see attached

see attached

General Observations

WDC should have identified brownfield sites within the existing urban areas of Kenilworth, Warwick and Leamington for Gypsies and Travellers. These sites would be more suitable and sustainable, and would enable better integration in to the local community. Despite such sites existing, they are all being proposed for redevelopment for more valuable uses. WDC should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments in Kenilworth, Warwick and Leamington. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, a doctors surgery and shops which are accessible on foot, on bike, by bus and by car.

Ecology and Environment - all of the sites have some ecological value and environmental issues which does not appear to have been assessed.

WDC should revisit its Greenbelt Policy and release sites to the north of Warwick and Leamington which would reduce the pressure to allocate land for all forms of development during the new Local Plan period to the south of the District.

WDC should consider allocating an area of land to the south of Warwick and Leamington including The Asps and Sites 5, 6, 9, 10 as Greenbelt to provide a 'buffer' to the proposed developments to the south of Warwick and Leamington and/or to extend the proposed Bishops Tachbrook Country Park as far as the Banbury Road near to Warwick Castle Park. This would ensure the villages in the south of the District retain their identity and are not 'swallowed up' by Warwick and Leamington over time.

Dear Sir/Madam,
I am writing to make my objections to the Gypsy and Traveller Site (G&TS) options clear.
It is clear that when considering G&TS's the following must be considered:
Convenient access to a GP surgery, school and public transport
In 2007, 2.7% of children of Gypsy/Romany origin and 8.4 % of traveller children of Irish heritage achieved 5 or more A* to C grades or equivalent exams including English and Mathematics in England compared to a national average of 45.4%. 8% of Gypsy and Traveller mothers have experienced the death of a child compared to less than 1% of the settled community. This could put a major strain on the already overworked education and medical facilities already available in the area.
The Catholic Primary in Whitnash, St Josephs' has had to turn away Catholics with siblings already at the school as it has such a high application rate. Is the council going to supply additional funds to help support these children's needs? Given that the parents of many of these children are unable to read & write themselves they are not in a position to help children with their own learning and this identifies yet another pressure point. As an adult not being able to read & write seriously narrows down the type of work you would be able to apply for, there are limited employers within in the village of Bishops Tachbrook therefore there is no immediate local economy for them to join with.
Avoiding areas with a high risk of flooding
Field on the corner of Mallory Road, Banbury Road floods on each side whenever there is a significant rainfall. Sites GT05, GT06, GT09 and GT10 are all prone to flooding.
Provision of utilities
Who would be expected to provide this? Sites GT05, GT06, GT09 and GT10 do not have adequate provision of utilities such as sewerage, drainage, gas and water.
Safe access to the road network and provision for parking, turning and servicing on site
Sites GT05,GT06, GT09 and GT10 are all on very major roads with no means of pedestrian access. There are no bus routes and they are all fast moving roads.
Avoiding areas where there is the potential for noise and other disturbance
Banbury Road is the main road off the M40 for people travelling from both the North and the South. GT05, GT06, GT09 and GT10 are all bordering the M40 meaning that these sites will be very noisy for occupants. GT05 is in extremely close proximity to residents of Bishops Tachbrook and so any noise from this site would have a major effect on current residents.
Avoiding areas where there could be adverse impact on important features of the natural and historic environment
St Chads church in Bishops Tachbrook has many historical features. It is mentioned in the Domesday Book. GT05 and GT09 are both situated on the approach to Bishops Tachbrook and would be the first visual sight that visitors would see of the village.
Sites which can be integrated into the landscape without harming the character of the area.
It is difficult to think of any area at all that would meet this criteria. The character of the area around GT05, GT09 and GT10 is agricultural farm land. I fail to see how a G&TS would integrate into this landscape without harming the character of the area.
Promotes peaceful and integrated co-existence between the site and local community
I would suggest this is highly unlikely due to the level of local disagreement with the proposed sites, in particular GT05, GT09 and GT10. I have concerns over the level of noise that any sites may incur, both from the inhabitants and also the local community expressing their objections. Local residents have discussed various methods of protest if these plans are to go ahead. Various residents have offered financial assistance regarding legal advice. The press and local MP's have been engaged and shown their support.
Avoids placing undue pressure on local infrastructure and services
Will additional funding be provided to the village school to support with the proposed number of children likely to attend? If not will a new school be built to support in this area? Will this cause a change in the catchment areas for the school? It would be unfair for tax paying residents to be moved out of the catchment area to accommodate these new developments.
The school in Bishops Tachbrook is single form entry and is already oversubscribed. G&TS of 5,10 or 15 are likely to provide homes for 10,20 or 30 children. A small school which is always at capacity is unlikely to be able to provide the infrastructure required to support the needs of the proposed sites. The school does not have the resource to support children that have received very little if any formal education. They will struggle to integrate into the local school environment.
The school also relies on the parent teacher working relationship meaning that parents support the school by giving up their time to help teach and read with pupils. It is known that 81% of Gypsy and Traveller children's parents are illiterate. This will mean no support for the school. It will also mean that these children will require even more support from existing parents. The extra support that these children will need will put the current children at a disadvantage. The school is simply not equipped to deal with the needs of these children.
There are already concerns that the secondary schools in the area are oversubscribed and that there is not adequate provision for the current population of the parish. Any additional strain on these numbers will only make the situation worse.
There is a grade 1 listed church and a sports and social club built through local fund raising. There is a small local shop, a hairdresser and one public house. That is it.
Reflects the extent to which traditional lifestyles (whereby some travellers live and work from the same location thereby omitting many travel to work journeys) can contribute to sustainability
I would suggest that it is a small minority of Gypsy and Travellers that live and work from the same location. I would be interested to see the evidence to show how a Gypsy and Traveller site can support local sustainability in this area.
Specific sites
GT05, GT09- Vehicle access is onto a very busy main road, with vehicles travelling at speed. To introduce caravans and mobile homes turning into the site would be dangerous. Additional traffic at the junction of Mallory Road & Banbury Road would put too much strain on an already busy junction onto a road where cars are travelling at speed, because of the north and southbound approaches to junction 13 of the M40. This is not an easy junction to get out of especially if you have to move slowly due to pulling a trailer or caravan.
Given the proximity of 50mph roads next to this site what are the provisions for the safety and security of both people & animals? For instance a horse on the Banbury Road especially a loose one could end in fatalities.
The potential visual impact would be devastating on the approach to the Historical Warwick town and could discourage visitors and tourists. There are listed buildings on this site in need of protection. The proposed location is not in an area that can be integrated into the landscape without harming the character of the area which is stipulated as a Site Requirement within the WDC Consultation Document. It would be the first thing that people see when travelling into the village from the M40
GT06 - Very remote from main centres and no means of pedestrian access
GT10 - Close to the Guide Dogs for the Blind National Breeding Centre. The risk of disease from any unvaccinated animals belonging to Gypsies and Travellers could be devastating. Given the proximity of 50mph roads next to this site what are the provisions for the safety and security of both people & animals? For instance a horse on the Banbury Road especially a loose one could end in fatalities. As could loose dogs.
Vehicle access is onto a very busy main road, with vehicles travelling at speed. To introduce caravans and mobile homes turning into the site would be dangerous.
The proposed location is not in an area that can be integrated into the landscape without harming the character of the area which is stipulated as a Site Requirement within the WDC Consultation Document.
GT15 - site located on the banks of the Tachbrook. There could be a chance of contamination, given that the proposed site may be used as a place of work. Europa Way is an already congested road and adding further traffic to this mix could be devastating.
Sites GT05, GT06, GT09 and GT10 are currently homes to many forms of farm and wildlife animals. They are also working farm land.
Other considerations
6 out of the 20 sites have been proposed around the small unique village of Bishops Tachbrook.
Are the sites identified in and around Bishops Tachbrook too remote from the main infrastructure of Leamington Spa or Warwick to be suitable for this type of development?
On behalf of Warwick District Council, Salford University has determined that there is a requirement for 25 pitches initially expanding to 31. Why the need for so many propsed sites then?
Who will monitor the sites. It is my understanding that the sites will be operated by Gypsy and Travellers and not Warwick District Council. If this is the case how can concerns such as noise pollution land pollution and overcrowding be controlled?
Recommendations state that the size of each site must be between 5 and 15 pitches but does not specify how many people can populate this sites. What plans have been put in place to ensure that what happened at Dale Farm does not happen again. This was where a legitimate site expanded?
What about the effect on house prices in the general area around these sites?
What will be the visual impact on Bishops Tachbrook village and surrounding area. Will it have an impact on tourism in the area?
All proposed sites are on busy roads where it would be a danger for any children to wait for transport to school.
Why are 15 of the proposed sites in the south of Warwick & Leamington? The small village of Bishops Tachbrook has 6 of these proposals within a mile of it, 3 are on its immediate doorstep. Potentially all of these sites could be approved and the very nature of our community and how the approach to our village would look would be irrevocably changed. The effect on Bishops Tachbrook would be devastating to our way of life. This is not acceptable nor a reasonable request for the council to make.
There is no statement from the Gypsy Council of Great Britain or any other organising body on behalf of the Gypsy & Traveller community, within your brochure/document, that they wish to join our community in Warwickshire or anywhere else. Perhaps this is because they have no desire to permanently live here? What evidence does the council have that the Gypsy & Traveller community wish to use these sites as a permanently settled site with a fixed maximum number of 15 Pitches? You also do not state how many people are able to live within a pitch or who is responsible for the site. Due diligence has not taken place here. I appreciate that you state the Regional Spatial Strategy & commissioned Salford University have produced a report but you have failed to put any meaningful back up data into this document . Therefore I have to question the validity of the study as you have not put it in the information you are handing out. Where is the proof that so many sites are needed? Much needed data is missing here & the council are remiss in leaving it out.
You also state that the Gypsy & Traveller Accommodation Assessment shows a need for 31 pitches, 25 within the first five years & a further 6-8 transit pitches over the Plan period. Yet the brochure you have produced is only showing 19 of these. Why are you not identifying where all these sites will potentially be? Are you planning to use these larger identified areas to put up multiple sites? Please be clear & honest!
Sites GT05, GT06, GT09, GT10 are all next to each other meaning that of all these sites are successful there would be a huge Gypsy encampment in a small area.
The images you are using on your front cover, page 3 & page 4 are clearly stock images of holiday camping sites. They are not permanent sites and they are certainly not Gypsy & Traveller sites. Why is the council not using real images from existing successful sites to give an honest & truthful photographic representation of how these sites will look?
Proposals
Has the area next to the police site on the west side of Europa Way in between GT06 and GT15 been considered. This could have access onto one of 4 roads and would have a high Police presence.
A further alternative site and one that is a much more suitable at addressing the issues that are set out in Section 4 of the consultation document is on the opposite side of Stratford Road, Warwick to Aylesford School. This site is located within walking distance of medical, educational and recreational facilities.
It is located on a straight section of road with good sight lines and a 40 mph speed limit. It is served by bus routes and has wide pedestrian footpaths. This site is also set back from the road so would provide some protection from any negative visual impact.
Other comments
The instructions for this plan are very unclear. I have been advised that a separate letter needs to be submitted for each proposed site but I can not see anywhere that this is mentioned for email responses, this is unclear. If that is the case I have grave concerns that this consultation has not achieved its legal goal of "improving the efficiency, transparency and public involvement in large-scale projects or laws and policies" as people do not know how to respond in the correct manner.
I request to know the name of the authorised Gypsy site shown in your brochure.
Whilst I appreciate that WDC are under instruction to provide sites I would suggest that the proposed sites around the Bishops Tachbrook area are in the wrong places. This community is already stretched to capacity. I fail to see how the G &T could contribute to our small community.

1.1 We strongly oppose the scale of housing growth that the Development Strategy proposes. The The scale of development and the extent of urbanisation proposed would undermine the pattern of towns and countryside that characterise the District and make it an attractive environment. It would depart from the policies of strict control on urban expansion that have been in place for 40-50 years since the Green Belt was first effective. The effects on the historic inner parts of Warwick and Leamington would be very hamful as these would be surrounded by ever more housing and be subject to heavy traffic volumes generated by the additional development.

1.2 The District cannot retain its character and quality of life unless the housing growth is kept at much lower levels and unless much of this is by windfall development within the urban areas.

1.3 The proposals to impose 100-150 houses on each of five villages, and 70-90 on five others, would in most cases damage their rural character and unbalance their structure.


2. Principles of the Development Strategy

2.1 A main aim of the New Local Plan is to promote growth, and this is based on the Vision of the Council that growth, per se, will increase future prosperity. This fails to recognise the character of Warwick District and the limits to development and expansion of the District's towns if they and their setting are to retain the quality of environment that has been achieved by generally good planning in the last 40 years. There is no demand from the residents of the area for this aim and it has not been subject to public participation as to whether it should be the principle underlying the Plan.

2.2 A motive for significant new development appears to be the Council's belief that the scale of development proposed will increase the income of the council and lead to improved services. Even if this were the case it is not a justification for development which would change the character of the District and undermine the quality of its environment. It is unlikely to have a financial benefit, because of the cost of the additional services that new residents, many inward migrants, would require.

2.3 CPRE is also very concerned that the earlier consultation results appear to have been ignored. The consultation on Options showed most support for a lower level of development in terms of annual housebuilding ('Option 1') than is proposed in the Preferred Option. We believe that the residents of an area should have a significant influence on the way that area develops and changes.

2.4 We seek a commitment to a vision of the district as a rural area containing a number of towns, with major historic centres. The New Local Plan would lead to Warwick District becoming a significant urban sprawl with a rural fringe at risk of development and decline.

2.5 The justification for the scale of housing proposed is not made. The ONS and SHMA figures include a large element of in-migration of population into the area. It is this assumption of in-migration that leads to the high household numbers forecast and the claim that 12,300 houses are required between 2011 and 2028. The Development Strategy fails to show the actual household increase that would result from accurate application of the 2011 Census and trends in migration in most recent years.

2.6 Other representations set out the reasons for a lower housing requirement, 5,300 over the period 2011-2028 or 250 new dwellings per year. This is an achievable and acceptable level of housing provision and should be adopted by the Council. In the most recent recorded period, from 2006/7 to 2010/11, 1,400 dwellings were completed in Warwick District - an average of 280 per annum. The annual housebuilding rate proposed in the Development Strategy has not been achieved in the past and is unrealistic.

2.7 The justification for the high housing numbers is expressed by the Council as being to 'achieve economic growth rates in line with national forecasts' (para 4.1.6). Para 4.1.10 claims that economic growth in the District is linked to providing additional houses. The aim therefore appears to be to encourage in-migration by providing more housing so that more employment is provided in the area to create more 'GVA' (growth).

Not only has this aim of the Development Strategy not been subject to public consultation; it is is wholly contrary to the interests of Warwick District. It is the attractiveness of the District's towns, villages and countryside and the strict control on development that makes it economically successful. The employment growth (much in small businesses and people working from home) has not required new employment land and there has been relatively little rebuilding of existing office accommodation. There is in fact a surplus of employment land and some is not used (see paras 4.5.18-20) while the District already 'has a good range of land within its employment portfolio'. No case has been made for releasing any greenfield land for employment over what is already available.



3. Proposed Locations for Housing Development

3.1 The previous consultation (Preferred Options) proposed 'growth across the District' including on Green Belt, and in villages. The large-scale development of Green Belt north of Leamington has been withdrawn, but Green Belt development at Thickthorn, Kenilworth, at Cubbington, and adjacent to certain villages now 'washed over' by Green Belt is still proposed. The proposals for development in Green Belt at Hampton Magna, Lapworth (Kingswood), Burton Green, and Baginton are strongly opposed.

3.2 The scale of development between Warwick, Warwick Castle Park, Leamington, Whitnash and Bishops Tachbook is unacceptably large. A rural landscape which is not 'urban fringe' but valuable agricultural land would be urbanised. The eastern side of Warwick Castle Park, which past policy has kept rural, would be partly built-up. Harbury Lane should remain the southern boundary of the built-up area of Warwick & Leamington, a function it has performed effectively since the Warwick Technology Park and the housing location known as 'Warwick Gates' were developed under past Plans.

3.3 This major location would not only develop valuable open countryside. It would be car-served development since it would be too far from the town centres for walking, cycling facilities are limited, the railway stations are not near it and bus services in the District have low useage and are not generally attractive. The traffic impact of the development proposed would be so great that Warwick's historic town centre would be heavily congested and polluted by the additional traffic. Routes in and out of central Leamington area already congested at peak hours and condiktions would worsen.

3.4 The proposals for 100-150 houses at each of the non-Green Belt villages - Radford Semele, Bishops Tachbook and Barford - would overwhelm these villages. Smaller numbers may be acceptable over a long period but not development on that scale.

3.5 These housing proposals are not sustainable development, in contrast to the three brownfield site proposals within Leamington Spa which meet sustainability prlnciples.


4. Gypsies and Travellers

4.1 CPRE has commented separately on the Gypsy and Traveller Sites consultation document. We would emphasise the opportunity to co-operate with Coventry City Council to expand provision at Siskin Drive, where the boundary runs through the existing employment areas.


5. Proposals for Employment Land

5.1 In August 2012 we responded to WDC's Preferred Options raising issues including the amount and location of employment land proposed in the emerging plan. Our conclusion on employment land in 2012 was that "no new development of employment land in the Green Belt is justified". The Revised Development Strategy increases our concerns that WDC's emerging plan is unsound.

5.2 Section 3.5 of the Revised Development Strategy (May 2013) summarises sustainable development principles including "avoiding coalescence". But WDC's proposals fail to achieve this principle. The so-called Sub-Regional Employment Site would cause coalescence of Coventry and Baginton and the proposed Thickthorn developments would erode significantly the separation between Kenilworth and Leamington. The proposals are not sustainable.

5.3 There is in fact an excess of employment land already available in Warwick District. The issue of the amount of employment land is mainly caused by WDC's approach to the assessment of Employment Land Requirements. This approach turns a substantiated excess of employment land into a claimed deficit of employment land, resulting in the proposed policy RDS6 which specifies that 22.5 hectares of new employment land should be allocated between 2011 and 2029, mostly in the Green Belt.

5.4 Table 4 shows the detail behind the claimed deficit; this is reproduced below.

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 16.5
C. Potential redevelopment of existing employment areas 13.5
D. Total gross employment requirement (demand) 66

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Balance to be allocated 17.5
(15 to 25)


5.5 Section 4.5.8 then takes the bottom line (Row H 'Balance to be allocated') figure of 17.5ha and increases this figure to 22.5ha in order "to allow for flexibility and the assumptions used in modelling and forecasting". The latter 'buffer' of 5ha overlaps with the Item B 'Margin to provide flexibility of supply' of 16.5ha. This is double counting. Error in modelling/ forecasting can go either way (plus or minus), not just one direction. The claim that "it is reasonable to provide an additional 22.5 hectares of employment land" is entirely unreasonable.

5.6 The established requirement (Item A) is 36ha; against this, 16.5ha 'Margin to provide flexibility of supply' is itself excessive: almost 50% extra on top of the established demand of 36ha in order to provide 'choice'; this seems to be an unjustified excessive amount of flexibility. The environment cannot afford such generous luxury of flexibility. A 10% contingency should be sufficient 3.6ha rather than 16.5ha.

5.7 The final component in the demand side of the table above is Item C 'Potential redevelopment of existing employment areas', amounting to 13.5ha. Although this seems at first sight to be supply rather than demand, more employment land is claimed to be needed because of the unjustified change of use of existing employment land, removing it all from the employment portfolio and allocating it to housing. Sections 4.5.19-4.5.20 (and 4.2.4) describe the proposal to remove 19.5ha of existing employment land and replace it with 13.5ha of new employment land.

5.8 The proposal to take all of this land out of the employment portfolio conflicts with other sections of the consultation document. Section 4.3.9 makes quite clear that some of the 'tired' employment land could be released for housing development. No justification is provided for taking all of the land out of employment use; there seems to be no reason why such employment land should not be redeveloped for continuing employment purposes (if demand is really there). It is extreme to assume that all of this land will be 'lost' to employment uses. It is not acceptable to take brownfield land in urban areas out of the employment portfolio and replace it with greenfield land outside urban areas, much in the Green Belt. The strategy should be to improve effective use of the 19.5ha for continuing employment use.

5.9 Established numbers in the above table show the base demand as 36ha (Item A) and the base supply as 48ha (Item F). The unadjusted numbers show an excess of employment land of 12ha. This excess provides ample flexibility and margin for error. A corrected version of Table 4 is provided below:

Table 4 Revised

The supply demand balance Hectares
Demand
A. Net employment land requirement 2011 - 30 36
B. Margin to provide flexibility of supply 3.6
C. Increased effectiveness of use of existing employment areas 0
D. Total gross employment requirement (demand) 39.6

Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5

H. Excess providing even more contingency and flexibility 8.9



5.10 Through double counting, unreasonable buffers and unjustified changes of use, WDC has transformed an excess of employment land of 8.9ha into a misleading claimed deficit of 22.5ha. This cannot be justified. The misleading claimed deficit is then used to try to justify development of new employment land in the Green Belt (section 4.6):
* Thickthorn (8ha) between Kenilworth and the A46;
* Part of the Coventry Gateway site (6.5ha) around Baginton and Coventry Airport.

5.11 By protecting existing employment land and by making more reasonable assessments of buffers and flexibility, there is ample employment land available without development in the Green Belt.

5.12 The Revised Development Strategy goes on to allocate a "Sub-Regional Employment Site" (Policy RDS8). Section 5.5 is based on an extant planning application, presenting claims from the planning application as though they were sufficient justification for the District's development strategy.

5.13 The first issue with Section 5.5 is evident in its title: the meaning of 'sub-regional' is not defined. The Regional Spatial Strategy has been abolished but the justification in section 5.5 still relies on its policies such as the Coventry & Warwickshire Regeneration Zone. This is directly in conflict with the the abolition of the RSS and makes the proposed strategy unsound. The long- established economic partnership in the area is CSW - Coventry, Solihull and Warwickshire - but the Revised Development Strategy focuses on the Coventry & Warwickshire City Deal and the CWLEP. In practice, the 'sub-region' is an artificial construct with no proven need.

5.14 While Section 5.5 purports to be describing a generic employment site for predominantly B1, B2 and B8 uses, it depends on the justification for the specific uses proposed in the Coventry Gateway application even though this focuses on the Gateway's proposed B1(b) (research and development) sub-class, for example. Policy RDS8 as described when the consultation document was written (before the planning committee considered the Coventry Gateway application in June 2013) is little more than pre-determination of the Coventry Gateway application.

5.15 Even if a 'sub-regional' need were justified, no justification is provided for siting it entirely in Warwick District and in the Green Belt. Considering that any 'sub-region' contains at least Coventry, North Warwickshire, Nuneaton & Bedworth, Rugby, Stratford upon Avon and Warwick, what is the justification for locating the 'sub-regional employment site' within Warwick District? Policy RDS8 would either take jobs from areas with greater need (unemployment is considerably higher in Coventry and Rugby, for example) or add further to the excess of employment land in Warwick District. The proposed site location undermines the well-established principle of urban regeneration, fails to recognise the brownfield-first policy (e.g. NPPF section 111) and would be inappropriate development in the Green Belt. Locating a major employment site in a rural area would increase the need to travel, particularly by car. The proposed criteria claimed to justify such a development in the Green Belt depend on policies of the abolished RSS (e.g. Coventry & Nuneaton Regeneration Zone) and vague concepts such as 'sub-regional need'.

5.16 The Core Planning Principles in the NPPF require planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them". Policy RDS8 fails to meet this requirement. The proposed policy is not justified, it would damage the environment and it should be removed.

see attached

see attached

see attached

We are writing to express our concern about the proposed development of land south of Warwick. We've attended public meetings and attempted to provide feedback through that channel (in fact the first one held at Warwick Gates Community Centre which was somewhat a debacle, offering little chance for proper discussion or feedback from the panel).

As residents of Warwick Gates since 1999, we have felt the impact of the ever increasing traffic congestion and the quick fixes which have not resolved the problems (i.e. new junction at Gallows Hill and the road layout near Morrisons). At the public meeting it was suggested that traffic wouldn't be a problem as people would be heading out to work towards Banbury, and that adequat infrastructure would be put in place but this really is not the case - the new proposals are simply going to add pressure through Warwick and Leamington town centres which are barely coping as it is and do not have room for road widening for instance. Neither have we been provided with any evidence that the sheer number of homes proposed are necessary, nor why the area near Milverton cannot be developed better placing residents to have access to the A46 and other routes to Coventry, an equally valuable employment region alongside Banbury.

Having resided at Warwick Gates for over a decade, and in fact moving in in the first year or so of devlelopment, we've already lived through the empty promises of locating a primary school on the estate - which never happened. As such we have this year also experienced the school places shortage - when our son was not given a place at his priority school of Briar Hill. The Local Plan proposes several schools but we have little faith that even one will be provided - as ever more land is given over to lucrative deals with property developers.

It seems that WDC are determined to take what was once a beautiful area and cram it full of new builds that need cars to get from A to B, as public transport links are poor (we've tried using the local buses but they are infrequent and ridiculously expensive compared to the car, particularly if there is more than one passenger).

We would also welcome further information as to why the proposed traveller sites have so much land attributed to each plot, when we, as private purchases, have half that available space on what is deemed a large property. It seems unnecessarily 'generous' given that the beneficiaries are not tax payers or contributing to the wider community.

We look forward to hearing your response,

see-attached

I refer to the 'New Local Plan'. I attended the meeting at Trinity School and now wish to comment as follows:


Concerns:
1. I consider the numbers of houses proposed over the life of the Plan to be excessive and unjustified.

2. The District is already too crowded, the additional population will 'swamp' the existing and is unfair to those who have already made their homes here. The additional traffic will lead to 'gridlock' in existing streets, especially Warwick High Street/Jury Street, and will create even more pollution.

Comments.
1. I was bitterly opposed to any further development in the Milverton/North Leamington areas as this would -
a) require the loss of good farm land at a time when the nation needs to increase not decrease agriculture.
b) it would further encroach on our 'green belt' separating us from Kenilworth.

2. I am pleased therefore that the Revised Plan recognises that there are no special circumstances for the use of this green belt and does not include proposals for further development in the Milverton/North Leamington areas.

3. The use of land in the south of Leamington/Warwick to meet the proposed development makes sense because -
a) ease of access to the M40 J14 and J13
b) all large and recently built supermarkets etc are to the south of the town.
c) local employment opportunities.
d) the Revised Plan allows for road improvements.

4. The District has an asset in Leamington Football Club (the 'Brakes'). The Club has risen through the levels of the sport and is only held back due to its present location. Provision for an independant stadium in South Town that would in due course cater for the Club becoming professional should be considered. (I am not an offial of the Club).

5. Having to use the Emscote Road 'cycle path' on a regular basis I have no confidence in the Council's ability to provide safe and acceptable cycling facilities which will be needed.

6. I have no comments to make on the proposed gypsy sites other than I feel the pitch size proposed is larger than needed.

7. If this development within the the District is essential I consider the Revised Plan to be the best option and it has my support.

Thank you for giving me the opportunity to comment. Having attended the Trinity meeting I do have sympathy with the Planning Officers with the task they have in this matter, clearly they will not 'please all the people all of the time'.