I am writing to show support for the New Local Plan Revised Development Strategy; in particular I support the absence of development on the North Leamington Green Belt around Milverton and Blackdown.
The Green Belt in this area meets five of the key roles of Green Belt and is an excellent and well used cultural and exercise related resource. Development in Kenilworth, Baginton and Lillington already take land from this essential Green Belt and further development on it would not be sustainable. It is essential that the plan does not return to a scheme involving any development on the North Leamington Green Belt.
I would also like to make the following points:
1. A Joint Strategic Housing Needs Analysis is currently being performed with Coventry City Council. If this review identifies that it is necessary to increase the number of houses above those currently proposed I believe that there is sufficient non Green Belt land to accommodate this additional development.
2. The Revised Development Strategy has a fair distribution of new housing across the District. It is fair because there are still plans for new houses in the Green Belt at Thickthorn and Lillington as well as proposed development in villages.
3. The Revised Development Strategy proposes that most of the new development is located close to where employment opportunities already exist (e.g. industrial parks to the South of Leamington & Warwick) this provides an opportunity for people to live close to their place of work, reducing or eliminating commuting for many people, reducing pollution & improving quality of life. Furthermore there is ample space to build to the south of Leamington as the next nearest town is Banbury.
4. Focusing development in the South, in one broad area, ensures adequate public services can be provided and developed to meet the needs of the new population. These services can be designed to meet the exact needs of that new population and planned within easy walking and cycling distance, minimising traffic congestion. If development were to be more spread across the district public services would have to be developed in an inferior and unacceptable "make-do-and-mend" fashion which would provide poorer levels of service to both existing and new residents in those areas.
5. The Revised Development Strategy provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district as it would have forced people to travel south to employment land, shopping (e.g. supermarkets) and the M40. Loss of vital Green Belt recreation land would also have resulted in more people travelling by car for recreation.
6. It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than for development in the North. For instance putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible. It could be crossed by cycle-ways and would act as a green-lung to reduce air pollution.
In conclusion the exclusion of development in the North Leamington Green Belt enables the plan to comply with the NPPF. Any attempt to re-introduce development in the North Leamington Green Belt would be unacceptable and be bitterly opposed as no exceptional circumstances exist; the land is a vital and immeasurable resource for the future of the district and is critical to its future sustainability.
Development in the South reduces traffic congestion and reduces air pollution, it enables better provision of public services and other facilities with better access to the employment hubs in the South.

Consultation Response to New WDC Local Plan Preferred Options Paper

I am writing to object to the proposal for 12,300 houses in Warwick District and nearly 4,000 new houses in Warwick. In objecting I refer to the National Planning Policy Framework which "aims to strengthen local decision making and reinforce the importance of up-to-date plans".

Population Growth

The NPPF states that there should be a clear strategy "taking account of the needs of the residential and business communities".

Why has the number of 12,300 been proposed which is higher than the 10,800 proposed in the Core Strategy and was strongly resisted by Warwick District Council at that time? The West Midlands Regional Office was vehemently criticised by WDC for producing these flawed and untenable figures. Your figures do not comply with WCC population figures and are therefore unreliable. A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause immense damage to the character of the County Town. Migration from other areas into Warwick's more attractive green environment has produced most of the population growth. The provision of more houses will encourage more migration and Warwick will no longer be an attractive area. The new Plan should cater for LOCAL needs not migration into the area. You have included figures to cover an increase in students but they should be housed near the Universities not in the District, especially in south Leamington. Increasingly high concentrations of students in certain areas is an issue of concern.

Regarding your assumptions on the demand for housing, given that more than 50% of national population growth has been from immigration over the last two decades, and the government has publicly stated it wishes to greatly reduce this future net immigration, why is Warwick District planning for an even greater level of growth over the next 15 years, than has been experienced in the recent past? Warwick District population has increased by 12% since 2000, which is approximately twice the rate of increase for Warwickshire, twice the national average increase, and over three times the increase for West Midlands. Warwick Councillors asked that the proposed development should be equitably distributed over the District but half of the homes proposed in the new Local Plan are south of Warwick.
Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and history has shown that the necessary infrastructure has never been put in place.

The NPPF (48) states that Local planning authorities may make an allowance for windfall sites in the five-year supply". 1,224 properties have planning permission or a planning brief at the moment and yet you do not appear to have taken these into consideration. This would equate to a two-year supply of houses. I do not believe our authority has identified and brought back into residential use the 300-400 empty houses and buildings (NPPF 51) to the extent they should have done. Not all empty homes have been identified. New planning laws now allow unused office space to be converted to housing and his should be taken into account in the housing projections.

We have not been given information on where the 'missing' 6,000 homes are proposed to be built. Why not? You have stated at Aylesford School that this has not been decided yet. How can we make informed representations without the full facts being presented in the proposed new Local Plan?

The validity of your forecast projections of housing need has been seriously questioned. Evidence submitted by Cllr. Ray Bullen demonstrates that there is a 5 year housing land supply. The last 5 year housing land supply document is dated November 2012. It is out of date. The NPPF 153 says the " Local Plan .......can be reviewed in whole or in part to respond flexibly to changing circumstances". Therefore the out of date 5 year plan should be updated immediately to take account of those changing circumstances.

Research by Cllr. Ray Bullen shows that only 5,400 homes are necessary for local need which allows for moving in and out of the area based on what happened in last 10 years (births/deaths/migration). 12,300 includes economic growth but if jobs don't materialise unemployment will rise. Unemployment is low 1.6% currently. We need a homes/jobs balance. If we are looking to build housing you then have to match employment to housing. There appears to be no current evidence of a demand for employment development schemes. Employment land currently available cannot attract employers so cannot justify building 12,300 houses, e.g. the lack of interest in office space at Morrisons. Where will we find employment to match housing? The large office block plan at IBM is now being used for housing (windfall site).

The NPPF requires 'sustainable development'. The three criteria of sustainability are environmentally, economically and socially sustainable. The development south of Warwick is not sustainable.

I believe that the only motivation for WDC producing such figures for demand is the income that will benefit WDC in New Homes Bonus, rent, rates, council tax monies etc.

Stratford-on-Avon is currently consulting on the possible provision of some 4,500 houses in Gaydon and Lighthorne and this would impact on the need for houses in Warwick District. Local authorities have a duty to co-operate but WDC have not had discussions as yet with SoA.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Green Belt

The NPPF (79) states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence."

An incredible 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

NPPF (88) states "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and I am objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. I would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

Stratford-on-Avon have said there are exceptional circumstances to develop on certain areas of Green Belt. Why doesn't WDC take same point of view? There is land available north of Leamington and in Kenilworth which is nearer to employment in Coventry and the Gateway.

Coalescence

The area to the west of Europa Way was identified as an area of restraint at the time of planning 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. The current Local Plan states in para 9.11, "It is important to protect the areas of restraint from development proposals that could alter their predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate one urban area from the next." The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including owls, uncommon woodpeckers, roe deer and badgers. This green space also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on! The NPPF 109 states "the planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological netwoerks that are more resilient to current and future pressures."

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Yet your reason for allocating development on Green Belt, against the National Planning Policy Framework is that "there is nowhere else to build". This argument is totally flawed and I would expect the Inspector to find this Plan unsound on this issue.

The NPPF (17) states that planning should be "empowering local people to shape their surroundings."

Why has this amount of housing been proposed for South Warwick when the previous consultation on the Core Strategy produced a 97% response in overwhelming opposition to housing here (700 objecting to the Europa Way, Gallows Hill and Banbury Road area.. Why were those results not heeded when you devised the new Plan? These plans do not reflect the aspirations of the community as the Government intended in the Localisation Act.

Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk but you are proposing to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102)

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. You have received photographic evidence of flooding from properties in Myton Crescent and the Malins. When the Warwick Technology Park was created, there were severe flooding problems in the adjacent Myton Gardens. The field donated to Myton school as a restricted covenant playing field has proved to be unusable because of water-logging, demonstrating on-going water-management problems. Even more relevant to the Malins and Myton Crescent was the severe flooding in 2007 caused by the re-orientation of the water run-off flows and the disturbance and removal of top soil from the Round Oak School playing fields behind Myton Crescent. It was only after threats to sue the County Council that remedial action was taken. This consisted of a bund to capture excess run-off and a pump situated in the north-west corner to return water uphill into the drain near the Round Oak School. This action has proved ineffective and inadequate as run-off water has periodically flowed into the gardens most recently in October 2012 when the water level reached was only a few inches below the level of the electricity sub-station situated between 26 Myton Crescent and 1 The Malins.

The field at the end of The Malins slopes upwards from The Malins and run-off water from adjacent fields above and to the right and behind also flows towards The Malins and Myton Crescent. When there is a downpour on saturated ground, water flows quickly down, fills up the lower parts of the field and collects in the gardens of nos. 26, 28 and 30 Myton Crescent, and overflows into the gardens of nos. 3 and 12 The Maslins and towards no. 1 The Malins and the electricity sub-station. There is little indication that the seriousness of this flooding is being taken into account.

Ignoring flood risk is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere." The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

 
Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. They were then allowed to build more houses on the area allocated for sport/play area at CM. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Coventry Council should also provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

Infrastructure

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:

* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and

* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries, evening clinics and Saturdays to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost. The public sewer discharges to Longbridge Water Treatment Works. Severn Trent currently transport sewage from Longbridge to Coventry by tanker several times a day. They do not have the capacity now to deal with sewage at the Longbridge site and it is inconceivable how they will cope with sewage from another 4,000 houses in Warwick. How many more tankers will be required and at what extra cost?

Buses have not proved to be sustainable. The only service for Myton Road is one per hour and no-one uses it.

CIL

The NPPF (175) states "Where practical, Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan. The Community Infrastructure Levy should support and incentivise new development, particularly by placing control over a meaningful proportion of the funds raised with the neighbourhoods where development takes place."

You have not provided information on these charges at all. I do not believe that there will be anywhere near the amount of funding available from CIL to cover the above extra infrastructure needs, especially new roads, bridges, schools and hospital. The hospital currently is in crisis and there is no room to extend. Funding for a new hospital is in doubt.

Air Quality/Traffic

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

The Traffic Assessment commissioned states, "Schemes proposed within the modelling at this stage have not been tested to a sufficient level of detail to determine that they are the optimum solution" and "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"!

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 12,300 new homes, bringing with it increased pollution in areas where air quality is already over the limit. 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. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?

The 2008 Air Quality Action plan for Warwick shows the very worst area being Warwick town centre and states on 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 assesse, 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. Ass 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."

NPPF 124 states, "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

I request that a Health Impact Assessment will be carried out including air quality testing well before any Local Plan in its current form is approved.

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road, Europa Way, Castle Bridge, Emscote Road and Prince's Drive are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen. One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area. The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then put it in for development - why? Traffic would increase at the Butts, the narrowest road in the town and the no right turn plan for St. Nicholas Church Street would impact severely on the economy of Smith Street. Vibrancy of the town centre is important. Think about what the effect will be on people sitting outside cafés in danger of being knocked over and pollution from all the traffic being funnelled through Warwick. People won't want to shop in Warwick because they won't be able to get into the town. It will be the destruction of Warwick and the people who want to shop here. There will be an adverse affect on Tourism.

Parks

In the new Local Plan our parks will not be sufficiently protected from development by the old area of restraint policy we once had.

Historic Environment

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. We need an impact assessment to ensure its conservation. English Heritage have offered to help with this.

The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional." The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre. Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe" (NPPF 32).

Gypsies and Travellers Sites

Why are 15 of the proposed sites south of Warwick and only 3 north of Warwick?

Conclusion

You state that in 2026 Warwick District will be renowned for being "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....." In my opinion this could not be farther from the truth.

The above comments demonstrate that this Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable. I believe the Planning Inspector will declare it unsound, especially on the air quality issue. It cannot be justified as "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence" and it is not "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework." (NPPF 182)

This Plan should be completely revised taking account of the above, specifically reducing the numbers of housing proposed for Warwick.

Congratulate WDC on their Revised Development Strategy. It has been proved that there are no exceptional circumstances to build on Green Belt land to the north of Leamington and alternative sites have been found.
The revised plan makes complete sense as jobs, numerous supermarkets, schools, the railway station are all in the south. The infrastructure in the south is already in place and it is nearer to the M40.
It is most certainly not Leamington's duty to take on Coventry's responsibility for building and providing new houses. Coventry is large enough to look after itself and to provide it's own land and not ours for their new houses.
Coventry is responsible for Baginton Airport and any new houses should be built on land belonging to Coventry. The fact that the owner of the airport is on the Planning Committee while conveniently living in Stratford on Avon is shameful to say the least.
I completely support the Revised Development Strategy concerning Leamington Spa.

I would like to compliment the Planning Department on their efforts to produce the New Plan. It must have been an incredibly difficult task and I am so pleased that it no longer includes building on Green Belt Land.

My husband and I are writing in relation to the proposed new development in and around Bishops Tachbrook. We feel the area will struggle to cope with the amount of development in the plan. Large amounts of increased traffic is a worry, we currently live on a main road and it already very busy and we have been trying to improve the speed and volume of traffic using this road since we moved in. The school is already unable to provide spaces for all children in the local area also we were not able to transfer to the local Doctors surgery when we moved here, as we were told they had a long waiting list. With the suggestion of thousands of new homes being built and including new travellers sites, we are concerned about how the local area will manage with current resources

(Sent to Cllr Gifford)
As a resident of North Leamington I share your relief that sporadic intrusion into the green belt in this area is no longer proposed. I live in Northumberland Road (No 17) I was an allotment holder close by but anno domine and good sense persuaded me not to continue with this For the sake of the other allotment holders I am relieved that their area is no longer under threat As a dog owner and walker and bringing up a family in the area I am entirely convinced that the Leamington Parks and unusually accesible green belt is a major factor behind the appeal of this area across a wide spectrum of people These people including many who commute to places of work away from the town nevertheless support the local businesses within the Town which in turn are a part of the Town's charm and appeal Please convey to whomsoever might be in a position to ensure the continuing protection of the area generally my views . I hasten to say that as a former resident of Coventry for over 30 years I am also well aware of the particular appeal of many parts of that City but the need to avoid urban sprawl merging the identity of south Coventry Kenilworth and North Leamington to the detriment of all three must surely be apparent to the residents of all three

Thank you for the opportunity of commenting on the Warwick Local Plan Revised Development Strategy.
Midland Red (South) Ltd trading as Stagecoach Midlands, is the leading commercial bus operator in Warwickshire. The company operates the vast majority of bus services in Warwick District, including Leamington Spa and Whitnash, where we operate a comprehensive network designed to offer both convenient local trips, but at least as important, services offering residents effective choices for longer journeys. The great majority of these routes are commercial, fully funded by our passengers
We also operate services supported by Warwickshire County Council, won following tenders for best value. We always strive through disciplined reliable operation, quality customer service and on-board experience, and effective marketing, to build revenue on such services as far as possible with a view to taking them on without public funding at a future date, where possible. These services to a great extent follow timetables and routes specified by WCC, as socially necessary services, where patronage today could not support a commercial operation by us or another bus company.
Stagecoach in particular has a national, independently assessed reputation for delivering among the highest levels of customer satisfaction. As well as offering reliable convenient services we are constantly investing both in existing services and our operational bus fleet, and developing new products and services aimed explicitly at providing greener smarter travel choices to the public, and especially those who do not yet regularly travel by bus.
Stagecoach proactively seeks to identify and pursue business development opportunities, and the company recognises the role it plays in delivering sustainable development. We welcome the opportunity to comment on, and help shape development proposals to the advantage of the community and the wider travelling public.
High-quality bus services are one of the most credible means of preventing car dependency, mitigating local highways impacts as far as possible, and achieving sustainable development. This includes not only environmental but also socio-economic goals.
We submit that there is a clear alignment of interests between stakeholders in the planning system, and ourselves and other commercial bus operators.
Strategic Vision
Stagecoach Midlands therefore wishes to generally support Warwick District Council's Strategic Vision, which is essential in setting the basis on which sustainable development can be realised, but has strong reservations about certain of the measures proposed, which we do not believe will deliver the vision. As this Vision is taken forward through robust policy-led prioritisation of actions, Stagecoach Midlands will be much better able to support the LPAs objectives while achieving our strategic goal to provide further high-quality greener smarter travel choices to the District's residents and visitors.
The National Planning Policy Framework (NPPF) makes clear in paragraph 7 that the "golden thread" of Sustainable Development that runs through it, includes economic, social and environmental goals. Stagecoach Midlands recognises not just its general responsibilities as a good corporate citizen, but the particular key role our business plays in securing these objectives at a local level.
Every day, Stagecoach buses:
* connect customers to markets and employees to businesses. Stagecoach Midlands itself is a locally-significant employer and customer of UK businesses
* connect people of all socio-economic groups to school, college, further and higher education; and of course to leisure and recreation opportunities
Our operations achieve all of this in a way that reduces congestion, and emissions. DECC statistics demonstrate that in the UK, personal transport use generates as many greenhouse gas emissions as the entire residential dwelling stock.
Not only do we reduce personal travel carbon footprints radically, but we are making strenuous efforts to reduce the carbon intensity of our own operations. Stagecoach Group announced in January 2013 that it has cut the carbon impact of its businesses in the UK and North America by more than 20% in the past four years. The transport group's absolute annual carbon footprint is now nearly 56,400 tonnes of CO2e lower than in 2007-08. The annual carbon saving is equivalent to the CO2e produced by powering nearly 11,000 homes for a year. Measured by carbon intensity (kg CO2 per £ of turnover), Stagecoach's carbon impact now is 22% less than four years ago.
As a result, Stagecoach Group is the first Transport Company to reach the Carbon Trust standard for emissions reductions.
Where land-use planning, and local transport policies align to facilitate high quality efficient commercial bus operation, then a full range of highways management, economic development, environmental sustainability and socio-economic inclusion objectives are all simultaneously met.
Where bus services are not effectively and positively planned for, and bus operators and their customers are marginalised, then unsustainable car-dependent development is the unavoidable result, contrary to the overarching intent of National Policy, and the explicit principles set out in paragraph 17 of the National Planning Policy Framework.
Stagecoach therefore regrets that connectivity is not given much priority in Warwick District Council's Strategic Vision, although we understand the preoccupation with meeting housing need.
Transport, to the extent that as it is addressed at all in the Strategic Vision, is largely considered in terms of lists of hard infrastructure projects, designed in response to the modelled impacts of the Revised Development Strategy. Transport measures therefore seem entirely to flow out of the Development Strategy, rather than the Strategy firstly taking account of "the opportunities for sustainable transport modes (to be) taken up, depending on the nature and location of the site, to reduce the need for major transport infrastructure" as required by NPPF paragraph 32.
This risks a strong misdirection of attention into physical highway works without looking at more creative and holistic approaches which better address the wider needs of communities, now and in the future. This is explicitly required by paragraph 17 of NPPF. Specifically, it states that plan-making and decision- taking should:
"actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable."

Stagecoach also submits that the approach being taken, with its emphasis on hard engineering, is likely to prove more costly than one which identifies and takes up the existing opportunities presented by more sustainable modes of transport, in deciding the location for new development. This approach risks the delivery of that development, by imposing additional burdens on development viability than might strictly be necessary. We note that, just before this consultation closed, the promoters of the greater part of the Myton Garden Village site west of Europa Way, have tabled an application for up to 800 dwellings, of which only 20% are affordable, rather than the 40% sought in Warwick DC's emerging Local Plan policies. The applicants submit a full viability appraisal, by professional development economic specialists, that demonstrates that the cumulative burden on viability of planning requirements, including transport, does not permit the Council's target to be met.
NPPF is clear that planning should also ensure that:
"improvements can be undertaken within the transport network that cost-effectively limit the significant impacts of the development."

NPPF paragraph 31 also explicitly requires that plan-making bodies should
"...work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development."

We therefore are disappointed that the Revised Development Strategy and supporting Warwick Strategic Transport Assessment (WSTA) makes little or no provision for infrastructure to support delivery of high quality bus services, and in particular, bus priority at key points and on key corridors to the South and North of Leamington where congestion is already becoming a significant difficulty for us, and where future development proposals will greatly increase pressure on the highway network.
Stagecoach Midlands is very concerned that, based on the Warwick Strategic Transport Assessment Phase 3 modelling, undertaken in support of this strategy, the following effects arise, even with all the prioritised mitigation in place:
* A deterioration in traffic conditions in both Leamington and Warwick Town Centres
* A general decline in traffic speeds during peak hours, especially in the network south of the Avon
* That with all model runs, the biggest residual deterioration in road network performance occurs on the south and eastern flanks of Leamington Town Centre, on the one hand, where scope for engineering-driven mitigation is most limited; and on the Europa Way and Tachbrook Road corridors.
* A general increase in peak delays and queuing, in both town centres and on key arterial routes. The modelled increase in queues even at full mitigation at the Victoria Terrace/Spencer Street lights, and the Old Warwick Road/Princes Drive junction, through which a large number of our services must pass to serve the proposed southern focus of planned development, is especially worrying; and barely less so at the Tachbrook Road/Heathcote Lane junction. We are equally concerned, on the opposite side of the urban area, that a similar deterioration in traffic conditions is anticipated at the A46 Thickthorn Interchange.
The result is that each bus within our Leamington and Warwick network will cover less mileage in a given period of time, at the end of the Plan Period. Therefore, just to "stand still" in terms of journey frequency, Stagecoach Midlands will have to find additional resources: buses, drivers and overhead; to maintain the current timetable offer within the urban area and environs. Actual journey times will be slower, which ordinarily would be expected to produce a decline in overall patronage.
There is a real risk that, far from improving the conditions to deliver improved modal choice, in conformity with the requirements of NPPF, the Revised Development Strategy undermines it, because of the absence of specific targeted and comprehensive measures to deliver bus priority.
With regard to the developments themselves, while we do note WCC's preferred strategy on bus service specification to serve specific major development south of the towns in particular, the sense from the consultation document is these and all other bus services, will also have to fight for space on the existing network, alongside all other traffic, with negligible rebalancing of the highway network in favour of the bus as a more sustainable travel mode, as required by NPPF Paragraph 29.
WSTA Phases 2 and 3 modelling do assume certain very limited bus priority measures, though these are largely focused at the northern end of Europa Way. These mainly take the form of priority bus gates to allow buses to enjoy priority release from signals, but do not allocate dedicated lanes for bus services over any distance.
We also note that there is a considerable discrepancy between the Virtual Park and Ride frequency for which WCC are seeking developer funding, and that modelled in WSTA. The Revised Development Strategy sets out a 30-minute frequency service to Warwick, and a 20-minute frequency service to Leamington. WSTA Phase 3 assumes a 9-minute service frequency to Leamington, and 12-minute to Warwick throughout the day (WSTA Phase 3 section 9.2, p.95).
There is also some lack of clarity about the P&R routing and operating mode assumed by the WSTA models. It appears the WSTA Phase 3 modelled a dedicated direct Park and Ride bus service as it is not clear that any allowance is made in the journey time for the service to stop en-route to pick up and set down between the facilities and the town centres, as the "virtual P&R" concept envisaged in the Revised Development Strategy anticipates.
We are also very concerned at the journey time penalty suffered by Park and Ride users, compared with car users, that the model produced. We are therefore extremely sceptical that the mode shift assignment of travel demands to the bus service will occur at the level anticipated by the Plan. We do not see that motorists will see any advantage in parking, waiting up to 20 minutes for a bus to Leamington, and then suffer a slower journey than cars taking a parallel route into town (WSTA Phase 3 figure 30, page 101).
To re-iterate, the Park and Ride bus services are anticipated to operate as a conventional bus routes, and will therefore also act as the main bus links from the proposed development allocations to the Town centre. We do not believe that this service should make an initial journey first to the park and ride facility, before making its way into town, without enjoying any bus priority at any stage. In the absence of bus priority measures, the 15% mode shift target required by the Strategy would be much better achieved by those services serving the developments taking the most direct route into town.
The time disadvantage that WSTA assumes for bus passengers at peak times seriously undermines the credibility of the mode shift targets for bus use required by the Strategy. This time penalty can only be addressed by the introduction of comprehensive bus priority measures on the main affected corridors, and in the town centres of Warwick and Leamington.
We also note that the Leamington Park and Ride Route has been modelled to operate through the Myton Garden Suburb area, a parallel but not comparable route with Europa Way in terms of speed. In fact, depending on urban design approach, this route, with the potential for multiple accesses, side roads and on-street parking, is likely to be, and perceived to be, slower and more circuitous than a service running directly along Europa Way, if conventional urban and highways design approaches are used.
We are aware that a formal outline planning application for the bulk of this area was submitted just before this consultation closed (W13/1016/OUT). It is clear that the Master Plan and Movement Strategy is quite conventional.
We will be making our own submissions in response to the application. For now, in response to this Policy consultation, we would say that there are a number of ways to address this journey time disadvantage by Master Planning and highway design within the Myton Garden Suburb site, which we cover later in this submission. For the avoidance of doubt, we can see the considerable merits of combining a service through the Myton Garden Suburb with the "virtual" Park and Ride operation, BUT for this to work effectively and be attractive to potential passengers, great care needs to be taken in the overall design approach to the actual bus corridor within and adjoining the scheme, and the urban design of the proposals as a whole.
The approach taken within the modelling to the assignment of patronage to P&R is high-level and is therefore relatively inaccurate. Experience over many years demonstrates that park and ride delivers significant mode shift, and commercially-sustainable levels of patronage, only when parking at the destination is highly constrained, very frequent bus services are offered, and significant on-line bus priority exists, to allow motorists to see buses passing them while they sit in queuing traffic.
Looking both at the national experience of successful Park and Ride schemes, and then at a growing list of failed Park and Ride operations in some other towns, we consider that the virtual Park and Ride proposals need far more robust and nuanced operational and commercial modelling, based on a service design that offers very much clearer and more credible advantages for potential customers, if this part of the Revised Development Strategy is to achieve the necessary impacts.
To conclude and summarise, no bus operator can provide high quality mode choices when its costs are increased by operating in heavy congestion, while its customers face delays and unpredictable journey times. Real mode choice requires that the relative attractiveness of more sustainable travel modes needs to be enhanced. The Revised Development Strategy makes almost no explicit provision for such rebalancing, at least as far as bus services are concerned.
Indeed, the relative silence of the Development Strategy on the role of bus services in securing a sustainable form of development is quite notable, despite the weight attached to the effectiveness of certain bus-based elements in the WSTA.
The Councils' own retained specialist transport consultants conclude at the end of the WSTA Phase 3 Report that "further detailed assessment of the potential benefits of the P&R should be undertaken although it is imagined that such testing would be intended to compliment an over-arching feasibility study of the P&R site meaning allowances for mode share and interception could be included within the modelling to allow a better understanding of both the benefits and impacts of delivery." We strongly agree. In fact, we do not understand how the Revised Development Strategy can be considered robust without this work having informed the Strategy.
WDC/WCC's own highways technical consultant explicitly states that "it is critical that sustainable transport improvements form part of the mitigation package to support the housing and employment growth proposals within the District." (WSTA Phase 3 Appendix H Technical Note 21/5/13, page 1).
Stagecoach Midlands considers, having carefully reviewed the revised Plan proposals and the supporting evidence base, that a considerable amount of further work needs to be undertaken, in partnership with promoters, WCC and bus operators, as required by NPPF paragraph 31, to arrive at a deliverable, robust package of sustainable transport measures in support of a much more sustainable local Statutory Development Plan for Warwick.
RDS1 Stagecoach Midlands has no comment to make.
RDS2 Stagecoach Midlands has no comment to make.
RDS3 Stagecoach Midlands wishes to object to the proposed preferred option for the broad location of development, because of the difficulty in serving the sites on a sustainable commercially viable basis.
We strongly agree that a strategy of urban concentration makes best use of existing public transport infrastructure, and allows existing bus services to perform significantly better in terms of load factor. Such an approach also gives scope for a virtuous cycle of service enhancements to be delivered based on an overall larger quantum of demand from which to draw, by developing the network.
This supports travel mode shift not just from within the new developments, but across the improved network as a whole. It is likely, for example, that new or augmented routes serving development to the south of Warwick would continue, as today, across the town centres providing new direct links as well as enhanced frequency. This would improve the overall attractiveness of the service offer, subject to operating conditions being at least as supportive as today.
There is currently virtually no bus priority within the Warwick and Leamington urban area. Were measures to achieve bus priority to be introduced, then the positive effects outlined above would be greatly magnified.
We also concur with WDC and WCC that there is scope through a concentration of development south of the towns, to kick-start a radically improved level of service in an area in which historically it has proved very hard to offer frequent, direct bus services, not least because of car-dependent urban design, and a lack of critical mass of demand. In addition, the major local highway corridors, in particular Tachbrook Road and Europa Way, are already affected by peak-time congestion, even before any new development is constructed.
This opportunity to improve the public transport offer will only be realised, however, by positively planning for the bus to play a much enhanced role. While some of this is implicit in the intent of measures set out in the Revised Development Strategy, we are concerned that overall there is no clear agenda, nor specified measures, to ensure that the opportunities provided by the Strategy to deliver a much higher quality of public transport offer have been taken up, in the form of sufficiently well-developed actions required by Policy. We will address the opportunities we identify in more depth later in our responses.
As such we submit that the Strategy is not in conformity with NPPF.
Stagecoach Midlands OBJECTS to the location and distribution of the quantum around the south of Leamington and Whitnash.
In general, we consider that insufficient consideration has been given to achieving higher density development across the sites, or parts of them, sufficient to make best use of existing and credible future quality public transport provision. While we recognise the attractiveness and desirability of the Garden Suburb vision, the provision of effective high quality bus services is undermined by the relatively low housing densities involved, and the consequent likely impact on the dwelling stock mix.
The current Strategy, in proposing a relatively large development footprint also effectively gives rise to a much greater expanse of development south of Harbury Lane, than is easy to serve by a single high frequency bus route. Diverting existing service 68 through these areas will pull it away from existing development at Warwick Gates OR risk creating a circuitous service design that will be very unattractive to existing bus passengers, while being even less attractive to car owners.
Large parts of the development footprint in Myton Garden Suburb in particular, are much closer to existing local employment and amenities, and are also most closely related to the existing urban area. This development proposal is expected be within easy reach of the proposed high frequency bus corridor incorporating the "virtual Park and Ride". Depending on the master planning approach, higher densities might be justified in Myton Garden Suburb adjoining this bus corridor, either on the eastern flank if the service uses Europa Way, or, if a bus priority corridor were delivered within the scheme, within 250-300m of that. Higher densities, of up to 45 dwellings/Ha, would support much better patronage levels for the proposed bus service.
If it were possible to accommodate a larger development quantum at Myton Garden Suburb overall, which is the location best able to take advantage of sustainable transport measures, it might be possible to avoid the need for land releases elsewhere, which are currently very much less easy to access by sustainable transport modes.
In particular Stagecoach Midlands considers that several small-scale proposed land allocations east of Whitnash/South of Sydenham look to be difficult to serve on a sustainable basis, by attractive public transport services, without significant infrastructure measures being put in place, that are not anticipated by the Revised Development Strategy.
As stated above, the Strategy proposes that the development footprint extends much more than 300m south of Harbury Lane. The development quantum on land allocated beyond this threshold would be equally hard to serve with a bus service sufficiently frequent and direct to be attractive. In addition the wider public concerns expressed about incipient coalescence with Bishops Tachbrook could also be mitigated by a revised approach that reduced the development quantum that needs to be accommodated here by achieving a higher-density more compact urban form on development sites better related to existing and future sustainable transport opportunities.
We particularly object to the smaller scale releases of land south of Sydenham/east of Whitnash. These areas are well beyond 400m of existing bus services. Extending services into this area will require an additional vehicle resource, even at a modest half-hourly frequency. We do not consider that the potential patronage that would be generated by the proposals would sustain a credible commercial service in the long term. In fact, the need to split access to land south of Sydenham with a second access across the current Campion School site, makes this problem much worse, with only an additional 300 dwellings available to support the operating additional operating costs involved, which are likely to be between £130-140,000 per year at current prices.
However, were direct bus-only vehicular access provided across the railway between Whitnash and the land South of Sydenham, we see much greater potential to incorporate these areas into a high-quality commercial bus network, subject to appropriate pump-priming funding being available during the build out period to deliver this service appropriately early. This would require a bus gate incorporating a pedestrian and cycle link; and a high-quality bus circulation facilitated through the site, also picking up the proposals at Fieldgate Lane west of the railway.
Such an approach would lead to Sydenham potentially being directly connected to employment both existing and proposed south of Leamington. We consider that this would significantly enhance its connectivity to these opportunities and greatly improving the socio-economic sustainability of the Strategy. A dedicated transport crossing would also give public transport and other sustainable modes a major advantage over private car use from all the development east of the railway, and as a result these additional measures would offer a much more sustainable location compared with further development south of Harbury Lane.
We support the proposals at Redhouse Farm Lillington where the whole proposal falls within easy reach of an existing commercial high frequency service. It is the one proposed allocation that best makes use of existing public transport services and infrastructure in a location that is already sustainable.
We note the current proposed approach at Kenilworth. We recognise the need to meet the housing requirements of the town, and can see the landscape and other factors that favour Thickthorn. However we object to the current proposals because:
* We see that with the main access being proposed on to the A46 interchange, it will prove to be an exceptionally attractive location for car-based commuting, causing additional peak time congestion and undermining the effectiveness of the Strategic Highway Network, and potentially delaying our existing services, not least those offering fast links to Coventry and Warwick University via A46.
* When evaluating how we might serve the development, it is unclear that the quantum of development proposed there, and that existing adjacent, is sufficient to support a dedicated high-quality bus service longer term. Were we to divert existing routes it would in effect lead to other large parts of Kenilworth which currently enjoy frequent services, being either unserved or much more poorly served.
We also strongly support the additional development envisaged outside the main towns, particularly in larger villages. Bus services to these villages already typically offer hourly services, or better, but the longer-term sustainability of the current level of service does depend in most cases on higher levels of demand. We submit that, at a time when Warwickshire County Council is faced with ever increasing pressure on its budget for socially necessary but uneconomic bus services in rural areas, the approach taken by the Revised Development Strategy outside the main urban areas, is a prudent one to maintain and indeed possible allow some enhancement of bus services to outlying settlements. Walking and cycling do not present as credible a sustainable travel choice in these locations.
We would suggest there is likely to be scope for the kick-start of improved service patterns in certain rural corridors, facilitated by limited developer funding sought across multiple developments served by a rural bus route corridor. This may not only involve added frequency, but also more direct services, making elapsed journey times much more competitive with other modes such as car or scooter.
RDS 5 Proposed Allocations
Station Approach: Stagecoach Midlands would point out that a substantial portion of this site is our existing operational depot for the area. The depot provides the bus services for Leamington, Warwick and most of the surrounding area. No suitable or cost-effective alternative location for a replacement facility has yet been identified. Therefore the site is not available and is thus not currently deliverable or achievable.
Hampton Magna: If it were possible to create a greater allocation here, this would offer a larger population and a wider socio-economic mix that would be much better able to support the ongoing commercial operation of a bus service in this location, and one that is less circuitous than the present route, which given existing levels of patronage, requires Local Authority financial support.
Hatton Park: If it were possible to create a greater allocation in this area, this would offer a larger population and a wider socio-economic mix that would be much better able to support the ongoing commercial operation of a bus service in this location, and one that is less circuitous than the present route, which given existing levels of patronage, requires Local Authority financial support.
The current design of internal roads also makes the existing development exceptionally difficult for bus services to penetrate, owing to the detailed design of traffic calming features. Any traffic calming measures introduced must be low floor bus friendly and very minor works within the highway could address this as part of future development proposals, and should be required to do so.
RDS 6 Employment Land requirement: Stagecoach Midlands has no comment to make.
RDS7 Location of new employment land.
Stagecoach Midlands supports the provision of employment land at the western end of Thickthorn, which could be served by our existing services; and also and allocation adjoining Warwick Technology Park (WTP).
The augmentation of employment at WTP could help create greater critical mass of demand for existing and future augmented services here, as well as reducing the average distances residents in the locality will need to travel to work from the new development overall. Shorter travel to work distances give scope for more sustainable modes, including bus services, to offer attractive options compared with personal car use.
It should be possible to address the current very unsatisfactory bus circulation and stopping arrangements within the existing Technology Park site, and the problems associated with on-carriageway and other inappropriate parking. Rigorous Travel Planning formulation and delivery should accompany proposals for this location to avoid exacerbating existing car-dependency and congestion. If a direct bus-only link could be provided from the north or north-east of WTP, through a Technology Park extension sited north of Harbury Lane, and into the wider Myton Garden Village beyond, this would make the resulting bus journey quicker than the car for many trips at peak times.
Chapter 5, Strategic Development proposals
Stagecoach Midlands has concerns that the strategic development proposals set out in the Strategy are coming forward through the development control system in an uncoordinated manner, in advance of the strategic Policy framework to guide this development being in place. These proposals now account for the majority of the strategic quantum. Having reviewed all of them, we find that in most cases, little consideration has been given to providing a sustainable high quality bus service within convenient walking distances of homes. We will make our separate representations on individual proposals in due course.
In general, Stagecoach Midlands believes that the density proposals do not support high-quality public transport provision. Within an average density of 30-35 dwg/Ha Master Plans should make provision for higher density along proposed bus corridors, even if this is offset by lower densities in the more remote areas.
Myton Garden Suburb: We are aware that a formal application has been submitted by the promoters ref W13/1016/OUT, for the bulk of the proposed allocation west of Europa Way, and was registered less than a week before this consultation closes.
This proposed allocation offers by far the most compact urban form of the sites identified in the Revised Development Strategy. In the view of Stagecoach Midlands, this site is the most critical to the success of the proposed Strategy. This is because it sits between the existing urban area, including Leamington Town Centre, and most of the proposed new strategic development. The main new strategic bus corridor is proposed to run either alongside or within the site. En-route, this corridor serves key destinations such as the Station, Morrisons, Leamington Shopping Park, existing employment at Europa Way, and the existing and expanded Technology Park, before continuing to serve the greater portion of residential development proposed in the Strategy.
Creative and imaginative urban design and master planning could deliver bus priority through or alongside the development, thus unlocking the viability of:
* The proposed virtual Park and Ride
* The new bus route
and by extension all the other public transport initiatives supporting the strategy
By linking together the Technology Park, its extension, the Park and Ride, and the residential area using a dedicated bus-only link through or alongside the development to create a bus priority route to Europa Way; the opportunity will have been taken to protect and exploit sustainable transport modes in line with NPPF paragraph 35.
A number of alternative approaches within the control of the promoters of Myton Garden Village could secure this outcome, including:
* peak bus priority along the dualled Europa Way, with the nearside carriageway being a bus lane at peak times.
* An additional bus lane or dedicated bus road provided over and above the dualling of Europa Way for general traffic
* A purpose designed bus corridor within the Garden Suburb, which may be used by vehicular traffic for portions of its length, but with a bus gate or gates to prevent rat-running.
Without such measures, we believe that the Strategy as a whole will only perpetuate and exacerbate the existing car-dependence in this area, in direct contravention of NPPF. Such an approach would be unsound, as it would be inconsistent with national policy.
South of Gallows Hill: Stagecoach Midlands supports this allocation in principle. The initial proposals made in a formal outline application by the developers for the eastern portion of this area did not anticipate bus services entering the site. The road layout would involve excessive circuity and only allow buses to serve the far edge of the development, which would mitigate strongly against effective and attractive bus service provision.
Those proposals have recently been withdrawn. We submit that any future master planning approach for this site and the land to the west, should be comprehensive, and assume the retention and enhancement of the existing bus routing, with good, well-surveilled pedestrian links to quality bus stops provided on Harbury Lane, spaced between 280-330m apart. This justifies higher densities on the northern edge of future proposals.
Proposals here should help support high-quality links from the area towards Warwick and thus can be considered to support the consolidation of demand on an existing public transport corridor.
We agree this area is less suitable for employment-led development, from a public transport perspective, not least because we believe it is more operationally expedient to provide the P&R and the Technology Park extension to the north of Harbury Lane, immediately adjoining the Technology Park and its extension.
West of Warwick Gates: Stagecoach supports this allocation in principle. Stagecoach Midlands reiterates that this site needs to make provision for high-quality roadside infrastructure and associated pedestrian links to them if the site is to be sustainable, and the overall Transport Strategy is not to be undermined.
Lower Heathcote Farm: We note a formal planning application was made for the northern portion of this site. Stagecoach Midlands notes that the promoter has made no provision for a bus service to penetrate the site directly or indirectly in those proposals. These have now been withdrawn. We found this omission most concerning. We submit that any future proposals for this land should assume the retention and enhancement of the existing service along the existing route/s, with attractive pedestrian links to quality bus stops provided on Harbury Lane. This approach justifies higher densities on the northern edge of future proposals that come forward. As a corollary it may be appropriate to reduce densities at the southern edge especially if these plots end up being outside a reasonable 400m walking distance of stops on Harbury Lane.
This would also support wider urban design and planning objectives.
We object to the development footprint extending further south onto land beyond the initial application site, as this land is well over 400m away from Harbury Lane and will not be within reasonable walking distance of a good bus service.
Former Sewage Treatment Works: Stagecoach Midlands objects to the proposed allocation. The Company does not see that a viable bus service could be provided, as this area could foreseeably be within 400m of a quality public transport corridor. Planning applications made on adjoining land to the east (Grove Farm) and west (Lower Heathcote Farm) make no apparent provision for an efficient bus route linking through this land. In any case, as discussed above, even if a comprehensive approach is taken to deliver a bus corridor south of Harbury Lane, this would draw any service away from the existing development north of Harbury Lane, or lead to the splitting of the provision such that the frequency of service offered would not be sufficiently high to be attractive. We therefore submit that, with the possible exception of some limited development on the northern edges of the site, this option is not sustainable.
Grove Farm: This site is not currently within easy reach of existing bus routes operating at regular high frequency. It is possible that a new service might be provided along Harbury Lane to the north of the site. Alternatively the existing hourly X18 running to the east of the site offers a much more direct route to the town centre, and might be augmented. We note an application for an initial 220 dwellings, all within 400m of Harbury Lane, is already submitted (W/13/0036/OUT). We can see that the layout affords a potential link to land to the south. The full quantum proposed, alongside proposals to the NE at Woodside Farm, might support the provision of a new local bus service, or a wider network recast to improve local bus frequencies serving the site.
However while in landscape terms this site functions as a unity with proposals to the west in particular, and equally adjoins the urban area, it will be much harder in this area to take advantage of the bus service improvements serving the wider area proposed by WCC. We consider this site less sustainable in terms of making best use of existing bus services, or logical improvements to the local network. We believe developer contributions from this site, and Woodside Farm, would be justified to kick-start a much better frequency of service on the Tachbrook Road corridor serving both this site and Woodside Farm, over and above those already being sought by WCC.
Woodside Farm: We note the site is the subject of an undetermined application W/13/0776/OUT. This site is relatively hard to serve directly by public transport. Providing a bus turning circle within the site, in line with the current proposals submitted earlier this year, or a bus-only gate giving through access to Harbury Lane, might achieve a 30-minute commercial service at final build-out when combined with the full quantum at Grove Farm, and a suitable means of running buses within the wider Grove Farm development. We recognise an existing PRoW offers direct access to our existing G1 Goldline service, but its width and quality is very poor, and many dwellings will be beyond the limits of a 400m walk to the stops on Coppice Road.
In our view, as stated for Grove Farm, additional proportionate developer contributions might be secured towards kick starting a new or augmented bus service via Tachbrook Road running at least every 30 minutes, and preferably every 20 minutes, serving these sites, and the poorly-served eastern end of Warwick Gates.
Employment Site Option 2: As noted above we support this option over a site south of Gallows Hill, subject to effective linkage both between the existing Technology Park and the site; and also the proposed residential development further north at Myton Garden Suburb. As discussed above we see a number of means whereby a creative and effective solution might be achievable.

Chapter 5.1: South of Leamington Infrastructure requirements
Stagecoach Midlands objects to the infrastructure strategy as the measures would not deliver a high quality public transport service and is thus inconsistent with the objectives of the strategy.
We have been previously notified by WCC of its intentions and approach to securing bus service improvements in support of the Strategy. We broadly concur with the overall shape of the strategy.
However it is clear to us that the 15% mode shift sought demands much higher bus frequencies, in particular on the virtual Park and Ride services. This would demand the pump priming of additional vehicles, above the four for which WCC is seeking funding.
Not least, the additional development quantum south of the towns that that RDS now proposes, demands significant additional capacity to achieve the required mitigation. Today the bulk of our town services operate with 38-seat midibuses. A 20-minute frequency would offer only 112 one-way seats per hour to Leamington. Full sized single decks would offer up to 46 seats per journey. If the Park and Ride is to be successful, and secure a significantly higher bus mode share from new residential development, which accounts for up to 3195 new dwellings and a new population of about 7,200, this capacity will not be sufficient
In particular we believe that a second new direct service needs to be offered via Europa Way and there must be sufficient bus priority to ensure that the speed of the service is attractive enough to encourage its use by the residents of this area.
We also strongly endorse WCC's view that a Park and Ride needs to be an integral part of the wider bus network to be viable.
We consider that a 20-minute direct and 30-minute indirect service to Leamington town will be not sufficiently attractive to persuade motorists passing the P&R site to use the service, or encourage local residents to make use of the facility. The time penalty associated with waiting for a bus is likely to be, or perceived to be, too high. Experience across Stagecoach operations shows that urban services ideally require a "turn up and go" frequency of between 10-12 minutes to provide an attractive choice for casual bus use by customers who have a car available. A 15 minute frequency is the absolute minimum service that might achieve this goal.
In addition to be financially sustainable the proposed Park and Ride site must be of sufficient capacity to cope with the existing pressure on parking at WTP, the proposed new employment park and shopping, casual leisure or tourism visits. We believe that a greater provision is warranted than the 500 spaces proposed due to the above demands. We look forward to working with the Council's consultants in further exploring how Park and Ride could be made to work successfully, through a robust and comprehensive design and operational approach.
Developers south of Warwick are also currently being asked to fund an additional bus resource on service 68. This service is now partly supported by WCC between Warwick Gates, Warwick town centre, and points further west. It is a 30-minute frequency service designed principally to meet essential socio-economic needs. Both in terms of frequency and routing, the service is not attractive to existing car users.
We now understand from the RDS and supporting WSTA phase 2 and 3 that the additional bus for which WCC is seeking funding, is merely to maintain the existing frequency as journey speeds slow down along what is a very long route. This is not what we, and some developers' consultants, have been previously led to believe. This no doubt arises from an assessment of the congestion produced by the proposed development; to allow further diversions into the Park and Ride; and provide possible extensions to serve some development roads. Stagecoach Midlands questions how this is either financially sustainable after a subsidy period ends, of how far such a service will perform much meaningful mitigation. This measure cannot be considered a service enhancement.
A 30-minute service 68 would not be able to perform a meaningful Park and Ride function between the proposed virtual P&R and Warwick, given that if a bus has just left, it would be as quick for a reasonably able person to walk the 1900m to Warwick Town Centre.
There is a large inconsistency between the Park and Ride service specification set out in the Revised Development Strategy, and that actually modelled by WSTA to develop and test a credible highways impact mitigation package. The WSTA Phase 3 model assumes a 9-minute bus frequency to Leamington and 12 minute to Warwick. From what we can ascertain in the Consultation Document, the Strategy and associated infrastructure schedule is seeking funding to maintain a 30-minute frequency on service 68 to Warwick and a new 20-minute frequency service to Leamington. The discrepancy between the RDS proposal and the supporting evidence base offered by WSTA is considerable, and we would appreciate clarification.
The Councils' own evidence makes clear within the results of the WSTA Phase 3 model runs, that should the P&R-based mitigation strategy fail, the implications for the wider network are very serious. This is demonstrated by the queue length outputs, and the average traffic speed outputs, presented at section 9 of WSTA phase 3, and attached appendices D-G. There appears to remain a significant risk that if congestion rises further this will create a vicious spiral of lower bus use, higher costs, and ultimately service reductions, aggravating the problem.
Stagecoach Midlands also wants to highlight the significance of the tradeoffs between the costs of on-site and off-site highways and engineering measures, other necessary infrastructure, and the delivery of other policy objectives.
We realise that the proportion of affordable housing provided is particularly liable to reduce to redress the difficulties of overall development viability.
This is very relevant to the robustness of the Plan, in terms of the opportunity to make best use of sustainable transport. We recognise that the 40% affordable housing target aspired to by WDC is relatively high. Experience nationally is starting to make clear that this does support generation of much higher bus service patronage on new developments.
In order for the package of additional bus services to the area to be sustainable long term, it is very important that the maximum affordable housing quantum is delivered. However, we can already see publicly available detailed evidence, in the form of the viability assessment provided by the applicants at Myton Garden Suburb attached to application W/13/1016,that a level only half that aspired to, may actually be deliverable based on the emerging infrastructure strategy.
On the basis of the above issues we object to the Infrastructure strategy, as it makes little or no explicit provision to rebalance modal dependence in favour of public transport. There is little provided in the way of bus priority and there is a risk that the impacts of the Strategy may undermine current bus operations.
Achieving mode shift and a parallel reduction in operating costs through higher vehicle productivity is of the essence in delivering the optimised transport strategy for the area. We are thus very concerned, that no mention is made of comprehensive measures to assist public transport and redress the current conditions in the area today that all favour personal car use over more sustainable modes.
It should be noted that today a disproportionate level of bus operating mileage within the area earmarked for strategic growth needs to financially supported, compared with the rest of Leamington and Warwick, where services are generally fully commercial. Thus the Strategy needs not only to deliver augmented service that can credibly be sustained through revenue alone at the full build out period, but to recover a modest deficit situation.
The current difficulties operating bus services in the proposed growth quadrant arise to a great extent from historic approaches to land use and urban design. Previously, planning did not make any provision for the creation of effective bus routings. In fact, master planning and detailed design of streets have led to a situation where bus services have had to be retrofitted on some roads within the Warwick Gates development that are barely able to accommodate the vehicles. There is virtually no provision of high-quality roadside infrastructure in the wider area. Any perpetuation of this approach would be inconsistent with NPPF.
We therefore welcome that the Plan Strategy makes explicit reference to high-quality bus stop infrastructure, at least incorporating high profile flags and timetable displays, a suitable boarding area to offer level access to the disabled and infirm, and additionally, high quality shelters where appropriate. We would urge that this takes a more prominent place within the final Plan. Given the difficulties encountered retrofitting bus stops after initial consent we strongly urge that sites are agreed as part of initial master planning at Outline submission stage, where urban design and effective pedestrian accessibility can be considered with bus stop location in the round, and not at the determination of Reserved Matters.
We also support WCC's design standards for residential streets (2002) which requires 6.5m widths to accommodate bus routes, or 6.2m where on-street parking bays are provided. We recommend tracking for 12.2m Scania K230UB or Optare Versa V1200 single deck buses should be assessed to test all proposed bus routes within submitted layouts for fitness. Effective and efficient bus operation means that routes for buses should avoid multiple changes in priority, and sharp bends. Equally, tight radius corners, however subtle the turn, cause buses disproportionate difficulty, and we recommend they are avoided.
Chapter 5.2 Sites at Whitnash/South of Sydenham
We object to the proposed infrastructure requirements as we believe that they will be insufficient to facilitate the provision for sustainable bus service.
The now-consented appeal site south of St Fremunds Way cannot be served by a further extension of service 67, as a further vehicle resource would be needed. Much less will be possible to serve an additional 300 units to the south, for which separate access is envisaged, and therefore an entirely separate bus route would be required. As outlined above, merely extending services into this area at existing limited frequencies will require substantial additional resource, the costs of which, if developer-funded, would neither meet CIL Tests of reasonableness across such a limited housing quantum, nor would it likely to be commercially sustainable at full build out.
As we have said elsewhere, without a bus link across the railway offering scope to tie this area into the wider network to the west we do not see how this proposal can be considered sustainable.
Final Comments
Stagecoach Midlands is very aware that land-use planning must resolve a very large number of conflicting objectives and interests, to the ultimate benefit of the community.
The Company also recognises the particular challenges involved in today's economic climate, and equally respects the plan-making efforts sustained by both Councils and other stakeholders over a very considerable period to date, that have led to the current proposals.
We trust that Warwick District Council and Warwickshire County Council recognise that we are very willing to play an active and constructive role in further shaping the Development Strategy, as key stakeholders in securing sustainable development now and into the future.
Stagecoach Midlands would be happy to meet with representatives from the two Councils, developers and their respective specialist consultant teams as required, to assist in achieving the optimum development strategy for Warwick District over the next 20 years, and to help ensure that the objectives of sustainable development are met in the detailed design of the development proposals.

I am very pleased to see that the Council has issued a Revised Development Plan which acknowledges that the exceptional circumstances needed for major development in the N. Leamington Green Belt area do not exist and have produced proposals which preserve the green area between Kenilworth and Leamington. It is good that housing requirements are being met in a more acceptable manner, with a fair distribution over the District and that most development is provided in areas where there are most employment opportunities. This is a rational and environmentally friendly solution.
I am happy to support the revised plan.

Conservation Advisory Forum
Comments on Local Plan Consultation Housing Sites

CAF Meeting 18 July 2013


* Scale of development. Concerns expressed about impact on Warwick . There will be a 40% increase in the population of Warwick which will have a dramatic effect on the existing settlement and on traffic passing through both Warwick and also Leamington along Europa Way.

* Sustainability. It is not considered to be a sustainable development rather suburban sprawl.

* Traffic impact . Significant concern expressed about the impact of traffic on the Conservation Areas in particular the increased use of Banbury Road and the need for upgrading of the road system and the impact on Castle Hill roundabout and the bridge over the River Avon which is a Listed Building.

* Increase in car usage .This type of development reverses the trend over the past 20 years a small scale infill and the reduction of car usage. These proposals will increase car usage which will impact upon the historic Town Centres, as all the sites are only accessible by car. This will have a roll on effect in terms of the transport infrastructure and will make everyone else use cars.

* Impact on cycling . It was felt there was no scope for cycling because of the intensity of traffic.

* Release mechanism for sites .The release mechanism of sites was questioned. It was felt that the present system will lead to sites being built on regardless of whether there is any infrastructure to support them. A staged approach is needed for any sites within the district.

* Impact on historic buildings .The impact of traffic entering the Town Centre will impact upon all the major junctions and will impact upon the Historic Buildings themselves and the setting of them.

* Thickthorn , Kenilworth .It was pointed out that Kenilworth did their own consultation and have come up with the Thickthorn site as the best of the options if we have to meet the five year housing supply.

* Infrastructure for Kenilworth . Kenilworth needs to have adequate infrastructure of eco houses and appropriately relocation of the various clubs that use the Thickthorn site before development commences.

* Integrated transport system. Kenilworth needs an integrated transport system with a proposed new station, each house being provided with two parking spaces.

* New Hospital .It was felt that to support the level of development a new hospital would be needed in Warwick.

* Transport mitigation measures .The impact of transport mitigation measures on Warwick would include a 3-4 lane Banbury Road development, traffic signals at Bridge End roundabout, effects on Listed Castle Bridge, gyratory system at the Castle Hill roundabout and traffic lights. All roads will have a greater amount of traffic; there will be significant effects on air pollution and the quality of air in the Town Centre. Congestion charges were suggested. It was felt that if traffic was removed completely the High Street shops would suffer.

* Station Approach site - it was felt that it should follow the SBD for that site.

* Student accommodation . It was felt that if more students were to be housed on Warwick and Coventry University sites this would release more houses in Leamington Spa for use by families and would reduce the housing need overall.

We are very pleased that you have taken account of the various points made to you during the first consultation period, in particular:
1. You are basing the majority of the development to the south of Warwick and Leamington on designated development land which is where the businesses are and most of the shopping complexes outside the main towns, and you are making use of the available brownfield sites. There is also room here for improved infrastructure to accommodate this development.
2. You are also spreading the distribution of the housing so that some of it is to the north i.e. south of Kenilworth and at Lillington, although these are smaller developments which can be accommodated by the existing infrastructure, and small amounts of development will be allowed in villages around the district.
3. You have recognised that there are no exceptional circumstances for building on the Green Belt north of Leamington which will preserve the green space between Leamington and Kenilworth.
We sincerely trust that the Revised Development Strategy will be accepted although we do have an issue with the total number of new houses that you propose to build.

I was pleased that you decided to attend the Forum meeting at Whitnash this evening. I have thought for some time it would be good if you could sense the public feeling face to face.

What you witnessed was the outcry of the public against the Local Plan. Unfortunately because the speakers used the majority of the time lecturing the people on the merits of the Local Plan there was insufficient time for many more questions. Many people left because of this. We consider this is all part of the very poor consultation that has been the norm at the public meetings.

If you personally had given a brief introduction then invited questions you would have received the same information that the independent objectors have been bombarding you with since the start of the Local Plan. Together with my colleagues we speak to the people and understand their feelings. They are frustrated because WDC have not consulted them effectively.

The sadness of this Local Plan is that the sheer amount of work that has gone into it by WDC (and no one is denying that) means it has become their baby and they are now trying to defend it and will not listen to any criticism. That clearly needs to change. You have now seen the reaction and hopefully listened to the voice of the people.

If I can now remind you of the exchange of speech's in 'The House' by Chris White MP for Leamington and Warwick, and The Leader of the House - Mr Lansley, that I read out in the meeting.

Mr White: "Residents in my constituency are becoming increasingly concerned about the local plan being developed by Warwick District Council. They feel that their voice is not being respected and I believe that the Council needs to rethink its ill-conceived proposals."

Mr Lansley: "My Honourable Friend makes a specific point relating to his constituency and his local council. I hope that his local council will listen to what he says. The Localism Act 2011 sets out to give power to local authorities and neighbourhood plans, and tries to ensure that they take account fully not only of the simplified national planning policy framework, but do so in the context of local decision making by local people. He is right to stress that point".

The questions you now have to answer are
1. "Are you going to rethink WDC's ill-conceived proposals?"
2. "Are you going to take account of the simplified NPPF but do so in the context of local decision making by people?" On this point and to make it abundantly clear, the local decision making by the local people is they are totally against the Local Plan and are demanding it be scrapped and altered to follow a sensible alternative as has been suggested.

You and your officers have constantly made the point that you would have to have very special circumstances to build the houses in the Green Belt. Now you have very special circumstances. Spelling that out, there is almost total opposition to the Local Plan despite the attempts to sell it to the people. Personally I do not know anyone who is in favour except those who stand to make very considerable financial gains. Their wishes should be the last thing you consider. WDC should not show any allegiance, consideration or support to developers and land owners. Additionally the current planning applications are premature and should be treated as such. There is no proven need for these aggressive plans so they should be rejected totally if they are supporting the Local Plan.

The local people are telling you that the Local Plan is extremely bad planning and is unacceptable, so WDC need to withdraw the Local Plan, reject all planning applications and then listen to the people who are willing to spend their time in order to get an acceptable solution. The reasons given in objections are all very real arguments but have been rejected by WDC as if they were irrelevant. Or officers have tried to convince us of vain attempts to prove that mitigating measures will be taken. The general con-census has sunk to the accusations that someone is living in a dream world.

Ray Bullen spoke last on the 12,300 number of houses that is the core problem that WDC are using to support the Local Plan. We know there is no hard evidence to support the number of 12,300. As we understand, this is not a figure demanded by government so it must have been invented by WDC. The information used is understandably risky and will not stand up to the test of time.
When setting out the framework of the Local Plan, WDC should have made it their aim to satisfy housing needs to satisfy the needs of the local people. That is why it is called a Local Plan. They should not have set out to place the great majority in one densely packed area so the new residents would need to commute to their work place. As there is relatively little unemployment in the District compared with neighbouring Coventry, then it follows that very little new housing is necessary.

It has been shown that by adopting a much lower prediction of 5,400 homes or thereabouts there will be no need to allow any of the batch of applications now being processed.

Furthermore, to be planning now for what will extend as a plan for the next 18 years is foolhardy and extremely irresponsible. It is seen as bad planning at its very worst. When approved in its acceptable form, the Local Plan should only be allowing a phased number of houses each year. Most importantly the Local Plan should be catering for the needs of Local People and it is not doing so.

WDC should have used a more sensible lower figure to cover for the next 5 years. Then proposed to update this on a rolling basis without the commitment to provide infrastructure for the higher number they have adopted. As I have pointed out in earlier correspondence, and supported by my colleagues this would not have needed the concentrated brown areas on your maps as it could be contained by existing housing stock that needs upgrading, together with brownfield sites.

Further to this and even if we did need the 12,300, and we do not, the houses could be spread through the District by either proportional distribution or the creation of a single new site to the West of the District or a number of smaller ones. Leamington, Whitnash and Warwick have been used extensively in recent years for the majority of housing developments with negative effects on that area. These alternatives have been put forward but are not being examined seriously.

Now it is time to stop this rude attack and think again. WDC do not have to hide behind the NPPF or the Green Belt. These are not set in stone and can be relaxed to stop the intentions of the Local Plan. The Green Belt excuse was used to appease North Leamington protesters but we still seek further information on how this occurred and if members of the Council were involved. There must inevitably be a time when the Green Belt will need to be relaxed. That time is now to avoid great harm to the area South of Leamington and Warwick

There must now be acceptance of the reaction of the public and accept that the Local Plan should not proceed.

WDC have constantly defended the support of and allowing the current planning applications that are tied to the Local Plan. Their excuse has always been that if they do not approve them they will go to appeal by and be judged by a government inspector. This excuse has been traced down to the Rt Hon Eric Pickles MP allegedly threatening to tell his inspectors to approve any such plans. This is a really serious turn of events and is being challenged. If that threat exists it must be removed to allow democracy to decide.

Regarding this point, WDC would be expected to do the right thing regardless of such fears they may have. Failure to do so will be an injustice. They are assured the people who are opposing the Local Plan and its planning applications will support them in that regard.

Finally the representative from WCC was considered to be rude and arrogant in the manner he spoke to the audience. He could not see that no one was listening to his ridiculous and dismissive comments about the road network. It would be appropriate if this comment was passed on to the leader of WCC as relevant to the opposition to the Local Plan..

From reading the Revised Development Strategy leaflet and attending The Guy Nelson Hall, Warwick School on Monday 22nd July, I was made aware of the full extent of this plan and the negative impact it would bring to Warwick and Leamington Spa.

I live in Warwick, on Camel Close, off the Myton Road and have lived in Leamington & Warwick over the last 20 years and consider this the most beautiful region in the Midlands.

During my time here, I have seen many changes in the region and with some of the recent developments around the new Morrison's and ALDI stores, I can see that the nature of the surrounding town areas are becoming overly congested and normal day to day commuting becoming more arduous.

When looking at the website for Warwick District Council, I have read the comments from Les Caborn and struggle to understand the points being made, as there is several areas of contradiction:
"Councillor Les Caborn, the lead councillor for the Local Plan said "I believe these proposals set out an approach which will enable the district to continue to grow and thrive, at the same time as protecting and enhancing many of the things that make Warwick district a great place"
Interesting... By exponentially expanding the requirements for new homes, the infrastructure required to support this and socio-economic factors it brings will not protect or enhance our region. On the contrary, it can only been seen that these changes will threat the things that make this a great place to live.

He also says:
"I'm really pleased to be putting forward proposals that provide for some real improvements in housing needs, a new country park, opportunities for employment, as well as transport schemes, schools and community facilities. I look forward to hearing what people think of these proposals."
But what about improving the stock of potential homes we already have available? Would this not remove the issues of additional transport schemes required (which would only worsen the situation), burden on schools, hospitals etc?

When looking at the proposed plans, I have major concerns and therefore need to make an official objection on many levels upon why these plans should be rejected.

1. New Homes and Projected Volumes?
District Council proposal for more than 12,000 new homes to be built by 2030?
This is a staggering amount of new homes to be built. A detailed explanation is required to understand how this calculation has been made?
When looking at the overall census from 2001 - 2011, there has been a steady increase in numbers over that period. When projecting this into 2030, an expansion of 12,000 new homes is an exponential growth. How can this be? With the increase of jobs in the automotive sector, this still does not cater for this growth.
Therefore, it is requested that the calculation of new homes is made available to be verified and cross checked with other external bodies.
See section 158 - NPPF: "Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

2. Empty homes currently within Leamington & Warwick and existing brown field sites
Has the existing stock of empty homes and properties available for renovation within the Leamington & Warwick been considered? Would it not make sense to address the issues in the town to rebuild and improve these properties, which are currently abandoned and derelict? Would it not be advisable on a planning perspective to make good these properties and bring them back into a good condition and build up and improve existing areas given the infrastructure we currently have? Is this not more sustainable?
(See point 17 of the NPPF: "encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high
environmental value"
See point 51- NPPF: "Local planning authorities should identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and, where appropriate, acquire properties under compulsory purchase powers. They should normally approve planning applications for change to residential use and any associated development from commercial buildings (currently in the B use classes) where there is an identified need for
additional housing in that area, provided that there are not strong economic reasons why such development would be inappropriate " - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf


3. Empty Office buildings.
In addition to empty residential homes, is it possible to convert existing business / office buildings into a residential properties. Looking around Leamington and Warwick, there are many areas identified that have been unoccupied for several years. Given the economic climate, it is likely that these properties will remain empty and potentially fall derelict.

As per point (2) and (3), it would only be in the council's favour to allow these properties to be converted into homes, such that they can start gaining revenues for council tax!

In addition to this, I see that additional offices are also being suggested within the plan.. Why are the planners doing this? If we can't fill the existing office spaces around Leamington & Warwick, why are we building new offices?
If there is new offices being built, exactly how many people would it support, if all units were occupied..? Would it cover the additional people moving into the area?
Given the current economic state, it is likely for more offices to remain empty. Given this, if the economy took a further downward spiral in the next 10 years, it is likely that the ratio of unemployed to working people would also rise. How does that help the district to grow and thrive?
See point 51- NPPF: - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

4) Green spaces in Warwickshire
One of the many positive aspects of living in this area is the consideration given to green spaces, that makes this region so special.
When looking at the plans of south Warwick, a large area of green fields could potentially be lost due to the unnecessary expansion between Warwick and Leamington.
In addition to this, it is important to consider proper planning and restraint when converting green field sites to urban sprawl. The conservation of wildlife is becoming even more important, but no references has been made to this within the plans for the protection thereof.
Yes, yes.. I see that there is plans for a country park in Whitnash and Sydenham, but lets not forget, this area is already a green field site. How does overstating this on the plan actually improve the wildlife conservation in South Warwick?

In addition to this, one of the biggest assets in our region is Warwick Castle. Why is it that this is the biggest area of expansion.. This can only be described as wilfully irresponsible, which will ruin one of the things that really makes this a great place.
See section 12. Conserving and enhancing the historic environment of NPPF.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

5) Transport
Currently, the road networks around Leamington and Warwick are barely adequate to deal with traffic today. Most homes will typically contain at least 1 if not 2 cars.
If we draw an average of 1.5 cars per household, that will be an addition 18,000 cars on the road. If only half of vehicles travel through Leamington / Warwick during peak times, that will be 9,000 cars...
Expanding the region to deal with this extra volume will only create havoc during peak periods.
The plans show several 'Grade 1 Junction' improvements. However, the network is fundamentally flawed as there are key bottleneck's. All roads tend to lead through the centre of Warwick or Leamington.
Warwick is not able to further increase the flow of traffic due to the smaller streets. Leamington has several rivers and bridges. Access over these bridges are limited.
Therefore, making better junctions will not improve the situation when adding additional cars on the road.
How can this make our region grow and thrive? What will it do to our open spaces? How would this affect the current lifestyle that we enjoy today? How can our roads be safer with more cars on the road?
Have the planners considered this when building the plan? If so, what is their response to traffic management, other than making roads bigger / wider? (which we suggested does not solve the root cause).
With these issues of traffic build-up within the town, it can be seen that issues along the A46 and M40 will also arise during peak periods, adding to the problem.
See a link to an interesting article published by the Project Manager for Transport and Safety in York.
(http://democracy.york.gov.uk/mgConvert2PDF.aspx?ID=12475)

6) Air Quality
Given the traffic buildup at peak times, the schools and homes based along these main roads, it will be apparent that air quality will be affected. According to tests currently being undertaken, the air quality in certain parts of Warwick are not acceptable and increasing traffic flow by 9,000 - 18,000 cars.
What is the planners response to this? Again, is this responsible planning?
In addition to this, new research proves that air quality is linked to the higher risk of lung cancer and heart failure.
See the following link:
(http://www.guardian.co.uk/society/2013/jul/10/air-pollution-lung-cancer-heart-failure)

See point 124 - NPPF : "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf


7) Infrastructure - Schools - Hospitals - Water - Drainage
With the added demand placed upon schools, expansion of existing schools is required plus additional new schools to be built. What does this mean to the overall quality of the existing schools today? Are they able to adequately expand to meet this demand? Will they be over subscribed per classroom, such that the quality of education in these schools drop?
I have 3 children in Primary and Secondary education and this is a very important concern that I have. Taking additional demand in existing schools as well as building a new school will incur a huge investment, of which children's education could be compromised. How does the planned respond to this? What assurances can they provide, not only for children in the area, but also children who wish to move into the area?

Added demand to Warwick Hospital. This is a site which is set within a residential area. Is it possible to expand this hospital to cater for any additional 40,000 - 50,000 people? What is the planners response to dealing with this additional demand. Are there enough beds within specialist wards within the hospital to cater for this growth? (As point 6 reveals, with the added pollution in the area, additional demands may be placed on hospital services).

Water and Drainage is already something of an issue, as works have been carried out within the town to repair this. How would the additional infrastructure cope with this increase in capacity?
Also, would the building of these new homes be placed on any land prone to flooding? Is this something that should be avoided?

See point 162. - NPPF : " Local planning authorities should work with other authorities and providers to:
●● assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands; and
●● take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

8) Alternative plans?
Given that the expected number of homes appears to be excessive and not clearly explained within the notes, the majority of these new sites are south of the region.. Why? Has it been explored if some capacity could be shared in the north of the region?
The protection of green belt land has been discussed for the North, but this is something that I believe should be explored further. Is it not already possible for the local authority to change the use of this green belt for the north? Why has this not been explored? Why is the focus of all the development concentrated on the south?

Has the planning office consulted with planners in other regions surrounding Leamington and Warwick?
What other plans have been submitted in Stratford or Kenilworth districts? Are there other developments already going ahead that the planners in Leamington and Warwick don't already know about? Is there some planning duplication being made upon the number of houses being built?


As mentioned before, I am opposed to these plans and have described over 8 separate and individual objections.

I would welcome a response to the issues raised and a chance to meet and discuss further.

I have now attended 2 public meetings regarding your proposals and would like to formally record my objection to this plan which in my opinion is ill thought out, incompetent and not in the interests of anyone other than developers.
Where do I start..........
Well firstly the number of homes planned bear no resemblance to what is actually required in the area. Based upon census data from 2001 and 2011 homes for local needs are estimated at 5,400, not the 12,000+ which is the total number proposed the the Revised Development Strategy, with the majority earmarked for the South Warwick area. It came to my attention yesterday that Stratford District Council are also planning circa 4000 homes in and around Gaydon (with 1900 at Lighthorne) to cater for the expansion of the Jaguar/LandRover/Aston Martin facility. It would appear to me that both councils are vying for the same customer for the homes and in reality the volumes planned by Stratford can be removed from the South Warwick plan for this reason (as Gaydon falls under Stratfords juristriction). As these councils share a common border common sense would ensure that there is formal communication between the two parties to ensure a sensible plan for the area as a whole and I believe no discussions have taken place. This should be addressed before any plans are passed. The council will counter agrue that the difference is required to cope with the projected upturn in the economic climate, but the reality is that the land earmarked for employment will cater for circa 2000 jobs. The most recent development at Morrisons has land adjacent earmarked for employment in a very prominent position but this is now being proposed for Retail as business is not interested. So in reality there are too many homes planned with not enough employment opportunities for the prople who may live in these homes - the plan is not sustainable or balanced and is clearly a charter for developers to 'make hay'. This cannot be allowed to happen and must be stopped.
There are also 6305 homes in the district that lie empty. Why are these not being utilised? In the last 5 years a grand total of 251 homes have been taken back into supply. I would suggest that the council should focus more effort into utilising what is already available rather than build more than is necessary
If you look at more recent developments that have been built - Warwick Gates and Chase Meadow, both these developments have proved unsustainable - what evidence is there in place to prove anything will change in this plan. a recent survey has posted that 76% of traffic passing through Warwick is transient and Warwick is a Conservation Area. How will this plan affect the conservation area? The answer is no one knows as this plan does not cover this point.
My main issue with this plan relates to Air Quality and Traffic Congestion which go hand in hand.
Air pollution today is above the legal limits - this will get much worse if this plan is adopted and nothing appears to be happening to resolve todays situation let alone if thousands of cars flood the area if this plan is implemented. As an Asthma sufferer I know only too well how intolerable air pollution is. We are also lucky to have many schools in the Warwick area (Warwick School, Kings High, Myton, Campion etc) with an abundance of playing fields for the children to enjoy sport. Damage to their long term health is already being done with the poor air quality in the area - all we hear from the Council is how they are going to mitigate any further damage but not what they are going to do to sort it.
Anyone who is a local to this area knows that the roads into Warwick and Leamington from the south are unpassable in peak times and that the Myton Road is the same. The council have a poor track record with Traffic flow - look at the debacle on the roundabout outside Morrisons. In the mornings getting off the Myton Road to turn right onto Europa Way is untenable, the traffic lights make the situation much worse (not better). The other way past Myton School and Warwick School are no better, and they want to put another 3500 homes south of Warwick with no option other than car useage (with an estimated 7000 additional cars) to go about their daily events. I said earlier that 76% of traffic through Warwick is transient, this will increase with these plans and the poor old bridge over the Avon will not cope.
Loss of green space and arable farming land - the green land around South Warwick is environmentally sensitive. It would appear that this argument has been dismissed, wrongly in my opinion
Infrastructure has also been overlooked.
Warwick Hospital - can it cope. Discussions have taken place but nobody has said that it can
There are not enough school places for the influx of young people even with the build of additional primary schools
There is no provision in the plan for young people - whare are they going to go, what are they going to do, whatever it is will involve a car journey on gridlocked streets.
Warwick is a beautiful tourist destination with wonderful history and attractions that people travel the country to see. Creating a mass urban sprawl where people are unable to make their way around will be the death of Warwick as an historical attraction and harm local business in the long term.

In closing, the Town Council is objecting to this plan. When the current Prime Minister came into office he pledged that local people would be responsible for local decisions. Its clear from the public meetings that local people do not want this plan to go ahead. Unfortunately our District Council only has two councillors in its executive affected by this plan so politically are not able to make local opinion count.
Everyone accepts there is a need for more housing to cope with local needs, but this plan is not the answer.
One solution would be to make all the brownfield land proposed for development into Green Belt. This can be done and is not illegal (to my knowledge). Making this happen would allow proper consideration of how to allocate development land with due regard to exceptional circumstances required to build on it, and therefore a plan with substinance could be developed

I move for this plan to be rejected in its entirity

I wish to object to the local plan in the strongest possible terms

The projected housing need of 12,300 new homes to be built is much too high. Half this number will be sufficient to meet local needs. It is a complete nonsense to suggest that it is possible to forecast a housing need as far into the future as 2029. It is wrong to allocate greenfield land now based on this wildly inaccurate projection and once used the greenfield land cannot be recovered.
The National Planning Policy Framework requires the approval of sustainable development which meets an established housing need, but planning applications already made or imminent for much of the land meet neither of these criteria. A realistic forecast of housing need would mean that the District already has the required five-year supply of sites, enabling economic growth and matching the housing market.
The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint'. Building on it would merge our built-up areas, turning them into a single suburban sprawl. This green space is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded just as strongly.
Transport: sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to existing road network.

Air Quality: the already illegally dangerous pollution in streets in centres of Warwick and Leamington would be made worse by the increase in traffic. Noise and vibration would be constant, business would be damaged
The historic environment would directly be damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, destroying the first impression of the spa town.
Other Infrastructure: I understand that development would be conditional on it funding schools, and healthcare facilities. As a regular user of the local hospital I know that it is already grossly overstretched and I am very concerned that the funding and provision would be inadequate. There would also be risks to water supply, sewage and drainage.
There are better alternatives. Lower housing numbers which meet local needs, especially for affordable housing, instead of encouraging in-migration; the gradual release of land for development as demand grows; giving absolute priority to using brownfield and infill sites; building homes close to jobs and not mainly within 20% of Warwick District .

Unfortunately I was unable to attend the presentation of the Warwick Local District Plan on 15 July but I have had feedback on the meeting and am concerned that the Council are not actually listening to the residents of Warwick in respect of this plan. It sounds as if the meeting was less of a consultation and more of this is what we have decided will happen. I have serious concerns about the consultation process and the politics of the situation but will concentrate on issues that relate to the planning process. I have sent a copy of my concerns to The development Policy Manager at Warwick District council.

My particular concerns with regard to the plan are as follows:

HOUSING PROJECTION AND LOCATION

The projected housing need of 12,300 new homes to be built seems far too high for the area. While the National Planning Policy Framework requires the approval of 'sustainable development' which meets an established housing need, planning applications already made, or imminent, for much of the land meet neither of these criteria. A realistic forecast of need would mean that the District already had the required five-year supply of sites, balancing housing with employment growth and matching the housing market. I feel it is inappropriate to forecast so far into the future and to allocate greenfield land now. This will allow uncontrolled growth leaving developers to decide what to build and when.

Also, it has been reported that Stratford District Council have approved a "draft" strategy to build a new 4000 home "town" in the Lighthorne area just south of Warwick. If that goes ahead it would also have some effect on the infrastructure requirements, (as mentioned below), within the Warwick Local Plan; yet no mention is made of that scheme has been taken into account when preparing the Warwick Local Plan.

The land between Warwick, Whitnash and Bishop's Tachbrook is rural and agricultural and present policies respect this. Building on it would merge our built-up areas, making them a single suburban sprawl. The green land is as important as the Green Belt to the north of Leamington and Warwick and should be safeguarded.

I feel there are better ways of ensuring there is adequate housing to meet local needs, especially for houses which people can afford such as gradually releasing land for development as demand grows, giving priority to using brownfield and infill sites near schools, shops and railway stations, building homes close to jobs and co-operating with other local authorities, instead of competing with them for development.
ROAD INFRASTRUCTURE:
Much is made in the plan of the proposed improvements to road junctions, new traffic lights, etc. to enable traffic to move faster into Warwick & Leamington, but no solution is given to the problems caused when the cars reach the towns. Warwick has natural "bottlenecks" in The Butts, Jury St., High St., Smith St., Nicholas Church St. Friars St., Hampton St., and Theatre St. etc. etc. Contrary to transport policies, it would make walking and cycling less attractive, and would have serious implications for public transport. No solution to this is offered in the "Plan" and needs to be prior to any approval for new houses.

I feel the historic environment, which attracts so many people to Warwick, would be damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places, e.g. Bridge End in Warwick, Castle Bridge, Castle Hill and St John's.

AIR POLLUTION
Pollution from vehicle exhausts in many streets in Warwick and some in Leamington is already worse than is legally permitted. The District Council is required to improve air quality, but the plan and its transport strategy would worsen it. Noise and vibration would also be constant, businesses and tourism would be damaged and the long-term health of residents of these streets would be even more threatened. The revised plan does not address these problems.

HEALTH
Apart from the additional health problems that can be caused by any increased traffic congestion there is no mention of the capacity of Warwick Hospital to cope with a massive increase in population. The present hospital is surrounded by housing and cannot expand, can it cope with such an increase as is projected by the "Plan"?

SITES FOR GYPSIES & TRAVELLERS
The need for such sites is recognised and the concept supported. However, even a casual glance at the Plan shows a marked imbalance of the distribution of the possible sites over the whole of the District. Of the 20 possible sites listed only four are in the northern part of the District with the remaining 16 in the southern part, with the biggest cluster just south of Warwick. This should be re-examined to ensure a more equitable spread of the burden on the residents of the District. Again, it seems so much protection is given to the green Belt and so little to our other green land.
CLOSING OBSERVATIONS
The above points are general rather that specific but clearly indicate a need for a more "in-depth" approach to what the District as a whole needs. From the information provided the people who have drawn up the Plan do not seem to have considered all the facts nor how to overcome, or at least alleviate, the problems that will be created by placing the bulk of the predicted new dwellings into one main location. To gain the support and the trust of the residents of Warwick District more openness and consultation than in the past is now required. In addition, serious consideration should be given to giving equal protection to open land to the south of Warwick and Leamington as that given to the "green belt" area located to the north of the towns so that all the open "greenfield" sites can be considered equally and the load spread more equitably.

As one of our elected representatives, I do hope that you will do all that you can to ensure that these concerns are addressed.

No credible evidence has been given for the need of 12,300 new houses.

A new sprawl of housing estates over green fields will encourage more car dependency in an already congested area as well as using up good agricultural land.

The suggested plans to 'cope with the vastly increased traffic will increase the already illegal atmospheric pollution to even more dangerous levels, quite apart from making the centre of Warwick unbearable for residents and visitors and creating multilane traffic light controlled road junctions.

There is need for affordable housing, but not in the numbers suggested and not in vast soulless estates to suit developers. A lot could be accommodated with in-fills and brown field locations much nearer shops and schools and other amenities. This would also give a chance to local builders who unlike big developers do not need vast greenfield sites.

I am a resident of Bishops Tachbrook, where I live with my husband and 2 children (aged 4 & 6). We have lived in the village for 8 years and chose the location because we wanted to raise our family in a village setting, away from the town centre.

I have read the WDC Revised Development Strategy (2013) and I have attended a public meeting, where I viewed the WDC RDS PowerPoint presentation. What follows is my considered response to the proposed housing developments and Gypsy Traveller sites.

The RDS completely contradicts WDC's strategic vision "to make Warwick District a great place to live, work and visit" (RDS 3.1).
An increase of 12300 homes will not achieve this vision and will, in fact, have the opposite effect for a number of reasons:
The actual number of homes required to meet the projected population growth in the district is 5400. This is based on factual information derived from the national census statistics, and allows for migration. Where is the evidence to support WDC's claim that 12300 homes are required?
The WDC presentation states that; in order to provide for growth of the local population (RDS 3.5), sites for 550 new homes per annum would need to be identified. Over an 18 year period this totals 9900 homes. Where does this number fit in with the 12300 WDC claim are needed to meet growth?

Why has the WDC empty home strategy not been included in the 5 year plan? WDC has redeveloped 250 homes back to use under this strategy and further homes have been identified. In 2012 www.emptyhomes.com identified approximately 1350 empty homes in the Warwick district. Why isn't more work being done around this type of development of existing homes, rather than proposing large scale new developments. There does not appear to be any mention of empty homes in the RDS.

Warwick District currently has a very low unemployment rate, with only 1.6% of the population claiming JSA. If some of the proposed development is about economic growth where is the evidence to show that people moving into the area will be able to find work?
Much of the employment land in the district has not been fulfilled and may subsequently become land for housing, but where are the jobs for the people moving into the area?
I have heard the growth of Jaguar Land Rover cited as an employment opportunity, which would require homes for employees moving to the area. However, the WDC's RDS does not take account of the fact that Stratford District Council are in the process of consulting on a proposed development of 4800 homes in the Gaydon and Lighthorne area. This would be closer to the JLR than any of the Warwick District developments in terms of homes for JLR employees.
Why have WDC and SDC not communicated about their development plans when they are so close? As a Bishops Tachbrook residents we will also be affected by the SDC plans, as any commuters and/or visitors to Warwick and Leamington from the new developments will increase the traffic and associated problems, noise/ air pollination etc.

The visual impact on the view from Bishops Tachbrook, Harbury Lane, Tachbrook Valley, Gallows Hill will be hugely significant for existing residents but also visitors to the area. No amount of 'country park' can make up for the loss of beautiful countryside and open fields, which would be lost to thousands of homes and the associated environmental impacts such as noise and light (from houses, cars and street lighting). The planning inspector who reviewed the current plan in 2006 said that Woodside Farm should not be built on then or in the future. The WDC's own landscape consultant, Richard Morrish, said in the Landscape Area Statement (2009) referring to the land south of Gallows Hill " this study area should not be considered for urban extension and the rural character should be safeguarded from development". The RDS goes against this recommendation, why?


The local infrastructure cannot support such a significant number of houses in one area. The Southern Site already has significant issues in terms of volume and flow of traffic. The RDS does not contain any evidence to show that the proposed infrastructure improvements would alleviate any of the problems that would come with such a large development. No number of dual carriage ways will improve the flow of traffic through the 'pinch points' such as crossings of canals, rivers and railways and the RDS does not provide any realistically deliverable solutions to these problems. Appendix E of the Warwick Strategic Transport Phase 3 Assessment shows traffic speeds of only 0-10 mph in large parts of Warwick. Any increase in traffic, never mind the exceptionally large numbers proposed in the RDS, will make this situation worse. Rather than increasing trade in the town centre it is likely that people would be put off visiting the shops because of the volume of traffic. This view was supported by the Chairperson of the Warwick Chamber of Trade, who echoed this point at the public meeting I attended.

A lot can be learnt from previous developments in terms of the volume of traffics. The Warwick Gates and Chase Meadow developments prove that the people who move onto these developments will use their cars to commute to/from work and to/from shops and town centres. The bus services serving these developments are not self funding and rely on subsidies to run. It would be naive and idealistic to think that this would be any different on new developments. Most houses have more than one car and most people will drive to work. The location of the Southern Site development would require most residents to commute to work.
A lot can also be learnt about sites identified on development plans for facilities such as schools and play areas, which are not followed through. The Warwick Gates plans contained a site for a school, which was never built. This subsequently put huge pressure on surrounding schools and there is still an annual scrabble for places amongst the Warwick Gates residents, who have a nervous wait to see if their child will get their preferred option. Therefore, I have no faith that if the proposed plans go ahead the schools will come to fruition. Similarly, the Chase Meadow development had a playground site on the plans and again this was not built.

One of my main concerns is the health implications. I have read the Local Air Quality Progress Report (2011) and the areas already identified in this report as 'Air Quality Management Areas' will be affected by an increase in traffic volume as a result of the proposed developments. As Air Quality is covered by the Air Quality Regulations 2000 (amended 2002) and the Enviornment Act 1995, as well as various other legislation, I cannot understand why a full Health Impact Survey has not been commissioned. How does WDC know that the proposed developments will not take air pollution levels above the legal limits? It is not acceptable to just go ahead and worry retrospectively when we are talking about serious health implications. Many schools, nurseries and parks are in the vicinity of the Southern Site and the health of the children who use these facilities could be at risk if this goes ahead without a full assessment of the potential impact of such a large development. I seriously worry about the affect on my children's health and other children in the area. In my opinion this issue should take priority over everything else and I am extremely disappointed that WDC are not giving due consideration to this aspect of the impact on local residents.
In terms of Bishops Tachbrook, the village is already a cut through for many vehicles on their way to/ from the M40. When I walk my children to school in the morning there is a disproportionate amount of traffic travelling through the main roads in the village, in comparison to the number of residents. Speeding along these roads has always been an issue and the speed reduction measures are ineffective. There have been no improvements made to the road systems or pavements in Bishops Tachbrook since the development of Warwick Gates and I see no acknowledgement of this need in the RDS. This is yet another example of WDC failing to recognise and consider the wider reaching impact of large scale housing developments on existing infrastructures. If the proposed development goes ahead it will increase the volume of traffic through Bishops Tachbrook and that will increase the risk to the residents of Bishops Tachbrook, as there are no proposed improvements.

The housing proposed for village settlements has categorised Bishops Tachbrook as the largest type (100-150 homes). The Bishops Tachbrook housing needs survey identified a need for only 14 homes. Again, where is the evidence to support the need for 100-150 homes? Why would this many houses be needed in the village when 3400 homes are proposed for the Southern Site development? With regards to the visual, environmental health and infrastructure issues I echo what I have said in the above paragraphs.

I have read the criteria for the sites for Gypsy and Travellers from the consultation document. I do not think that the proposed sites are distributed evenly around the district and again the south contains a disproportionate number. All of the above points I have raised would also apply to the development of a Gypsy and Traveller site in this area.
In terms of the relevant criteria I do not consider the following sites to be suitable:
Site 3: this site is very remote and does not have easy access to facilities, access, pedestrian access.
Site 4: as above.
Site 5: The access is onto a very busy road and there is no pedestrian access. There would be a visual impact on the approach to Warwick and there is a listed building on the site. There would be undue pressure on the local infrastructure and services of such a small village.
Site 6: has no pedestrian access and is very remote in relation to distance from main centres and services.
Site 9: there would be a visual impact on the approach into Warwick and there are listed buildings on the site. The access is onto a busy road and there is no pedestrian access.
Site 10: Too close to the Guide Dogs for the Blind National Breeding Centre.
Site 15: This site is located on the banks of the Tachbrook. As the proposed site may be used as a place of work there could be a risk of contamination.

The school in Bishops Tachbrook has one class of approximately 30 children per intake. A GT site of 5,10 or 15 could be home to 10, 20 or 30 children. As Bishops Tachbrook is a small school already at capacity is could not support the needs of the site. There are other schools in the district that are not at capacity that could support the need.

The sites around Bishops Tachbrook are too remote to support the development and the village and its facilities are not big enough to support such an increase in population, in terms of infrastructure and facilities.

I understand the requirement for WDC to provide 31 pitches but I strongly feel that a larger number of smaller sites evenly distributed across the district in areas where the existing facilities can accommodate the need is the most appropriate way to meet the requirements.

New Homes and Projected Numbers

I struggle to understand the long term plan to increase the volume by 12000 and in the south of the District by over 4000 in the next phase. This will completely transform the dynamics of the community to the south of Leamington and severely damage the appeal of the area. I would want to see clear evidence that the local economy and new employment will demand such growth. This said, in planning terms the recommended solution seems to be an easy planning option. A huge swathe of housing adjacent to Myton is not clearly thought through.

We already have a large vacant property stock and many brown field sites which with imagination and thought could be brought back in to play to regenerate the town and restore its character.

Why cannot we see smaller developments around the outskirts, both north and south of Leamington rather than one' big bang '.
The constraint of green belt seems to have been overcome and modifications made by other District Councils . Is there joined up thinking across the whole of the County both in terms of policy and capacity?

I am also concerned at the impact the Plan has on the land close to and surrounding Warwick Castle - a major economic attraction to the District.

Office Buildings

Why are there proposals for more office accommodation?
There remain significant office buildings vacant in Leamington - indeed many offices have been unoccupied for some years. Proper planning should bring these buildings back into the equation. They also provide options for redesignation / modification as housing.
In this way the gradual decay of our town centre could be addressed. It remains too easy simply to build outwards!

Transport

The proposed modifications / widening of roads to meet expected volume changes does not acknowledge the fact that as roads draw closer to the centre of Leamington there are unavoidable bottlenecks with simply no where for traffic to go! Peak travel would become impossible if we extrapolate the average number of cars per proposed new dwellings in terms of vehicle growth.

Health Services, Schools and infrastructure

While any developments would need to balanced by additional health centre and GP services it is difficult to see how Warwick Hospital and both its general and maternity services could cope with increased patient numbers which in the long term could rise by up to 50,000 The hospital itself is landlocked with no scope for expansion.

The quality of education in existing schools could well be undermined if capacity is not accurately calculated. I am uneasy about class numbers rising above accepted norms.

Has the current work regarding drainage in the town taken account of the impact of such a large increase in dwellings?


In conclusion I remain very unhappy about the Plan. It does not appear to have been thought through with any in depth knowledge of the District but and with somewhat dubious population statistics and economic forecasts.

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

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

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


2. Principles of the Development Strategy

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

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

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

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

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

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

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

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



3. Proposed Locations for Housing Development

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

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

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

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

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


4. Gypsies and Travellers

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


5. Proposals for Employment Land

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

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

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

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

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

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

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


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

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

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

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

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

Table 4 Revised

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

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

H. Excess providing even more contingency and flexibility 8.9



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

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

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

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

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

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

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

see attachment

I wish to respond to some of the points outlined in the Local Plan:

3.4 Do not agree: has the Avon Bridge been assessed for increase in traffic? Solution: commission report asap. Installation of additional traffic lights not enhancing the aspect in this conservation area.
Solution: decrease in traffic required.

3.5 Do not agree: concentration of 4,500 houses in one area ie to south of Warwick and Leamington. Solution: look for alternative sites

3.5 Meeting Housing Needs: 6,000 required by 2010 so why is WDC proposing 12,000? Solution : reduce stated number

3.6 No mention of air quality ie traffic emissions. Already an ongoing problem identified. Solution commission report to assess impact of increased traffic asap. Solution 2 - reduce number of vehicles in town centre.

3.6 Sustainability: Do not agree - the plan does not meet our current needs and therefore fails this criteria

4.3.10 It was agreed at Area Committee in January 2008 to reduce the volume of traffic in Warwick. So how will this be achieved with the inevitable increase in traffic?
Solution: there is only one way into Warwick from Banbury Road and no viable alternative. Saying that car drivers will use M40/A46 to access roads to north - what evidence do you have? I was told at exhibition "it was hoped this route is used"

5.1.29 This will result in deterioration of air quality ie standing traffic at lights and slower speeds through town.

5.6.1 Have these been tested to a sufficient level of detail?

Public Transport - I do not drive therefore I know the limitations of using buses, reduced evening services, limited on Sundays and Bank Holidays, none on 25th & 26th December. It is not realistic that
residents can rely on public transport. Solution: provide and subsidise
a comprehensive bus system to suit the needs of residents
7 days a week from 6am to 11pm including Sundays and Bank Holidays.

5.6.3 The proposed implementation of blocking the right turn from Smith Street into St Nicholas Church Street will seriously impact on visitors, customers, traders and residents. How is it proposed that drivers wishing to access roads to the south ie Banbury Road or Stratford Road do so efficiently? Solution remove this idea from the proposal.

5.6.5 The introduction of possibly 2 lanes and reduced parking in St Nicholas Church Street is detrimental to this historic road and its residents. It does not seek to reduce traffic, will impact on the poor air quality identified both at St John s and St Nicholas Church Street.
In addition visitors to St Nicholas Church will not be able to access a right turn from their church onto Banbury Road. A crossing across Castle Hill for tourists and residents has been identified as a requirement for safety, how will this be accommodated?

At an exhibition of the Local Plan I was informed that the Plan was rushed through and therefore not passed through the "Plain English" route. I also feel the amount of documentation and short time scale imposed is difficult for respondents to reply to.

My greatest concern is air quality especially in light of two reports recently published in national newspapers concerning traffic emissions.
The Council has a responsibility to ensure that a reduction in pollution is carried out as a matter of urgency.

see attachment

We would like to protest very strongly against the suggested plans for so many extra houses to be built on all sides of Warwick Town.

We live in the centre of the town in Theatre Street and already we are subject over the years to greatly increased traffic which brings with it increased noise, dust, fumes and pollution. This means that even in this hot weather it is far from pleasant to have our windows which front onto Theatre Street open. Added to the already heavy and constant traffic, every time there is an accident on the M40 or Warwick Bypass traffic is directed into the already gridlocked town.

There are a lot of people who live in this lovely town, please do not spoil it by increasing the traffic as every house built will create at least two extra cars to snarl up our narrow and busy roads even more.

Please consider us in your deliberations.

I am writing in support of the New Local Plan Revised Development Strategy.

I feel that, after the original consultation process, the further studies undertaken by the Council have produced a plan which has a sound basis.

It makes sense that most of the new development is located close to where employment opportunities exist with a fair distribution of new housing across the remainder of the District.

The Revised Development Strategy providing for improvement to the road network south of Leamington will undoubtedly reduce existing congestion and will obviously cater for new development and is to be welcomed.


It is essential that any amendments to the plan to not involve development on the North Leamington Green Belt area which, it has been demonstrated meets the five key roles of Green Belt.

I trust that the finalised plan will now be completed and submitted at an early date.

In general I would support the revised development strategy and welcome the inclusion of specific provision for a country park to the south of Leamington.

However, the remaining comments on green infrastructure (GI) are vague and weak and need considerable strengthening. GI is broader than the concept of open space within the Council's Open Spaces Supplementary Planning Document and that document should not be relied upon to define standards of GI expected in growth areas. GI should be integral to any design, not a bolt on. The Local Plan should seek to spell out expectations for GI and it's design.

Areas that particularly need stressing that are largely absent from the present document include

* the ways in which different elements of GI relate to each other, creating networks and corridors of green space, allowing people to move by sustainable, health promoting means within a semi-natural environment and allowing movement of wildlife. The relationship between elements of GI and the networks created are far more important than simplistic quantity standards, but it is very difficult to create these networks later. When making new green field allocations the requirement of well planned, interconnected GI should be explicit.

* the importance of urban tree planting as a vital structural element of GI. Urban trees have significant benefits in terms of mitigating climate change (cooling the urban heat island by both shading and
evapo-traspiration) [1,2], rainfall interception [3], cleaner air [4,5], residents' sense of social wellbeing [6], economic activity [7], crime levels [8] and more [9]. They are increasingly difficult to 'retrofit'
and should be designed in to new development. The Local Plan should be explicit in expecting integration of grey infrastructure with green. In particular there should be a clear requirement that major thoroughfares and a significant proportion of smaller roads be tree lined, and that all new surface car parks be planted so as to eventually provide a closed canopy (car parks being an area that allows large spreading trees). Integration of grey and green infrastructure will require that grey infrastructure is constructed so as to provide a suitable environment for trees and other GI elements to flourish. As the benefits associated with trees are greater with large spreading species, these should be favoured.

As a resident in the District, I would like to register my fundamental concerns to the proposed Revised Local Plan.

There are a number of features that will prove to be serious retrograde steps to the area:

1. Why are brownfield sites not being utilised before new greenfield developments - is it "easier" for developers to go for greenfield sites?
2. The farmland that is now being earmarked for development is medium to high grade and should be retained for its ability to produce multiple crops and be part of the UK agricultural economy rather than requiring yet more food to be ultimately imported
3. The density and volume of new houses - the number of houses appears to be significantly overstated and concentrated to the south of Warwick along Gallows Hill area rather than being spread more evenly (even if the number of houses required is a correct projection).
4. It is not a given that all new residents will work in the same area as they live, therefore congestion is inevitable because of the concentration of new houses to the south of Warwick
5. Likewise the proposed new employment area close to Gallows Hill is likely not needed, there are numerous empty office blocks available for new businesses already existing on various technology parks or other areas around the district. Many that have not been fully occupied since they were built.
6. The density of development means that the very features that attract people to live in Warwickshire will be lost and the developments will just become co-joined, with no distinction between the different sub areas and villages. The attraction of Warwickshire is farmland between and surrounding the town and villages adjacent to Warwick and Leamington, providing space and definition to the residential areas. People who live in Warwick District do not want to live in a housing/pseudo town sprawl. The "country park" that is proposed on the edge of the new Gallows Hill development is a poor substitute for open fields and becomes a semi urban "park" given its location not open countryside. Prior studies that WDC commissioned (Planning Inspector 2006) )stated that the Woodside Farm area should not be built on.

In addition, Bishops Tachbrook, seems to have been "chosen" as a Primary Village for expansion, presumably because of the volume of housing due to be created as a result of the Local Plan. This is based on a poor premise and seeks to alter the dynamic of a successful village. A village has a distinct identity and the boundaries shouldn't be needlessly expanded. The views from the village are of rolling countryside, which would be slowly eroded and the distinct spacing that allows the village to function as a village (rather than as an add on to a new development or Warwick Gates or Whitnash) will be lost. There is real history to the village which would be lost forever. Likewise extra housing and increased attendance at the school will cause more congestion and be dangerous to pedestrians and drivers. The size of the existing roads fits with the size of the village and to expand or widen the road network would again destroy the soul and history of the village, which should be retained for future appreciation by others. Adding on an extra 100-150 houses is also unnecessary, and again a very high volume where the need is not supported or proven.

Gypsy Sites

There are significant concerns regarding the location and number of pitches proposed. Firstly, it should be noted that it is not a given that gypsies would use such sites, in other areas (Shipston) there are sites which were set up but not used. Land that is used by the gypsies tends not to be managed well and so becomes an eyesore to other surrounding residents. The write ups suggest that they will pay council tax but given that many of the gypsies will probably be unemployed there is no motivation to take pride in the surroundings. If the council does not manage these, then there is limited re-course by those potentially affected in the direct vicinity.

The proposed sites, such as those at No's 3, 4, 5,9, 10 and are all located adjacent to busy roads, which would be dangerous to all parties including the gypsies. They are not close to secondary schools.
There is no information on the maximum number of people that would be allowed to stay on the site. The public information states 20-30 number of caravans but that does not give any idea of possible density of inhabitants, which will put a strain on local services.

I sincerely hope you will listen to the feedback the WDC receives and revise the location and volume of development to a less intrusive and a more sensitive number.

I write to raise my strongest objection to the 2013 Local Plan, and the many planning applications that are associated with it - those that are currently under consideration, and those that are undoubtedly yet to come.

This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash.
It also suggests an unfair proportion of proposed Gypsy and Traveller sites in this area particularly in the Parish of Bishops Tachbrook, despite there being brown field sites in the district, (in addition to the vast amounts of Green belt land in the district that would also be more suitable due to infrastructure already in place).

Consideration also needs to be taken to the proposals by Stratford District Council to build a 'New Settlement' of approximately 1,500 new homes at Gaydon/Lighthorne Heath and the damaging affects this will also have on our infrastructure and air pollution levels!! From my own experience of living in Bishops Itchington, people in these villages travel to shop in Leamington for groceries, etc, not Stratford. The town will benefit from increased custom without the need to build excessive numbers of houses in our own district that there is no local need for.

Warwick and Royal Leamington Spa are centres for tourism, not just Stratford!
The proposal to build Gypsy and traveller sites on the main tourist routes from the M40 could affect the visual impact.

Scale and proportion


* massive long term coalescence of settlements,
* loss of significant open space,
* loss of local countryside,
* loss of agricultural land,
* lead to significant urban sprawl.
* excessive bulk and scale,
* significant overdevelopment of the area
* increased air pollution in Warwick Town Centre (already at high levels)


The effect of these potential developments on the existing local communities and infrastructure will be devastating, and I believe have been grossly underestimated by both Warwick DC and the developers.




Effect on local road traffic/infrastructure

The road infrastructure south of Warwick/Leamington and around Whitnash is already stretched.

* 2 or more cars per household,
* 9000 extra vehicles using the local road network.
* the local road infrastructure is inadequate. (e.g congestion on various local roads)
* traffic heading towards the town centres is already a major problem,
* gridlock, increased pollution etc.
* congestion on rural roads outside the town at peak times is also already a problem
* traffic noise,
* potential increased danger to pedestrians and children.

The National Planning Policy Framework, Policy DC7 states:
"Policy DC7 goes onto highlight that development will not be permitted where it generates significant road traffic movements, unless mitigation measures are used to avoid adverse impacts."

These developments will generate significant road traffic movements, and I do not believe that mitigation measures will alleviate the problem, certainly on a local level. If all the developments in the area are given the go ahead as part of the Local Plan, the situation will become untenable.

Effect of local services/amenities

The National Planning Policy Framework, Policy DP2 states:
"that development will not be permitted where it has an unacceptable adverse impact on the amenity of nearby uses and residents and/or does not provide acceptable standards of amenity for future users / occupiers of the development."

* pressure on local schools
* primary schools already oversubscribed year on year
* increased pressure on the local secondary schools
* effect on catchment areas
* effect on applications from siblings of children already in one school
* new schools not "guaranteed" to be built as part of the developments
* limited access to doctors and dentists surgeries in the Whitnash and Warwick Gates and Myton areas already
* effect on increased numbers on the local hospitals

Flood Risk

* already flood issues in Whitnash and Warwick Gates
* scale and density of proposed housing,
* large areas of paved/concreted or tarmac surface etc,



Alternatives to the Local Plan

There are many reasons why the Local Plan represents a disaster for the whole of the South Warwick/Leamington/Whitnash areas, predominantly because of the sheer concentration of most of the districts proposed new housing in one relatively small area.

Alternatives that should be considered include:

* Identifying existing housing that is derelict or currently unoccupied,
* Identifying empty industrial units with a view to use the land for brownfield site housing.
* Identifying an area in the surrounding countryside to use to build an entirely "new town".
* Spreading the numbers of new homes evenly around the district, with lots more much smaller developments.
* Smaller developments given to local builders rather than large national firms, thus helping the local economy.

Applications have already been submitted for land that is earmarked to be part of the Local Plan, before the Local Plan has been fully agreed and approved is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed.

Therefore, I hope you listen to the concerns and suggestions of the residents of your district, and act accordingly. This Local Plan cannot be allowed to come to fruition, and I hope Warwick DC come realize that, withdraw it, and refuse all the various planning applications relating to it, namely:

W/13/0776 - 280 homes at Woodside Farm fields
W/13/0606 - 720 homes on Lower Heathcote Farm land, south of Harbury Lane
W/13/0603 - 370 homes on land west of Europa Way/South of Gallows Hill
W/13/0607 - 220 homes on Hawkes Farm fields
W/13/0036 - 200 homes on Grove Farm fields (application on hold)

I object to the new local plan for the following reasons. We only need 5,400 houses. We do not need 4,000 in Warwick. Increase in traffic congestion and already illegal levels of pollution. Coalescence removing area of restraint. Infrastructure proposals inadequate and insufficient funding available. Increased flood risk. Inadequate sewage capacity. More sewage lorries needed to carry sewage to Coventry. Too many Gipsy sites in south Warwick. Please acknowledge this E mail.

4.3 Broad Location of Development Housing
1. The Council's revised assessment of housing need is welcome, specifically the reductions in the need for large developments on green-field sites by an improved focus on the capacities of urban SLHAA sites and likely windfall sites.
2. The Council's proposals to maintain important green areas, such as the Green Belt north of Leamington and the Asps adjacent to the Castle Park, the creation of a 'country park' along the Tach Brook and proposals for other as yet undefined green infrastructure corridors are also welcome. Further work should be done, however, to ensure the establishment of significant areas of connected green space within all major proposed housing developments in order to minimise the unrelieved uniformity that characterises so many modern large-scale housing developments and facilitate healthier alternative forms of transport. In this regard, my comments on paragraph 5.1 of this plan suggest a possible significant enhancement to the current proposal for the Country Park adjacent to the major development area south of Warwick and Whitnash
3. In particular, however, the location of the bulk of the housing to the south of Leamington, Warwick and Whitnash is strongly supported, not primarily because it minimises use of Green Belt land, although that is important, but because it does not necessitate the construction of an environmentally destructive new road across the Avon corridor north of Leamington. Significant development to the north of Leamington also makes no sense in terms of transport planning when most of the large retail outlets requiring car access are south of the railway and would increase cross-town car traffic - already at its limit because of the barriers of river and railway.
4. Spurious arguments of 'fairness' should be countered with robust defence of planning logic by officers and councillors - in particular in the area of transport planning. The areas now proposed already have good access to the M40, Leamington station and an existing, relatively easily upgradable transport infrastructure. The key transport problems within Leamington are railway crossings. North of the railway, development is currently fairly stable, while almost all of the new road infrastructure and major-volume retail development (Sainsbury, Lidl, Morrisons and Aldi) has been to the South, with further additions recently announced. Placing the bulk of housing development on land to the South of the railway line, with easy access to the motorway and rail network and to most major retail outlets, will minimise the traffic pressures at rail crossings and across the historic centre of the town.
5. There are, however, legitimate concerns for residents in areas adjacent to areas of large housing developments, particularly with respect to transport issues and to the look and feel of their neighbourhood. It is essential that the Council explores all possible options to ensure that these developments do not assume the character of the Warwick Gates development - a ghettoised housing desert of nearly identical builds relieved by few amenities, little communally useful green space, and almost no integration except by car with other areas of the town. It is essential in the major developments now envisaged, that the total outcome is a high-quality integrated urban development, which significantly enhances the overall attractiveness of the southern areas of Leamington, many areas of which seem to have been accorded 'second-class' status in the past.
4.4 Housing allocations
1. One topic completely missing from the current plan is the allocation of land for self-build properties. This has been raised in one of the consultation meetings and in my opinion should be included into the current consultation and review process and into any future reviews of the plan. The lack of land available for self-build in the district is well-known, so addressing this by identifying areas for self-build properties could provide a significant, practical and popular addition to the plan. Self-builds typically deliver higher quality and more varied housing and could provide an important quality-enhancement both to the housing stock as well as enhancing the amenity and character of the area. This could be ensured by requiring all such builds to meet the highest standards in terms of ecology and sustainability and design. It would also help local employment, because such developments are much more likely to use the services of local professionals and tradesmen.
2. In particular, as demonstrated in my submission to the original plan, there is significant scope for beneficial, larger scale development in both Primary and Secondary Service Villages and - in a more limited way - across the totality of the numerous smaller villages and settlements. This should be explored both as part of this plan and any future revisions of it because it is a way of managing development across the district while also minimising loss of/damage to Green Belt areas. Village residents are right in not wanting to have their environments degraded by significant developments, but this applies just as much in already established areas so real issues of 'fairness' lie here rather than in intra-town disputes fuelled by nimbyism. It cannot be right that inhabitants of major local villages parasitise services in neighbouring towns when many such services (schools, shops, health facilities) could with some extra growth in major villages sustainably be provided locally for themselves and adjacent smaller settlements. Apart from the added convenience for villagers, it would also reduce traffic problems across the district. Making self-build land a significant element in village developments (though not only there) could also do much to encourage developments of an unthreatening kind.
3. A further general comment relates to the uncertainty of some future aspects of housing allocation relating to negotiations with adjoining areas. In particular, with respect to the proposed major employment site around Coventry airport and the outcomes of the Joint Strategic Housing Market Assessment undertaken with other councils within Coventry's Housing Market Area, should further Green Belt land be required to provide additional housing in the Warwick District Council area, sites should be identified on the fringes of Coventry adjacent either to the airport development or in the proximity of Warwick University (a major employer located on the border between Coventry and WDC land). In the re-evaluation of the SHLAA presented with comments on the previous plan, a number of suitable sites with potentially significant capacity were identified. As with Kenilworth, there is no alternative to the use of Green Belt land, but all of these were sites where impact could be minimised, especially in conjunction with the development of green corridors similar to those proposed below for the proposed developments south of Warwick and Whitnash.
5.1 Southern Sites: Sites South of Warwick and Whitnash
1. While supporting in general the idea of a Country Park to prevent coalescence with Bishop's Tachbrook, the current proposal privileges only Bishop's Tachbrook residents and those in new developments immediately adjacent to it. It does not form part of any green infrastructure useful to the establishment of non-road transport alternatives or create an amenity benefit across the whole of the new development area. This proposal should be amended and extended to the potential benefit of all residents in the proposed new developments and adjacent areas by, for example:
a) Creating a significant green strip all along the north-eastern side of the proposed South Warwick development area (west of Europa Way, south of Harbury Lane and west of Oakley Wood Road) and south of Gallows Hill, which would both improve the green space and amenity areas to many more southern residents, and facilitate an appropriate base for the establishment of linked amenity areas as well as for a healthy, safe non-road transport infrastructure - for walking, cycling, mobility scooters and other sustainable personal transport devices.
b) Compensate for the loss of building land involved by moving the proposed Country Park to the area of 'possible expansion' shown for it south of the Tach Brook. This could extend right up to the current northern boundary of Bishop's Tachbrook, so facilitating the expansion of non-road transport links with it and ensuring a barrier against future coalescence or development north of Bishop's Tachbrook. If the ideas outlined in my response to 4.4 were adopted, there may be no need for further allocation of building land in this area, but if there were, some suitable space exists south of the current development west of Europa Way, which, but if kept close to Europa Way, would not significantly affect the designated protected area of the Asps.
c) This linked amenities/alternative transport infrastructure could form the basis for further enhancements to an alternative transport infrastructure linking the north-eastern corner of these development sites with the town centre and local retail sites to the potential benefit of many more local residents, especially if complemented by the addition of a new alternative transport crossing of the railway line and canal so better linking the north and south of the town and benefitting all town residents, including car users,. In the longer term this could, with the addition of bike hire as in London, also facilitate in the longer term the establishment of a "park and bike" scheme to complement any virtual park and ride facility south of the town.
5.6 District-wide Transport Mitigation Proposals
Note: In the comments made below, reference is often made in terms of cycling, but it is everywhere intended that these are taken to include walking and use of other low-speed personal transportation such as mobility scooters.
1. In the absence of the time or information to rank these proposals in priority order, it is noted that all seem in principle justifiable. This is, however, far from the key issue, which is the continuing lack of attention to sustainable alternative transport in the Warwickshire area and the continued imbalance towards expenditure on car transportation (specifically cars, because no such expensive works would be required even with a significant increase in public transport). A continuing progressive rebalancing is urgently needed.
2. As outlined, the proposed improvements to the cycle network are piecemeal and will result in little more than one significant cycle route - from Leamington to Kenilworth and on past Warwick University to the outskirts of Coventry - a sort of HS2 for cyclists with few linkages to any wider, safe alternative transport environment. All the rest of the cycle transport network consists and will continue to consist of (slightly upgraded) a hotchpotch of routes, sometimes partial, sometimes on roads, sometimes on pavements, usually ending just before a point where real investment is needed to provide safe facilities for cyclists, frequently ignored by drivers, who drive on them or park on them apparently with impunity because infringements are rarely if ever policed. They are also designed with little consideration of the desire (and need) of cyclists to travel efficiently - crossings and road junctions seem designed primarily for car users and to favour smooth flows for cars rather than for cyclists or pedestrians. Against this background of historical lack of delivery, all of the protestations about maximising sustainable travel, reducing the impact of car-based travel in the region appear to be just more hot air, unlikely to be realised.
3. The Warwick District Council plan requires a long-term strategic plan to establish a basic infrastructure (with targets for initial delivery and targets for extensions and improvements) if the health and amenity benefits of walking and cycling are ever to be properly realised and the mobility interests of disabled people to be addressed. The suggestion of enhanced green-corridors outlined in the comments on 5.1 above could be one element, which could be matched in all of the other major development sites. The strategy should then be to establish a network of major routes for personal non-car/motorbike travel within and between the local population areas, which could inter alia include:
a) a continuous tarred riverside pedestrian/cycle route from Warwick to Leamington with a pedestrian/cycle bridge to cross the Avon and the Leam/Avon junction (this route has been facilitated by the proposals to develop the old Guide Dogs for the Blind property and the 8 metre buffer zone from the watercourse to the development boundary) and would be relatively easy to achieve from St Nicholas Park to the Campion Hills, providing a safe alternative transport spine between the two towns. Appropriate long-term targets would be to enhance this so as to provide, in the longer term, an uninterrupted route with no interactions with conventional road traffic.
b) a continuous tarred canal-side route from Sydenham to Warwick Parkway Station created by cutting back growth and works to maximise the width where possible. Appropriate long-term targets would be to explore options for creating more space underneath existing bridges (perhaps as bridges are maintained/redeveloped), a link to Warwick hospital and railway station and towards the town centre, a link to the new southern development and riverside route, a link to Leamington station and on to Whitnash.
c) a south-north route within the town, from the station across the Leam and Pump Room Gardens and to Clarendon Road up Binswood street and Tavistock Street, which should both be made pedestrian/cycle and deliveries only. An extension up Beauchamp Road to Binswood Avenue would create a very efficient safe path for non-car users, especially children cycling to school, through the town with minimal impacts and possible improved footfall for shops, the loss of relatively few parking spaces and mostly positive impact for car drivers (the main town centre parking sites are along this route - all reachable from Augusta Place, Windsor street and Russell Street).
d) the effective extension of the cycle path past Guy's Cliffe to Coventry by identifying the B4115 as a road primarily for non-car use. This would not require the banning of traffic but through/inessential traffic could be minimised by enforcing a low speed limit and making some sections one-way only, so facilitating car and cycle separation. Long-term targets for this route, which could become the major inter-urban link for the area could include a link from Old Milverton to Hill Wootton with a pedestrian/cycle bridge across the Avon, links to Leek Wootton and Kenilworth across existing pedestrian/farm bridges, an extension from Old Milverton to Trinity School/North Leamington School along the backs of the allotments. An extension into Coventry could also be negotiated.
e) Alternative personal transport users, like car drivers, need secure places to leave their cycles, mobility vehicles, and other equipment. At all important destinations (stations, shopping malls and town centre locations, parks, etc.), provision of spaces where such vehicles can be securely parked should also be factored into a strategy with longer-term improvement targets - preferably with a good proportion protected from the weather and -if feasible - some provision for lock-up storage.
These proposals are not intended to favour the existing cycling community, though they would clearly benefit them. They are aimed at the increasing number of people who would like to cycle, who would like their children to cycle, but fear to do so because of the evident dangers of cycling in an environment which is so skewed in favour of cars that cyclists are ignored and resented in equal measure. Equally importantly, they are also aimed at benefitting pedestrians and the less mobile, who would welcome more, safer infrastructure to facilitate their travel. Safer cycling would increase uptake, reduce school-run impacts and other traffic problems, improve air quality, improve health, reduce healthcare costs - and be much cheaper than conventional roads to establish and maintain. The demographics of Leamington undoubtedly favour a progressive policy of this kind and could help to sustain the attractiveness of this area for young, highly-educated entrepreneurs.

General: We submit our comments on the above with heavy hearts and pessimism that no account will be taken of the points that are made by a very concerned community, who believe our chosen way of life in this lovely Warwickshire area will be destroyed.

Estimated Needs: I question the need for 12,000 new homes in the WDC area. The proposed concentration of 4,5000 homes (1/3 of the total) south of Warwick/Leamington amounts to destroying the green belt - an attractive rural area of the County. This will create an urban sprawl and almost join up Whitnash, Bishop's Tachbrook with Warwick and Leamington. A distribution of houses among all the villages/towns would be fairer and more pleasant for everyone. Is account taken in the draft plant of proposed developments of 1,400 new homes south of Leamington? More use of brownfield sites, such as Ramsay Rd derelict industrial area in Leamington, would be an ideal site for attractive development; bordering on Sydenham estate it would benefit from the existing facilities. It is currently a disgraceful tangle of empty units and overgrown environs. I understand that new homes are proposed for newcomers from cities and towns. Will the idyllic prospect of a rural life be less attractive when it is no longer rural or attractive.

Warwick and the Castle are the jewels in the crown of the area. Motoring to the Castle from M40, J 13 or 14 presents an outstanding journey past an agricultural landscape; this will be destroyed by a development of the size envisaged and detract from the Warwick experience.

Pollution: The air and noise pollution in Warwick centre itself (already at very high levels), will become a health hazard - and added to pollution from the M40 in this village area, will destroy a peaceful, attractive environment of which the District Council should be proud.

Traffic: Congestion of roads already causes severe problems, consequently we avoid going into Warwick and Leamington at peak times. To drive across the Banbury Road from this village to travel to M40 north, Warwick and Leamington, we sometimes have to journey south to join the convoy of cars from Leamington, Warwick and M40 and then find a turning area before proceeding north!

Access into Warwick and Leamington involves crossing one of the five bridges. The delays even now deter us from shopping in these towns to support local businesses, which WDC should be encouraging. Greenfield development would make residents car-dependent and would further increase the traffic flows into and out of the towns.

Provision of extra traffic-light crossroads at such junctions as Bridge End, Castle Hill, Smith Street would destroy the appearance of these unique historic areas.

Urgent attention should be given to providing a Park and Ride facility from near Greys Mallory Island/A46/M40 to Warwick and Leamington. Other towns, such as Shrewsbury, Stratford, provide successfully this useful facility to maintain the environs of their town centres.

Amenities: The impact of a substantial increase in population on the local hospital facilities and services, including car parking, is a matter of grave concern. Journey times to the hospital are erratic, dependent on traffic flows, and can lead to being late for appointments.

Schools: Some Local schools have already reached their full capacity - particularly if, like our village school, they have worked hard to produce excellent standards, Recently a new family to the village could not get their child into the local school and have to transport him by bus elsewhere, thus aggravating road congestion.

Agricultural: The destruction of good arable land into housing estates is a very worrying effect of the Plan. The country needs to encourage and develop farming to provide food for future generations.

Water Supply/Sewerage Can Severn Trent provide adequate services for such a vast development?