Dear Sir/ Madam

REPRESENTATIONS TO THE WARWICK DISTRICT REVISED DEVELOPMENT STRATEGY - JUNE 2013

CBRE Limited writes on behalf of a third party client who wishes to remain unnamed at this stage. These representations should therefore be registered under CBRE Limited.

Our client is a major land owner and occupier in the City and is also a key service provider falling within Class D1 of the Use Classes Order. Our client is in the early process of giving very serious consideration to relocating an important part of their operations to another site within the city. We are not able, at this stage, to identify that potential relocation site, however, suffice to say that it is a brownfield site and is not a Green Belt location. In summary therefore, our client is a key stakeholder locally, a key service provider and an important local employer. These representations are submitted in that context.

We set out below our comments relative to the corresponding paragraphs in the Revised Consultation Development Strategy document:


Paragraph 3.4

We support the overall aims and objectives of the Revised Strategy as stated. However, we consider that the District Council should clear and specific in relation to the need for more homes (including affordable homes) with a strong and implicate emphasis on the re-use of brownfield urban land in preference to greenfield land.

Paragraph 3.5

We agree with the aims set out in paragraph 3.5 however there is no reference to the need to support (and enhance) existing service provision at the local level in addition to the need to provide new service provision as part of larger new development allocations.





Paragraph 4.3

We note the broad location of proposed housing development set out in RDS3 and whilst it may be clear to Council officers that there will be a focus on the re-use of brownfield sites (including conversion of premises), this objective should be stated clearly as part of the first bullet point.

Paragraph 4.3.2

We note that there has been considerable concern by stakeholders previously at the proposed identification of Metropolitan Green Belt to deliver significant growth of new development. The Council's revised strategy should be strongly focussed on the need to better utilise existing brownfield sites within the urban areas to deliver new jobs, homes, and community services, prior to the release of either Greenfield or Green Belt land.

Paragraph 4.3.9

We note the high level of vacancy attributed to some of the towns existing industrial/commercial estates (for example at Warwick Technology Park). We believe very strongly that the Council should state what action they intend to take to resolve such vacancy. Specifically we would want the Strategy to allow for a flexible policy approach which considered a wider array of uses (and occupier types) in such estates. This could include non traditional B class uses (subject to criteria) including local community services, health care use and education uses to name just a few. The Council needs to ensure that its policy approach is flexible, commercial, and innovative to ensure that employers and businesses can utilise existing premises and land resources. Many non pure B-Class uses generate employment and deliver associated benefits to the local economy and to the area generally. Policies should be sufficiently flexible to allow non office uses to maximise existing commercial premises and land which is (or has remained) vacant or under-used.


Paragraph 4.5.3

We agree that the Government's NPPF provides significant weight to the need to provide for sufficient employment land during a Plan period. However, we are concerned that the Council's Revised Development Strategy appears to focus completely on the need to unlock new land and there is no guidance or view expressed on the need to support and facilitate growth of existing services and facilities (see our comment to paragraph 4.3.9 above). A significant element of economic growth is generated through changes of use and the optimisation of existing land and premises. In this important respect, the Council's strategy is silent. Indeed, the NPPF is clear that LPA's should work to build 'strong competitive local economies' and yet this key consultation document forming part of the Local Plan contains very little substance to explain or justify how the LPA will use its development and planning strategy to help existing businesses, employers and service providers to expand and adapt their offer through the planning system.

Paragraph 5.61 - 5.6.4

We agree with the Council's in-principle statements, however, developer contributions and mitigation needs to be viewed and assessed in the context of financial viability. The Revised Strategy document appears to be silent on the issue of viability and this important factor should be referred to by the Council (in accordance with the advice set out in the Government's NPPF).

Summary and Conclusions

The Revised Consultation Strategy document represents a very positive and useful discussion paper and sets out a range of very laudable aims and objectives as part of the Council's emerging LDF. In particular, we are pleased to read the positive statements regarding the need to promote and support development growth, and the need to support the local economy, create new jobs, and deliver new homes in the district's main settlements. We are also highly encouraged to read positive statements regarding the need to deliver new 'infrastructure' locally.

However, the consultation document appears to miss an opportunity in relation to the need to support, nurture, and enhance existing community services and existing businesses through the planning and development system. In this respect, the consultation document appears to be overly focussed on the delivery of new land rather than existing land and existing uses. The majority of wealth and job creation in Warwick will be generated through 'churn' (the use, re-use, and adaptability of existing premises), not just through the provision of new land.

We also note that the consultation document provides a very narrow view of 'employment' generating uses (B1, B2 and B8). Active thriving economies need support for a wide range of employment types including uses falling outside the traditional B Class uses. For example, service providers in the education and health sectors (Use Class D1) are vital contributors to the local economy and yet there is nothing in the Strategy document to acknowledge this factor and no reference to the need to ensure that existing social infrastructure and services will be supported and encouraged through the planning system.

In this respect, the consultation strategy discusses the need (at some length) for developers to provide new infrastructure as part of larger new development allocations but it is largely silent on the need to improve, enhance, and support existing community infrastructure and service provision at the local level (e.g. existing schools, health facilities, community uses etc). Such uses are important sources of job and wealth creation in their own right. Such uses may need to significantly expand or relocate during the Plan period in order to improve their service provision and/or meet necessary statutory standards. What view does the Council have on this? It is silent on these points.

Whilst we fully acknowledge that new large-scale development should mitigate the impacts of the local community, we note that the consultation document is also largely silent on the critical issue of financial viability and the absolute need to ensure that development is not discouraged with the excessive burdens of financial and other obligations (in line with advice contained in the NPPF).

I trust that these representations will be considered carefully and brought to the attention of Members.
Should you wish to discuss the contents of this letter in more detail please contact me direct.

I wholeheartedly agree with the ambition of making WD "a great place to live, work and visit" but I am not convinced that this Local Plan addresses the issues in such a way as to achieve that vision.
I therefore wish to raise my concerns regarding the new local plan. I am extremely conscious of the position WDC finds itself in but am very worried that this solution is driven by an urgent need for a strategy in the face of developer pressure against the backdrop of the NPPF.

1. Assumptions

I am not convinced by the ONS's forecasts for population. There should be a forecast for 2030 and another for 2050. Most economists agree that UK population will start to fall away mid-century.
There are only 4 options presented and each is exclusive of the other; there are no options presented which are simple or complex hybrids. This is narrowing the choice unnecessarily when a hybrid plan may present the best compromise / optimum mix for all.
The options do not fully consider the needs across district or borough boundaries. The RSS Core strategy in 2007-10 looked at the wider picture and sought to find regional, more balanced solutions. By looking at numbers individually by District or Borough, our choice of options is dramatically reduced and does not consider the impacts on surrounding areas. These artificial political and authority boundaries are not considered by business or residents. As a parallel, in the past Fire Services looked only at the provision of service within a County boundary...clearly this is inappropriate when best planning a reactive service, particularly in rural areas, to avoid duplication eg N Warks / Sth Leics.

I see that there is now a Joint SHMA following the intervention of the Planning Inspectorate. Surely a Local Plan cannot be fully considered through consultation until this has met and made broader, more fully fledged proposals that meet the needs of the wider area and so avoiding duplication and ensuring more joined-up thinking? And what is the "new information" that has come to light?

Finally, when the Plan refers to 'Sustainable Communities', what is is meant by this? Very seriously, a definition is required to know what is being spoken of. Does it mean a community feeding itself, travelling within its own confines, providing its own energy and water needs? Please provide.

2 Housing

The primary determinant for the preferred option seems to be to avoid building on the Green Belt even though elsewhere WDC and Coventry CC will allow industrial development on the Green Belt. This is surely not a principle. Whatever guides the decision-making should be consistent and coherent. If one is permissible, then so should the other.

The notion of the primary employment site being planned at Baginton / Coventry Airport whilst 70% of new housing is proposed south of Warwick and Leamington doesn't seem to make sense

And "The apportionment of housing was guided by the principle of....avoidance of coalescence of settlements". The option proposed for suburban peripheral development to Warwick and Leamington would guarantee that the two in fact would become symbiotic twins with no green buffer separating them.

I would like to have seen a 'HYBRID 5' option being proposed that included elements of options 2, 3 and 4.
I believe in particular that the development of a new town, in the mould of the Eco-Town once proposed near Ettington a few years ago, in South-central Warwickshire would be the best solution to our collective needs. Sites such as the former Royal Engineers depot at Long Marston would have been perfect. I also believe that further expansion of Southam would make sense regionally.
Other villages such as Leek Wootton and Hatton should be expanded more than proposed given a) their size, b) their available land c) their current lack of village services and d) their proximity to the A46 corridor and Warwick and Warwick Parkway train stations. Hatton currently has next to no services and amenities: how was it allowed to be so?

Despite the huge impact on the area, the matter of HMOs and students seems to get little coverage or perhaps I have missed something in the documents. Given the sale of the issue, the Local Plan should address how in future it expects to balance the town between long-term residents and students etc. I would advocate more block development and place a moratorium on the conversion of existing housing stock: there has been a great surge in the number of terraced houses converting to student occupancy which has reduced the availability for young home-makers and families. Surely this is placing an additional burden on the housing shortage being faced in Warwick District. I would urge that WDC considers the conversion of Riverside House and the Fire Station to student blocks with the Council retaining 51% ownership of the sites for future revenue generation.

3. Economic considerations and Employment

I cannot see where in the document it speaks of the additional employment lands other than at the Gateway site.

In fact, worse still, the mention of a Reduction in employment land on industrial estates in Sydenham, Cape Road, Montague and Common Lane would be to the detriment of low skilled work forces throughout the area. Currently such workers are able to walk / cycle to work. this will not be the case in the future as these sites are sold off for housing. By insisting on maintaining the land as industrial, the land value will fall and then become viable for future industrial use; if the land value rises then this will be impossible in future.

The document speaks of " a need to provide new employment land in and around the District's main towns to meet local needs and encourage the creation of new jobs". Completely agree with this but have serious reservations about the viability and robustness of the Gateway project to deliver the number and quality of employment it is promising. In fact, the notion of a business park by the airport would suggest that this is really a giant logistics park by stealth when the former Ryton car plant site is a ready made brownfield location for such business. If I recall, such an application was made some years ago but turned down by Rugby BC. Using Green Field and Greenbelt land to provide such business seems wrong on all counts therefore.

I do not see how the expansion of the Warwick Technology Park is going to help low-skilled workers find jobs. It does not make sense.

Further, the document details the need to "support the rural economy"; this is really important but only touched on. The entire viability of villages is threatened in future with the withdrawal of services from them (the closure of post offices / pubs, small village stores, even primary schools etc..)

4. Infrastructure

The document speaks of an emphasis on infrastructure - "the development of sustainable communities with strong local centres / and or community hubs". As above, the rural economy is very fragile and villages need greater support if they are to remain viable. Rural bus services will become more and more threatened unless the villages served have sufficient mass.

I don't understand how having the major employment site to the north of the district and the housing tithe south will not lead to massive congestion in the town centres of Warwick and Leamington. This does not make sense.

5. Sustainable

See point 1) above. To re-iterate, what is really meant by sustainable communities. It is important to be clear on this point to avoid accusations of 'Greenwash', but it is similarly important to ensure the best, most durable and sustainable communities are created, it just for 2029 but for 50-100 years from now.

The coalescence of Warwick and Leamington does not seem to support a better environment.
The document states that "..ensuring new development is based on principles of sustainable Garden Towns, suburbs and villages" is key however it is not fully explained how this may be achieved. Urban centres have an optimum mass but this is not explored. Likewise, their interdependence is not explained; creating an hierarchy of primary and secondary villages is welcome but this needs to be examined in depth as to implications for the main settlements.

Section 3.4 para 17 talks of contributing to conserving the environment by "....reducing pollution" yet this is not supported with any evidence or data. The development of south Warwick and Leamington would surely have quite the opposite effect.

The document speaks of "caring for our built, cultural and national heritage" which is laudable and right. But the strain on Warwick and Leamington town centres by the addict all 'peripheral residential development would be at odds with this aim.

There is no reference to Building Regulations or the greatest ambition of all, namely, to build 'Passivhaus' dwellings for all new developments between now and 2029. It is possible and should be our goal.
Cycle routes are mentioned only on passing. They should be a key factor in new transport planning to / from town centres and stations / transport hubs.

In summary I have major reservations about this Plan. It appears fundamentally flawed in its assumptions, its siting of housing and its assumptions for employment in the north of the District and not in the south. Foremost, I have grave concerns about the lack of infrastructure, in particular for roads and transport in general to support such number sof homes around the periphery of Warwick and Leamington.
These two towns are very unusual in that they have three barrier to the passage of people and traffic. From north to south and vice versa: a railway, a river and a canal. As such, in Leamington, there are just three narrow single carriageway routes joining the two halves. They will not be able to support any increase in traffic. And in Warwick their is the medieval town and castle to navigate around. What is already a nightmare for pollution will only become worse.

This is not a plan to deliver "Sustainable Communities and Development".

I urge you to reconsider urgently before these towns are forever destroyed by the short-termism forced on WD by developers and the NPPF and the Localism Bill.

I am writing to object to the draft Local Plan that has been proposed by Warwick District Council on the following grounds:

The estimates for the demand for new houses are based on very unclear evidence and assumptions. Many other districts make some attempt to justify their housing demands based not only on the change in demographics but more importantly the estimates for growth in employment in the area (and what the plans will do to stimulate that growth). The Revised Development Strategy adopts an interim level of growth of 12300 homes between 2011-29, and quotes various studies but there is no hard evidence in the document to substantiate the huge growth contained within the estimate.
To get an idea of the scale of the demand, I drove around Warwick Gates with its own community centre, health centre, and shops serving around 1500 houses. This is a big development. The local plan estimates the Warwick District will need the equivalent of 8 x Warwick Gates to satisfy the housing demand. We need some hard evidence to substantiate that scale of development!
The National Planning Policy Framework specifically states that councils should take into account neighbouring schemes and yet no mention is made of the proposals by Stratford District Council to build a new 'village' of 4500 homes near Gaydon, which would be nearer to Warwick than Stratford. This is another 3 x Warwick Gates. There must be some overlap in the assumptions made for the demand in such a small area and the plan should not proceed until that demand is justified by realistic assumptions.

The plan defines the location for about 6000 of these homes. It proposes to put the vast majority ( nearly 3 x Warwick Gates ) in a small area south of the Warwick. The rationale for the location of the major developments in this area seems to be that the Green Belt protects development elsewhere in the county. When the Green Belt land was established, north of the towns of Warwick and Leamington, it was intended to stop urban sprawl. There is no difference in practical terms between the 'green' land to the north of the district and the south of the district. They are both green and they both should be protected from urban sprawl. The council has the powers to use the Green Belt land for development and not use it as an excuse to condense all future development into a small area south of Warwick.

The subject of transport is the most baffling part of the plan. We live on Myton Road and we chose to live there because of the difficulties of commuting to the centre of the town. Everyone who has to get into or through Warwick knows of the huge traffic problems around the town. The proposed infrastructure improvements seem to ignore the fact there will always be 'pinch points' where roads cross the river. These cannot be overcome by improvements to junctions and dual carriageways. There will be much more congestion as a result of the proposed massive increase in housing in the area (11 x Warwick Gates ). The house occupants will be reliant on cars, usually with more than one car per family. There has been no clear data ( from traffic simulations ) to show the effect on traffic congestion in the area. It is not realistic to estimate an increase of over 12000 homes ( most of which will be in the area south of Warwick ) and have an infrastructure plan which simply improves traffic junctions. This is not a sound basis of a sensible plan for a town that is already experiencing huge traffic problems.

Warwick already has air quality issues, which will be exacerbated with the increase in pollution caused by the introduction of additional large numbers of cars crawling through the streets of the town. The residents of Warwick should not be exposed to this additional risk and the school children of Warwick School and Myton School rely on sensible adults to protect them.

The demands on the infrastructure for schools and hospitals will greatly increase. In particular, the demands on Warwick Hospital have not been adequately assessed. This is a relatively small hospital just about coping with the needs of the current population. Add 8 x Warwick Gates (plus the likely effect of the Gaydon 'village' - 3 x Warwick Gates) and it is clear that the demands will exceed the capacity of the hospital to cope with the increased population.

In summary, this is not a plan that shows how Warwick District will grow and change over the coming years. It is simply a charter for house developers. The demands for housing are speculative and excessive. They have no declared employment projections and no mention of the effects of adjoining developments in Gaydon. The concentration of development into one area conveniently relies on green belt rules, which could be easily overcome. The effects on Warwick in terms of traffic, pollution and health are not adequately addressed and I hope that the plan will be reconsidered before we go down a route, which will ruin such a beautiful town. As a newcomer, my sense is that the outrage shown by the people of Warwick is not a NIMBY reaction but a genuine desire to oppose a plan, which would have such an adverse affect on their town. The Council's stated vision is 'to make Warwick District a Great Place to Live, Work and Visit'. It is inconceivable that this plan can fulfil that vision and the plan should be rethought, involving the people of the district to satisfy that vision.

We are attaching our objection to the Warwick District Council Local Plan Revised Development Strategy published in June 2013.

We are also forwarding a copy of our objection to Chris White MP.

The objection applies to two addresses in Warwick as we currently live at 172 Emscote Road and will shortly be moving to 50 Myton Crescent.

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.

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I refer to the Revised Development Strategy for the Local Plan and write to register my objection to the proposed development of land to the south of Warwick as follows:

Introduction
It is noted that in the Introduction reference is made in para 1.2 to "the need to take in to account what our neighbours and partners are planning to do over the next 15 years."

The Revised Development Strategy appears to completely fail to take in to account the proposal by Stratford on Avon District Council to build 4800 houses at Gaydon/Lighthorne. The effect on Warwick and Leamington Spa of such proposal will be immense in respect of increased traffic, pollution and use of the hospital and other amenities. Such an increase must be taken in to account in preparation of the Local Plan, as it will impact on the local infrastructure.

Para 1.3 refers to "some work regarding the evidence base to support the final proposal for the Local Plan is on going."

We have not been advised as to the nature of the evidence that is not yet available. It is noted that no reference is made to the Environment Agency and the undoubted problem that the area has in respect of flooding. At the present time the Environment Agency places the postcode in which I reside as "moderate risk." What impact is anticipated if the proposals contained in the Revised Development Strategy are implemented? The last Flood Report obtained by the Council appears to have been undertaken in 2008. Since then the country has been subjected to the highest recorded levels of rainfall. The fields upon which the proposed homes are to be built remained water logged for several weeks after the winter storms and absorbed rainfall, which would otherwise have come down in to Warwick. Has there been/will there be any report prepared based on the proposal to build on such a large site situated south of the River Avon and on high ground? Will the District Council provide a flood plan and appropriate compensation should the need arise?

How can a plan be formulated when not all the relevant evidence is available? Surely no decisions should be made until the Strategic Housing Market Assessment has been made, and this would appear to be the view of the Inspector appointed to review Coventry Council's Core Strategy. It is disputed that number of homes proposed are actually required, and there is a suspicion that the wishes of the Developers is being put before actual need.

At the present time it is understood that homes are required to accommodate the proposed employees at the Gateway Project close to Coventry Airport at Bagington. Situating housing for those employees on the other side of Leamington and Warwick, two established and historic towns with existing traffic problems, is totally inappropriate. If the Government's wish to reduce car usage and pollution are to have any credence then the housing should be situated closer to the Gateway Project site.

Para 1.4 confirms that not all topics are included and it is sincerely hoped that no decisions will be made until all the evidence is available.

The Local Plan and Consultation
The issues referred to in respect of process are noted. There is however considerable concern locally that there is now a degree of 'panic' by the District Council as they have radically changed the proposed areas for development from the Preferred Options consultation. There appears to have been a failure to consider changes to the greenbelt to enable the obvious and more appropriate development to the north of Leamington Spa. Whilst the earlier proposal of development to the south of Warwick was not welcomed, the massive increase now proposed appears to be an attempt to do something, indeed anything, even if it is wholly inappropriate. It has is also unfair to the local community, who have now been presented with a significantly increased area of proposed development with only just over six weeks (in the holiday period) to respond.

Strategic Vision
Although certain paragraphs have been included in the Revised Development Strategy that are referred to in the Sustainable Community Strategy, the document itself refers to "A shared vision", and refers at length to the different local groups/agencies with whom it proposes to consult. However, it is clear from the District Council's own research that the local community were hardly aware of the Preferred Options Consultation yet alone the Revised Development Strategy. We are further advised that all Warwick Town Councillors and the two representatives on the District Council have unanimously opposed the proposed development south of Warwick. How then is the proposal to build south of Warwick "a shared vision"?

Page 16 of the Housing Strategic Aim refers to issues including "working closely with Community forums/neighbourhood groups..." and yet the District Councillors responsible for planning have been unavailable to attend meetings with concerned residents.

Level of Housing Growth
Until the Joint Strategic Housing Market Assessment with neighbouring authorities has been completed, such a large development south of Warwick should not even be contemplated. The figures the Council intend to rely upon in the interim are not accepted and cannot be until the Gateway Project has been finalised.

It has been noted that the Chase Meadow development in Warwick had not yet been completed and again, no reference is contained in the Revised Strategy to the planned development at Gaydon/Lighthorne.


Broad Location of Development: Housing
The concerns raised in para 4.3.3 remain, and have not been answered by the additional research. Indeed, RMA Consultants recommend in relation to the land south of Gallows Hill and The Asps that "...this area should be protected from development."

The Council's own research in to local issues confirm that traffic and environmental pollution are of concern. The Strategic Transport Plan does not address those issues. The plan for four lanes of traffic along Banbury Road will not produce a solution to the two lanes available over the Bridge. Myton Road is already acknowledged to have excess traffic and the location of two schools in the road will make any increase in traffic extremely dangerous. The same applies in respect of additional traffic funnelled through the centre of Warwick. The existing level of traffic and the delays caused are of grave concern to the residents and inappropriate in a town containing historic buildings. The proposed plans seem to completely ignore the issue of Conservation Areas.

If Warwick is subject to an even greater level of traffic it is inevitable that the existing pavements will have to be reduced in size and safely barriers will have to be constructed. To ignore the location of the schools in the centre of Warwick is to ignore obvious safety issues. Will visitors wish to come to Warwick when it is no longer safe to walk, and pollution levels make it unpleasant and dangerous to do so?

The Overview of Development - Map 2 indicates the completely disproportionate level of building proposed to the south of Warwick. The infrastructure will not be able to cope. The Council refer to 'mitigating' the effects of traffic, but the proposals to do so are totally inadequate. The same applies to their response to the concerns for the historic centre of Warwick and the environmental impact.

I regret that I have not been able to respond in detail to all of the documents referred to on the Council website as the requirement to register my objection on time has been my primary concern. I am however deeply troubled by the Council's approach to earlier concerns raised, and the implications for opposition to the Revised Development Strategy in that problems with infrastructure, environment, traffic, pollution etc appear to have been dismissed with the term "this will be mitigated." There are no solutions to a plan, which places a disproportionately large development on the wrong side of a river, with increased levels of traffic passing through an historic town with inadequate roads and infrastructure to cope.

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The proposed site allocations for the new Local Plan result in an overall imperative to ensure that policing infrastructure expands proportionally with the delivery of new development growth, in order to ensure the continued delivery of policing services to a significantly growing population. Warwickshire Police expresses no preference amongst the growth options presented, but there are a number of observations to make about the new Local Plan that will be vital to helping us work in partnership with the Council and applicants to deliver required policing services into the future.

Observations
Strategic Vision: This currently makes no reference at all to the need to ensure safe, secure and low crime communities and places are created and maintained in Warwick District. This is at odds with paragraphs 58 and 69 of the National Planning Policy Framework (NPPF) and the Council's forthcoming Sustainable Community Strategy, described at paragraph 3.6 of the Local Plan. Unless this is addressed, support for the infrastructure and design measures necessary to create and sustain such places and communities is critically undermined.

Section 3 makes a number of references to the importance of sustainability. Low crime & disorder is vital aspect of sustainability, as stated above, which must be included in any definition or statement regarding this term.

Revised Development Strategy: Please see the enclosed representations, prepared by consultants Boughton Butler LLP, regarding this topic.

Strategic Development Sites and Infrastructure: All of the strategic development sites detailed in the Local Plan will require the proportional growth of police infrastructures to maintain equivalent levels of service in the areas concerned. However, the police service does not receive funding to cater for the infrastructure needs and associated costs that come with the delivery of development and associated population growth. This is because with population growth there is a corresponding increase in crime and the number of incidents requiring a police response. This places demands not just on the 'front line', but on the whole spectrum of support and specialist police services, e.g. forensics, roads policing or armed response team to name but a small number, that will be called upon during the lifetime of a development.

Further, policing is a countywide, regional and national service and it is not practical or sustainable to develop an infrastructure on a piecemeal basis. The recognition (such as in paragraph 5.1.14) that cumulative impacts must be planned for at the strategic level is vital to achieving the most effective infrastructure, both for individual agencies and for joint agency partnership working and shared services is consequently a very welcome inclusion and represents a big step forward in the provision of cohesive public service infrastructure, including policing.

We therefore request that the Local Plan includes specific policy recognition of the need for additional police infrastructures in relation to strategic and other development sites. We intend to provide details on the precise infrastructure required as work on the Council's Infrastructure Delivery Plan progresses over the course of this year.

Secured by Design - Strategic Development Sites and Infrastructures - Housing Mix: The Lifetime Homes standards include safety in terms of both traffic and crime. It should therefore be a requirement that all homes should be designed and built to the Association of Chief Police Officers (ACPO) Secured By Design accredited standard. Also, achieving the best possible traffic safety of any new roads development should involve consultation with the Warwickshire Police Road Safety Unit.

5.1.27: Highlights the potential for 12,300 new homes in Warwick District. This represents an increase of approximately 23% increase in the District and approximately 5.4% increase in Warwickshire as a whole. It is logical to conclude that this will lead to a proportional increase in demand to policing services. This is in addition to significant housing growth elsewhere in the Warwickshire policing area. Accordingly, the Warwickshire Police infrastructure will require expansion in response to the planned housing and other development growth in Warwick District.

Whilst this will not, in most cases, lead to the visible structures of new police stations, there remains a fundamental requirement to provision expanded infrastructure capability in policing through mobility (police vehicles), communications (radio systems and IT infrastructure), support functions (crime recording, strategic planning, judicial services, HR, Finance, Fleet Management, Estates and others). Wherever possible these will be developed in partnership with other agencies, and should be a core component of CIL planning.

Map 4: Whitnash and south of Sydenham: There is a potential need for a neighbourhood policing base within the housing developments proposed for the South of Warwickshire & Witnash. Ideally this will be a shared facility operated in partnership with other public service agencies.

Conclusion
The Warwick District Local Plan Revised Development Strategy presents police infrastructure and Secured by Design considerations that need to be addressed. The significant growth in housing, employment and population also requires continued engagement between the Council and Warwickshire Police in infrastructure planning and CIL scheduling to ensure proportional provision of flexible police infrastructure into the future.

This is an objection to the Local Plan on the grounds that the public's wishes as reported in the Final Report of Public Consultation (published December 2011) very much seem to have been disregarded in the Local Plan Revised Development Strategy (published June 2013).

Appendix 5 in the Final Report of Public Consultation (page 63) shows that:

a) 54% of the public respondents advocate LOW LEVELS of development or growth in our part of leafy Warwickshire with all farming land protected.

b) 31% say that NEITHER LOW LEVELS NOR HIGH LEVELS of development in our leafy Warwickshire are acceptable. Only a LIMITED LEVEL of development is acceptable.

c) Only 15% say that HIGH LEVELS of growth of services and facilities are required to support a growing population in our leafy part of Warwickshire.

The message behind these three percentages is partly concealed because the (incorrect?) percentages are separately presented on page 64. The wording seems to conceal the real meaning of the Scenario 3 which is that high levels of population growth will demand a proportionately high level of growth in services and facilities. So only 15% of respondents want a high population growth.

Why then does the Local Plan Revised Development Strategy expound on an intention to build 12,300 new homes? The consultation process shows that the public does not want it. Such a HIGH LEVEL of growth would result in a high level increase in road congestion and air pollution - a staggering 78% of respondents agree that this is an important issue.

I object to the Local Plan Revised Development Strategy because it does not seem to have been developed from public consultation. In Paragraph 1.2, WDC considers it important that the Local Plan revised development strategy will "deliver the Council's Vision for the District". The idea of consultation is generally recognized as a bringing together of visions from residents, voters, elected representatives and district councils alike. A declaration by WDC that it will deliver the Council's Vision for the district is not in keeping with what I understand to be consultation and I therefore object to the whole document.
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We have been advised to write to you regarding objections to the Revised Development Strategy Local Plan. Having studied documentation and attended meetings I wish to object to the overall plan to build the number of new homes suggested in Warwick district and in particular the 3420 planned in the south of Warwick (zone 6).

The whole basis for the homes is population growth nationally. The amount of employment land within the plan would not fulfil the amount of local unemployment and create enough for the amount of housing proposed. Imposing massive growth on an area with little expansion of employment would create greater numbers of people who would have to commute to work, much to the detriment of the area and a poor location of people.

Warwick District has already seen much development over recent years, much of it to accommodate those moving from the urban areas of Coventry and Birmingham into a less dense area. Many of those still commute into Birmingham or London and if people are prepared to work in London and commute from the Warwick district this will do nothing to help keep the prices affordable for the locals who want to continue living here.

I have lived in Warwick most of my life and still live at home with my parents. I would like to continue to be able to live in the area with my own family in the future and for my children to have green fields around them and affordable homes, not to be surrounded by and urban sprawl of commuters.

Warwick District population has in fact increased by 12% since 2000, which is approximately 2x the rate of increase for Warwickshire; 2x the national average increase, and over 3x the increase for West Midlands.

Warwick has therefore already been subject to significant recent Urban Fringe development and population expansion, a large proportion being at Warwick Gates which is in South Warwick where the majority of further development is now proposed.

By only building the amount of houses currently required for Warwick district this will discourage migration from other areas as has happened with past developments.

As it stands, I wish to object specifically about the development zone 6 in the area of restraint to the west of Europa Way. This area was identified as an area of restraint at the time of the agreement of planning for the Warwick Technology Park. It was put forward as an


untouchable green buffer zone to separate Warwick from Leamington Spa, to prevent the two towns becoming one urban sprawl.

There is likely to be considerable job creation towards Coventry, including up to 14,000 new jobs speculated at the Coventry Gateway scheme. Therefore several extra thousand people per day will want to drive through Warwick, morning and evening, which would lock up the highly congested Myton Road, Banbury Road and Europa Way at peak times and also the road layout of historic Warwick.

The suggested improvement to the junction to the end of Myton Road and Banbury Road is redundant. The bottle neck of the narrow historic Avon Bridge, constrained road layout and traffic calming in the Town centre, means such provision would not ease the current backlog along Myton Road at peak times.

The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and onto the M40 will have the opposite effect at the eastern end of Myton Road. The alterations made to the roundabout with the addition of Morrisons has made some current improvement but will not be able to handle the extra traffic created by the number of dwellings proposed for zone 6.

Development of this particular site will have a profound impact on the area where the roads are already gridlocked for a considerable period every day during school term, not to mention the excessive pollution that would be caused. It is currently possible to queue from the M40 into Leamington and the length of Myton Road in both directions with queues heading down the Banbury Road and Gallows Hill. Narrow side roads off Myton Road, in particular Myton Crescent, are blocked by parking making it difficult to negotiate these roads as the schools come out.

There is no capacity on these roads for another 2-3000 cars to exit from this triangle at peak times and join the current traffic load plus, extra traffic from other proposed developments needing to use these routes at peak times. The access to Warwick and Leamington from the site would be queued back even at a fraction of the proposed development.

There is no capacity for extra cars at the stations in either Leamington or Warwick town centres for commuters. This means additional traffic driving through Warwick at peak times to Warwick Parkway.

Furthermore, the land West of Europa Way, the area of restraint, is an area of rich agricultural land which has been under the careful stewardship of the Oken and Henry VIII Trusts. There are wide green hedges providing habitats for many species including woodpeckers, buzzards, bats, foxes, the occasional deer, as well as newts, hedgehogs etc.

This is the type of area that should be being protected for recreation and education and healthy food to have a positive impact on the quality of people's lives with the traditional land-based activities such as agriculture, new tourism, leisure and recreational opportunities that require a countryside location. By building dwellings on this land, we will have no countryside left in the urban areas to make use of to support healthy lifestyles through ensuring sufficient land is made available to all for play, sport and recreation without travelling out of the area.

I ask, is developing the ASR a sustainable development? "Much rubbish is talked about sustainability, usually by developers. It does not mean that estates are built near to a bus stop or a primary school or a doctor's surgery; this is just moderately intelligent planning. To get to the correct definition it is necessary to go back to the source of the concept of sustainability which was the United Nations commission chaired by the Norwegian Prime Minister Gro Harlem Brundtland in the 1980s. This said that sustainable development is that which meets the needs of the present without compromising the

ability of future generations to meet their own needs; in more simple terms it means that we should not destroy something which future generations would find valuable." (www.stortfordcf.org.uk)

Surely if all this land is built on to the south there will be nowhere that the future generations can use in Warwick for recreation other than St Nicholas Park. If the land was made into recreational use, as it was designated to be, that would serve not only our generation but those of the future too.

Development on the area of restraint threatens the local houses with flooding. At present, during heavy rain, the runoff is slowed by the pasture and crops. It backs up by the Malins and is relieved into the Myton School playing fields. At these times both ends of Myton Crescent become flooded with the current drainage system being unable to cope.

Property in Myton Crescent was flooded when development was carried out on the Trinity School site. Developing the Myton side of the site would threaten all of the houses south of Myton Road.

The most disturbing consequence of the proposed development of zone 6 is the danger to Public Health as a result of exposure to dangerously high Nitrogen Dioxide (N02) levels. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. In 2012, air quality remained in breach of these regulations, and will become toxically high with the increased traffic volume resulting from the Local Plan preferred options. Please see weblink: http://aqma.defra.gov.uk/action-plans/WDC%20AQAP%202008.pdf and particularly page 17:

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape, geology, cultural heritage and material assets must be thoroughly assessed, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. All assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

It was pointed out at a public meeting in 2009 that part of this area may not be needed for development in the future but we learnt at the recent Warwick Forum that 2,000 homes planned for Milverton had been transferred to zone 6, the worst area for infrastructural needs and more importantly the area of restraint.

This should, with immediate effect, be designated as the last site to be developed so as to protect this area until a viable alternative is found.

The further urban fringe development of Warwick is unsustainable with respect to saturated infrastructure, constrained historic town layout, and the existing Public Health danger that exists today as a consequence of high traffic volume.

Current infrastructure including town centre rail stations, schools, GP surgeries, sewage, water, drainage are at capacity with the current population, and will not sustain the proposed increased numbers within the proposed site at zone 6.

Numbers have reduced drastically in schools over the years with those such as Trinity and North Leamington moving to smaller sites and a number of primary schools having given over part of their accommodation for other uses, many having been 3 form entry 30 years ago now down to 1 form


entry, whilst village schools have closed completely. This means that the schools in this area are oversubscribed, including Myton into whose catchment area the whole of that site would fall.

There are suggestions that schools would be expanded or new builds created but a new primary school was in the plans for Warwick Gates which never came into fruition.

Warwick hospital is completely surrounded by housing and has no capacity for expansion so how will they cope with another 25,000 people based on the figures of 2007 with 71% in a traditional family set up with 1.8 children.

Why do district councils have to accommodate a certain amount of housing? Should the government not just be looking for appropriate sites for building? At that same meeting in 2009 the suggestion of a perfect site around Gaydon was mentioned for a new town but the response was "It's not in Warwick District". Not only would road improvement be possible where air quality is not already in breach of regulation but this site is perfect for links to the M40 and there is also a rail station already at Kings Sutton on the main Birmingham to London line so commuting traffic would not be funnelled through Warwick's congested urban centre. To build one whole new site would be more cost effective in the long run.

Stratford District have now put this area forward as part of their Local Plan. Can District Councils not communicate with each other? To have this large area developed as well as the south of Warwick District will create even more stress on the road structure towards Warwick.

There is also the possibility of more use being made of the land around Warwick Parkway, which is in Warwick District and again perfect for rail and road links to both Birmingham and London.

So what can be done to accommodate the Local Plan?

How about looking at sites already within the towns and regeneration areas? The infrastructure is already in place and could take out a large number of the dwellings required. I know this would not be chosen as great big swathes are cheapest but not necessarily the best option.

Build student accommodation near Warwick University in Coventry and reclaim the hundreds of dwellings (including Station House, Union Court, Chapel Cross and The George) in the South Town of Leamington to private affordable starter flats, homes and family homes.

Villages could be given their communities back - expand them with affordable housing. Let those that grew up in the villages and wish to remain there, stay there. Let them support the village schools and shops, some of which have closed over the past few years due to lack of numbers or use.

Warwick District Council's original Strategy to 2026 stated that 90% of the population live in the urban areas and 10% in rural areas. The 90% of the district's population currently living in the urban areas occupy 10% of the district's land whilst the other 10% of the area's population live within the remaining 90% of the land.

The Core Strategy stated that there should be limited development within and adjoining villages so that they can be protected and the character of the villages kept. This is also the case within the towns. It is not that long ago that Whitnash was a village but is now a town along with Leamington, Warwick and Kenilworth. These towns want to remain separate towns. They do not want to become joined and eventually become part of Coventry as the way Edgebaston, Hall Green, Moseley and Sparkhill are to Birmingham.



According to http://warwickdc.jdi-consult.net/ldf/readdoc.php?docid=15&chapter=4 the Preferred Vision for Warwick District to 2026 will be

"Warwick District in 2026 will be renowned for being:
1. A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands, that have developed and grown in a way which has protected their individual characteristics and identities, contributed towards creating high quality safe environments with

low levels of waste and pollution, and made a meaningful contribution to addressing the causes and potential impacts of climate change;"

If this building work is allowed to go ahead as it stands, it will be far from that.

The Core Strategy also pointed out that the development should be directed towards the south of the urban area and this has been carried forward into the Local Plan apparently to avoid incursion into the West Midlands Green Belt area and hence becoming part of Coventry. What this is in fact doing is encouraging the joining of the towns of Leamington, Warwick and Whitnash, making it one urban sprawl.

If Green Belt land was taken to the north of Leamington and south of Kenilworth, to the east and west, to build the bulk of the houses required for Warwick District and included a supermarket for the residents of north Leamington, Lillington and Cubbington this would alleviate the need for them to travel to the south of Leamington or Warwick to shop and would not cause incursion into the West Midlands and Coventry or encroach on the current residents of those areas.

This Green Belt land could then be reclaimed to the south of Warwick and Whitnash and residents of the new dwellings would be a more central position for employment in Warwick, Leamington, Kenilworth and Coventry.

I urge Warwick District Council to revise the whole plan taking into consideration the views of the residents of Warwick, not allowing any further planning applications to be passed on land within the Local Plan until it is fully agreed and finally to consider the overwhelming number of objections received from Warwick residents at previous consultations.

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1. First of all, I want to register my agreement with the proposed plan in principal which was discussed at the meeting - I agree that there were no exceptional circumstances which would allow for the inclusion of the green belt land to the North of Leamington Spa to be used for building purposes.

2. Queries:

2.1 With regard to the sites for gypsies and travellers, how does the Council propose to deal with the management and maintenance of the sites, collection of rent etc from the gypsies and travellers who will be using the sites.

2.2 As I understand that it is proposed that some of these sites might be allowing for permanent or semi-permanent sites for the gypsies and travellers and that schools, doctors etc. should be accessible to these sites, how is it proposed that the gypsies/travellers will be contributing to the cost of providing schooling etc. in the form of council tax and how will that be collected?

2.3 If it is the Council's intention for these sites to be used rent free/council tax free by gypsies/travellers, please explain to me why they should be allowed to have the use of these facilities (paid for by the local taxpayers) free of charge.

2.4 In response to one of the questions raised at the Forum, the Council representative said that the Council has no say in how the builders will develop the sites and what they will build on them. This caused some consternation and confusion because of the following:

(a) of course the Council has to consider any planning applications and plans put forward by the builders and therefore has a significant power to agree, disagree or amend such plans;

(b) in the years before the slump in the housing market, a great deal of flats were either purpose-built or converted out of the old Victorian/Edwardian buildings - these were in the main bought by investors for rental purposes and there is a significant number of students as a result based in Leamington Spa/Warwick. In light of this there was general agreement in the room that amongst the properties to be built, the requisite proportion of affordable housing should not take the form of flats but should be freehold properties with a minimum of two bedrooms and with a garden. It was therefore disturbing when the Council representative indicated that the Council has no say in what the builders build.

(c) There was concern that in light of the current difficulties in first time buyers (or indeed generally) obtaining mortgage funds, there was a risk that a significant number the houses which are to be built might be bought by corporate or private investors (as they have easy access to funds) for rental purposes which could start another building boom and result in an increase in house prices to the continuing detriment of first time buyers. The question I wished to raise was what steps the Council might consider taking to ensure this could be avoided e.g. by requiring the builders to come up with a scheme to help finance the sale to first time buyers and perhaps take steps to discourage builders to sell houses en masse to investors i.e. require any buyer to be the owner/occupier of the houses.

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I have responded to the consultation using the log in facility on your website but also want to email with additional comments.

I am in agreement with the locations identified in the new plan.

I strongly believe that there are no exceptional circumstances for building on green belt land to the north of Leamington as originally proposed and am pleased that this has been recognised in the new plan. I also urge the Council to ensure that this is not sacrificed if the result of the additional joint SHMA with Coventry City Council shows there is a need to build more homes in the District.

Another issue I wanted to raise is the quality of the new build. Developers are in it for profits and are answerable to their shareholders. This is a fantastic opportunity to build quality, well designed homes achieving high levels of energy efficiency i.e. Passiv housing or close to this level. What say will the public have in this? Previous build in recent years have, to say the least, been dull viz Tournament Fields and Warwick Gates. The developers will say they build what people want but the reality is we have a massive need and they can build what they want knowing it will be sold. This is a blank canvas and an opportunity to make a real statement and urge you to ensure high quality.

Will there also be land made available for self build as this will ensure people are able to design their own homes. Austria is a prime example of success doing this where quality of build is years ahead of the UK and 80% of homes are self build (info on this available on BBC website at http://www.bbc.co.uk/news/magazine-14125196).

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1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

1 & 2 Introduction / Consultation Process
Right now the District is in an uncomfortable position, with limited powers to exercise priorities, before a new Local Plan is in place. Progress towards that Plan is crucial but the Plan will be of little benefit unless it sets clear and specific criteria for shaping the District's development. This statement of the obvious is made because we seek firmer guidelines for development within the Plan period.
The Leamington Society has previously made strong representations about PO10: Built Environment and we note that in the current Strategic Vision text there is more than one reference to "Garden towns, suburbs and villages". We therefore include this theme in our response (and did indeed 'phone to consult one of your officers on this point).
3 Strategic Vision

3.5 SOCIAL
Of the four bullet points, we particularly endorse point 2 :-
"Providing for diversity, including affordable homes, homes for the elderly and vulnerable and other specialised needs"
But the context of "diversity" should include specific reference to a wide range of dwellings to meet varied lifetime circumstances - beyond the limited special categories identified here.
We pick up this theme below, detailing our concern about the character of the suburban housing developments currently anticipated.
4 Housing
Formulating a core strategy in relation to housing provision is proving controversial. The headline feature of the revised strategy is to plan for very large suburban extensions to the south of Leamington and Warwick. It is evident that this has the potential seriously to aggravate existing traffic problems and will require considerable road works. Such works will be expensive and highly intrusive: they may mitigate the immediate local problem but will not prevent an increase in congestion and pollution around and within the adjoining towns.
There are three elements to this large increase in housing allocation: the total numbers, the proposed locations, and the character and density of the new developments.
THE NUMBERS
We note that half of the potential growth derives from predictions of inward migration to the District. These projections are fraught with uncertainty, as the ONS (Office of National Statistics) warns :-
"The projections are not forecasts and do not take any account of future government policies, changing economic circumstances or the capacity of an area to accommodate the change in population. They provide an indication of the future size and age structures of the population if recent demographic trends are continued. Population projections become increasingly uncertain the further they are carried forward, and particularly so for smaller geographic areas."
We have underlined the ONS phrase about capacity. There is a danger that the Local Plan confuses supply and demand. Building a lot of extra houses will attract immigrants to occupy them. This might appear to be meeting demand, but the demand is a response to supply and not the other way round.
ONS provide separate figures, for "natural" growth and for migration, only as far ahead as 2021. Beyond that there is simply an aggregrate projection, for the years 2021 - 2031. The latest projections are for just over 1000 extra people per year in the District. But the ONS systems round their figures to the nearest 1000, which could include any number between 501-1499. There is therefore a huge potential variation in the total as the annual figures accumulate over the Plan period for Warwick District.
This Society ventures no guesstimate on the projected District numbers, but we do not believe they can honestly be laid down as a certain evidence base for a plan to be set in concrete & brick over the next 15 years and more. Granted that there needs to be a working assumption, the NPPF also demands realism in plan making. In the longer run it is much more likely than not that the outcomes will depart from current projections. Good, realistic planning would provide flexibility to track progress during the plan period and criteria to respond appropriately.
Rather than simply being reactive to individual applications, the Plan should set a hierarchy of priorities towards achieving the District's housing needs, with sequential choice assigned to key objectives.
LOCATION
Warwick District has had difficulty in allocating housing locations for the large numbers anticipated. But even if an overall allocation of sites is set out as in this strategy document, there remains the question of how developers will respond. Understandably they will seek to cherry pick, in search of convenience and maximum profit. Any Plan worth the name will need to prioritise and hence respond to applications on a firm basis.
The mechanisms for setting and achieving effective priorities are no doubt technical. Various carrots and sticks are available but these will surely need to be driven by criteria set out in the Plan.
4.2 We are glad to note significant numbers allocated to urban sites, along with some consolidation from employment areas and a large allowance for windfall sites.
4.3 This starts with WDC preferred options on broad location, but lacks any emphasis on"Brownfield" sites.
We believe the plan needs a stated priority to re-use such land, driven by beneficial conditions as necessary. (See also NPPF para 17 Core Planning Principles, bullet point 8)
This group of POs ends with a bullet point on rural areas, focussing on larger villages We believe this is an appropriate allocation, to concentrate on villages which can best sustain local schools, shops and other services. This should encourage a younger rural population to stay. Also inevitably some migrants into Warwick District will choose a village location and they can best be accommodated in this way.
CHARACTER of new HOUSING DEVELOPMENTS
Given the total numbers, a key element of their location is the land requirement. In arriving at this far too little attention is given to the character of the proposed developments. If Warwick and Leamington had been built at the low, suburban densities envisaged under the plan strategy, they would sprawl over a far greater area of the Warwickshire countryside.
But this is not simply a matter of the amount of land needed. It also relates to diversity of housing need, to affordability, and to the viability of public transport.
Affordability
This is almost certainly the most challenging problem in shaping housing policy. The figures in terms of house prices and of market rents are stark. We supported the PO5 for 40% affordable housing in new developments. This is easier said than achieved : the District has to cope with market forces and is a small local cog driven by the machinery of national government.
5.1.4 "Provide 40% . . The nature of this affordable housing should be agreed with the Council as part of any planning applications"
This vague aspirational statement offers no guidance for negotiating such an agreement, no hint of the means to this end. Can this be a robust or reliable basis on which WDC will resist developer pressure to dilute or claim grounds for avoiding the 40% requirement ?
Affordability at 40 % will surely be dependent on design (not merely on financial engineering) and we doubt very much that this policy can be sustained without firmer guidance, perhaps through Design Codes (NPPF para 59).
Diversity
There is brief reference to size & number of bedrooms related to the SHMA and also mention of older people, (plus students and HIMOs,which are not required). But this seriously fails to address the diversity of varying accommodation requirements over modern lifetimes & social choices; it also entirely ignores the potential for an imaginative range of layout and architecture in addition to rows of houses and lawns.
This is not to denigrate a traditional house and a garden as a common choice of family property but it is simply unrealistic to assume that throughout our typically long and varied lives we are all or mostly living in unchanging families of parents with young children. Moreover that choice / assumption carries with it serious environmental and cost consequences. It appears that developers are most comfortable with this traditional layout. But the function of a local Plan is not simply to align with the "low hanging fruit" most attractive to developers: otherwise there would be no point in a Plan, just leave it all to the market.
We say that the District Plan should give a much stronger lead in challenging developers to come up with more ambitious and diverse designs for varied needs, including affordability.
Transport & Sustainability
The effectiveness of the WCC traffic mitigation proposals, as well as their potential to degrade the local environment, is a matter of argument. But the prime question should be : what is it about these housing proposals that causes such serious traffic consequences ?
It is inevitable that large additional developments - of housing along with employment and community needs - will give rise to a substantial increase in traffic. It is also true that those living in these new developments will own and use motor cars for much personal travel. But it is not inevitable that all of them will do so or that they should have no other options. Some may not be able to drive, some may not have individual use of a car. If housing is to include 40% affordable, then for many household budgets the cost of motoring and especially of multiple car ownership will present hard choices. That is without considering the sheer hassle of daily congestion, parking at destinations, and other considerations in making a personal choice to walk, cycle or use public transport.
3.4 Says that the strategy seeks :-
"Low carbon environmental sustainability" & "Provide for the appropriate & necessary transport "
NPPF para 7 sets out the three dimensions of sustainability, including the third, environmental role
para 17 lists Core planning principles including :-
* "Contribute to conserving . . the natural environment and reducing pollution"
* "Actively manage patterns of growth to make the fullest possible use of public transport , walking and cycling . . ."
5.1.3 Densities
WDC refers to the Garden Towns, Villages & Suburbs Prospectus with Densities of 30-35 dph (dwellings per hectare) or 25-30 dph at the edge.
An undeniable outcome of such densities is to bias transport options overwhelmingly towards use of the car for the vast majority of journeys. It is this feature of your southern housing strategy which aggravates the potential traffic congestion in and around Warwick & Leamington.
This feature is directly in conflict with your own stated Strategic Vision at 3.4
It also is in conflict with the NPPF : Environmental dimension of Sustainable Development
It does not require technical analysis to understand the general point that low density suburban layout is inimical to efficient and economic public transport links. But professional analysis provides good evidence that densities of the order 50 dph and more are the benchmark for viable public transport within 10 minutes walk of each home.
While cycle ways and footpaths may be provided, the very intensity of motor traffic allied to big highway formations (mitigation) will seriously deter cyclists and pedestrians. That, along with the paucity of public transport, makes for a vicious circle against the sustainable choice. It will also increase pollution.
Garden Space

We do not suggest there should be no private gardens in the new developments, but neither is
it useful to insist on gardens throughout. It is perfectly possible to incorporate garden space at up to 50 dph, alongside a smaller proportion at the lower density. Were a choice of some flats and maisonettes included in a mixed development, these may well be at 100 dph. Altogether, a brief for a more diverse range of accommodation within varied layouts could provide a much less sprawling development. This would take less road space, meet varied housing needs, offer more sustainable transport options, and could more realistically provide the crucial element of affordability. It can be set alongside green wedges, allotments, etc as well as leaving more real countryside.

Finally, regarding the WDC "Garden Suburbs" prospectus I attach our response from last year. We indicated a series of points on which we say this is inadequate as a policy document and in parts misleading. It often confuses green pictures with genuinely sustainable solutions to the District's housing needs.

In this connection, we have looked at the WDC website commentary on 2012 responses to the POs. In relation to low density sprawl it states :-

"A balance needs to be struck between land-take and the quality of design"

We are surprised at this suggestion of a false conflict: quality of design resides in meeting the needs of a situation with skilled, well tailored solutions.

see attached