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Dear sirs,

I feel the need to email my comments regarding recent consultations and the local plans for development and travellor sites within the Warwick area.
I have massive reservations to both the plans and have listed them below.
I hope that I am in time to make my objections heard within the consultation period.
I would like to comment that we were not informed properly, and only found out about these activities by doing research and talking to others in the local community. Having heard that wheely bins had flyers left on them (we don't have a wheely bin), local radio and supermarkets used as tools (we work long hours and are at work when this must have happened, I must admit I am very disappointed by the councils actions.
I do understand the needs and government requirements but wonder if all consequences have been taken into consideration, Warwick is a small chocolate box town which tourists flock to and local businesses need.

Local development plan
Over 6000 dwellings planned for construction

1- pollution
This area is already measured as above levels of pollution that are acceptable for townships, adding to the number of homes and cars will only increase this unacceptable level. This in turn increases the risks of asthma and other ailments in the young and frail. I would also like to point out that at least 20% of people who die from lung cancer have never smoked, a statistic that should not be ignored when planning to massively increase areas of population.

2 - road infrastructure
The road system around this area cannot sustain the number of vehicles that use the roads. Traffic build up, congestion and long ques are something that we all struggle with. It can often take 45 minutes to drive the few miles from Warwick to Leamington. This is also affecting properties and how stable they are structurally. The M40 junctions near Tachbrook and out to Gaydon already have long ques on the hard shoulder in the mornings where people have to wait hoping that nothing will happen to them whilst other drivers rocket past them at 70 miles an hour.
Surely this will also have an impact on local businesses, as they rely on people passing through for trade, and using the current road systems, I understand that plans to change traffic flows could mean a threat to our small beautiful town. Having had a car written off whilst it was parked outside my home, it is a worry to me that more cars will only mean more risk of damage, and worse.

3 - flood impact
This area does have problems with surface water collection, not technically flooding, but major issues are often seen. Surely new building areas will only increase these problems as there will be less natural land for water to discourse into.

4 - sewer systems
Can the current sewer system take the amount of new homes proposed? Considering that the water board don't have accurate plans for the sewer systems I wonder how this will be reported against and updated.

5 - entertainment for young people
We already have problems with vandalism (especially cars and during holiday periods) in the area and with an increase in homes, families and teenagers it seems only logical that without enterntainments to keep them occupied this will quite possibly increase. I wonder how many times my car will be keyed, bonnet jumped on, wing mirror smashed off, washer jet caps stolen again in the future. I don't have infinite funds to keep repairing damage caused, and would like to see some proper actions made to decrease these.

Travellor sites

1 - access to GP's, schools & public transport
The current population struggles with access to see GP's, and it takes over two weeks to have a scheduled appointment with a doctor or nurse unless you take the tact of it being urgent, an increase in people in the area will only make this worse.
Local schools are already too large, and are struggling with the numbers of children needing places, how can this be managed effectively?

2 - avoiding flood areas
Flood or surface water problems, as we do have surface water issues, which are not recorded and reported against. Making it a little inaccurate to use only a flood report to go on.

3 - noise and disturbance
Wherever there are groups of people there will be noise disturbance.

4 - undue pressure on local infrastructure
With all the activities planned it is clear that this will have an impact on an already fragile infrastructure.

5 - integration in local landscapes
Having seen how a site is left on television program's, I don't feel I understand how this is possible without proper management of sites, which I understand will not happen.

I know not a valid reason for complaint but it was discussed at a consultation meeting that council tax would be required to be paid, but I don't understand how this wil be collected, rates also fall into this.
I would also like to know who will fund the proposed utility blocks.
Could you advise what numbers of sites are required in adjoining wards, as it seems our green belt land percentage is massive and I do wonder if this has been considered.

I hope these reasons can be taken into consideration as being genuine and relevant concerns.

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I am writing to object to the new Local Plan. I am absolutely disgusted that Warwick District Council intends to destroy our lovely town by carving up our beautiful surrounding countryside and building houses, turning Warwick and the surrounding area into a massive suburban sprawl. Our area is renowned for being part of 'Leafy Warwickshire'. If the local plan goes ahead then 'Leafy Warwickshire' will be no more. Our surrounding countryside, which has been here for thousands of years, should be protected and safeguarded for future generations, not decimated by this preposterous Local Plan.
Furthermore, it is abhorrent that you are dumping 12,300 houses on Warwick District. Less than half that number would meet local needs. Warwick and its residents will suffer greatly for many reasons. Besides the fact that the appearance of Warwick and the surrounding area will be greatly altered and ruined for people who live in and visit the town, Warwick is designed in such a way that would not sustain any more people and cars. There is not sufficient infrastructure to support such a massive increase in urbanisation; the District Council's predicted funding and provision for other infrastructure such as schools and healthcare facilities etc. is not enough and there would also be risks to the water supply, sewage and drainage.
There is not sufficient infrastructure to cope with any more people, let alone the massive development that Warwick District Council are proposing. Sprawling development is inevitably car-dependent. Currently the roads of Warwick cannot cope with the amount of traffic that passes through it every day. This plan would just be squeezing more congested traffic onto the existing road network, the already buckling old bridge over the River Avon, and in limited parking areas. At the moment this traffic is causing severe air pollution in Warwick and the surrounding area, which is already worse than is legally permitted. The District Council are required to improve air quality, but the plan and its transport strategy would worsen it. Noise and vibration would also be constant and businesses and tourism would be damaged in these tough economic times. Of even more concern is the fact that the long-term health of residents in the town would be even more threatened. It is disgraceful that you are willing to risk the health of the people who already live here just to fulfil the criteria of your ill-informed and poorly conceived Local Plan.
Moreover, the historic environment of Warwick, which attracts visitors from around the world and of which locals can be proud, would be directly damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge (described as being the most beautiful view in Britain), on Castle Hill, and at St. John's; and on the approach to Leamington via Europa Way.
What message are we sending to the world about how we treat our beautiful historic towns? This would undoubtedly have a dramatic effect on tourism and consequently the economy of the area. We should be preserving our heritage, not erasing our cultural identity and destroying the historic integrity of our buildings.
There are better alternatives to this crazy Local Plan. Please reconsider what you are doing to our wonderful town. If the Local Plan goes ahead then Warwick and the surrounding area will be irreversibly damaged and the town that we all know and love will be no more. It is an issue that many of us are concerned and upset about, but you have the power to change this bleak future for our town.

Whitnash Town Council would like to see a plan for the development of Warwick
District which meets the real future needs of its people, enhances the environment
and improves the quality of life.
Whitnash Town Councillors understand the need for more housing in Warwick
District. However, Councillors are opposed to the density of the development sites
which have been identified in the Revised Development Strategy and the fact that
they are all located in the south of the district. There should be a more equal
distribution of development sites across the district. The impact on Whitnash Town
and its residents is great. Such an excess of proposed developments will be
detrimental to residents as well as the environment, and does not adhere to the
specific principles relating to the key elements of Sustainable Development as per
page 8 of the Revised Development Strategy.
Furthermore:
1. The level of housebuilding proposed may exceed the actual population growth
and demand within the District. The projected housing need of more than
12,000 new homes is too high. We are not convinced with the methodology
that has been used to predict the level of growth needed for the area. We also
feel that forecasting so far ahead cannot possibly give accurate numbers.
2. Building on yet more land around Whitnash will leave little green land left. The
current proposals would just merge our built-up areas and create a single
suburban sprawl. We don't want to lose our green fields. Green land here is
just as important as the Green Belt to the north of Leamington and Warwick,
and should be safeguarded just as strongly.
3. The increase in traffic on our roads will have a huge detrimental impact. With
so much development planned, there will be a phenomenal rise in cars and the
existing road network will be unable to support such an increase. This includes
the bridges over the River Avon which need to be crossed to get to the town
centres of Leamington and Warwick, as well as Warwick Hospital and many
other services. With so much housing concentrated to the south of the town
centres, roads will be severely congested. Access from this area is already
becoming extremely difficult due to already congested bottleneck river bridges.
4. Following on from the previous point, there is a need to improve the air quality
around Warwick and Leamington as it currently exceeds Government
standards. With the proliferation of cars, pollution will increase and air quality
will continue to decrease. This will have an impact on the general fabric of the
area and the long-term health of residents will be affected.
5. Infrastructure needs to be in place sooner rather than later when any
development has been agreed, in order to putt less pressure on already
stretched resources.
6. Whitnash Town Councillors object to the proposed development of land at
Woodside Farm:
a. In the current Local Plan, this is an area of restraint and we would like it
to remain so.
b. Woodside Farm is the highest point in Whitnash and any development
will have an adverse visual impact and also affect the character of the
area.
c. Woodside Farm is the last remaining green area attached to Whitnash
and the loss of this would have a significant impact on the rural
landscape when approaching Whitnash from the south.
d. The high volume of traffic will impact on entrances and exits in Whitnash.
Traffic access from Tachbrook Road is impractical due to the already
high volumes of traffic.
e. The steep incline of land at Woodside Farm, if developed, would mean
flooding of Tachbrook/Harbury Lane, areas that already flood despite it
being a modern junction.
f. Local schools and medical centres are already full.
7. Whitnash Town Councillors object to the proposed development of land south of
Fieldgate Lane:
a. In the current Local Plan, this is an area of restraint and we would like it
to remain so.
b. Development of the Fieldgate Lane site was refused before following
objections from the County Engineers about access from the Whitnash
Road/Golf Lane junction. Nothing has changed at the junction but the
traffic is now greater so the problem is worse.
c. Additional housing will have an impact on schools, medical centres and
local amenities in Whitnash.
d. Access to this development and increased traffic on Golf Lane and
surrounding areas is a major concern.
e. Flooding in the area is also a concern.
f. The Leamington and County Golf Club, has been in Golf Lane for over
100 years and part of the course runs alongside the Golf Lane extension
(a single lane track). If residential development is to go ahead, this track
would need to be widened which would have a negative impact on the
historic golf course. There is also the danger of wayward golf balls on
nearby residential properties.
8. The proposed sites for Gypsies and Travellers are also heavily concentrated in
the south of the district, giving little consideration to our environment and to the
impact on infrastructure. Referring specifically to the proposed site on Harbury
Lane (GTO4), its location does not meet the criteria:
a. It has no convenient access to public transport - it is not on a bus route
and there is no footpath.
b. It is adjacent to a site earmarked for development (Woodside Farm)
which is an area at risk of flooding.
c. Harbury Lane is a fast and busy road - cars often have to be guided off
the football ground site by a person standing across the road checking
when it is safe to manoeuvre.
d. None of these sites are within close proximity of schools, doctors or a
post office for them to change their benefit cheques.
Whitnash residents strongly oppose the Revised Development Strategy and have
voiced their opinions to the Town Council. They are also very concerned about the
severe impact the proposed developments will have on our town. As a Town
Council, we listen to our residents and do our best to support them and represent
them.
Referring to the letter we sent on 27 July 2012 in response to the preferred options
consultation, the comments we made in that letter are still applicable. Please find
attached a copy of that letter which we would like you to include as part of our
response to the Revised Development Strategy.
We feel that more consideration should to be given to views raised by Whitnash
Town Council, Whitnash residents and our neighbouring towns before the Local
Plan is finalised.

Please accept this objection in addition to any others as it contains other information that has come to my notice.
1. There is no supporting Local Plan to allow this application.
2. The existing 2007 Local Plan is still in force and is still relevant to this application.
3. This application has been made by the developer knowing that the current Local Plan would not support it.
4. The application by the developer/land owner has been made with prior knowledge that a new Local Plan was under consultation but not approved.
5. The application is for 220 dwellings but makes no reference to the phasing over the next 17 years. As this is common to all applications that have been made and most likely will be made then it should fail on this point and be rejected.
6. WDC should have made this clear in any discussions with developers but failed to do so.
7. The NPPF came into force in 2012 and should not be assumed or considered to be out of date.
8. WDC have identified and recommended this site as being acceptable for development without any consideration of the harmful effects on the surrounding neighbourhood.
9. This application must not be taken in isolation. It is part of a large number of present and future applications to satisfy WDC's poorly researched information on housing numbers. This may be due to numbers they have accepted from the Minister of the Environment or their own numbers from GL Hearn.
10. The 12,300 is the latest number that is now being quoted by WDC. This has been challenged as being pure guesswork without any positive proof. It has been suggested that 5,400 is closer to the truth following work by a local councillor.
11. It is not being truthful or fair of WDC to invite individuals to object only to the application sites adjacent to their homes, as indeed that is the case of this development. They should be objecting to the total applications under the umbrella of the Local Plan. If that is seen as unsustainable then all applications should be rejected.
12. WDC have put themselves in the position of having to consider many applications to build a large number of houses. It is now a rat race by developers as to who can get in first. This should not be run on a 'first come first served basis'. Applications should be in abeyance until after the Local Plan has been properly consulted.
13. Consultation meetings I have attended all have the same theme. That is to give the public details of what has been decided and ask for questions. There is indication that the massive objection that is taking place will stop the intention of the Local Plan.
14. The Local Plan as seen by the public for the first time was in its final and intended form with no facility to consider alternatives. Therefore it is not a consultation document seeking approval. Rather it is a statement of intent. This must be referred to a Public Enquiry.
15. There are alternatives to creating urban sprawl. A - Proportional distribution throughout the district over 90 to 100 small sites in or adjacent to villages, with no increases for Leamington Warwick and Whitnash that have received the bulk of development over many years. B - Two or Three medium isolated sites to the North, East and West of the District with zero housing South of Leamington and Warwick. C - A new town in Green Belt that is completely independent of neighbouring towns and villages. This would be a challenging but exciting alternative that would give established towns and villages a chance to stabilise.
16. It has never been made clear by WDC that they have supported or facilitated the applications by various developers even though they deny this.
17. WDC are aware that the Local Plan now under consultation has not changed from the previous 2007 Local Plan and are now attempting to convince the public it is a viable and acceptable plan.
18. WDC are in full knowledge that this application is just a part of a massive urban sprawl they have recommended as being suitable for the 12,300 houses they have stated are needed to 2029, without any proof of the needs of those houses.
19. WDC have failed to recognise the severe impact on the present incumbents of a very large area South of Leamington and Warwick that the combined applications would have. So this application like all of the others must not be permitted.
20. By encouraging the various developers (including Gallagher Estates) to submit applications in order to show that the 12,300 houses are deliverable they have effectively isolated each development application from the residents who are not directly joined to every site.
21. By not carrying out a fair and just consultation on this application and con-joining it as part of the overall intent of the New Local Plan, WDC are minimising the effects on the unwitting public of all the applications when combined under the 'Master Plan' .
22. The consultation period for the Local Plan has been extended after public protest. There is still not enough time to complete an effective consultation because of the large area covered by the Local Plan.
23. This application must only be judged in combination with all other present and known future applications. Each application must be placed in a Local Plan Group and considered as such.
24. If the 12,300 number is successfully challenged and kept within a suggested 5,400 this total can be shown to have satisfied the 5 year and beyond requirement.
25. This application being part of the New Local Plan that is to provide housing needs up to 2029 is for 280 dwellings. That should only permit an application for 17 houses each year. Any application in excess of that should be rejected.
26. The laws of supply and demand should be accepted as being the meter for providing houses for those who not only need them but can afford them. The 12,300 number being quoted by WDC is a mythical number with no proof. Therefore the New Local Plan should have recognised this fact and factored the numbers accordingly.
27. Owning a house is the biggest single commitment anyone takes. It is undeniable that of all those who want a house, there will be many who will never afford to do so. Their only recourse is to rent. The houses in this application (and all others) are not aimed at the low cost rental market.
28. The number of people living in the vicinity of 75% of the 12,300 houses who need or will need a house do not represent the need for this number of houses. The truth is that developers are speculating on selling these homes to anyone outside of the area who can afford them. WDC should have recognised this and should only allow developments that are for the local people
29. A result of the above, is that anyone who lives in the area concerned who will be looking to buy will not be able to do so as they are out of their price range.
30. This application will destroy the protecting green area that protects the ancient town of Whitnash. There is considerable wildlife in the neighbouring woodland and the farmland that will be gone forever. This is important and needs protection.
31. The actual site of this application will further disruption to an already extremely busy road.
32. A further proof of supply and demand is that the estate agents are overflowing with houses for sale, but only a few that are affordable.
33. Another fact is that present house owners wishing to move or upsize cannot afford to due to the squeeze from government spending cuts. Their only answer is to extend and even that is very restricted due to the high costs involved and petty restrictions imposed by District Councils.
34. Warwick District Council should not cave in to government demands but should use the ability of elected councillors and the public to protest to the Minister of the Environment.

WDC should revisit its plans and include sites to the north of Warwick and Leamington. Stratford DC are proposing to develop 4,800 new dwellings in the Lighthorne Heath and Gaydon areas. The combined weight of extra traffic these and the Warwick DC proposals will create, cannot be accommodated by increasing the capacity on a few junctions as described as the way in which this can be managed. The pressures on the existing roads are already under strain.

It is important that the character of villages south of Warwick and Leamington do not lose their distinct characters and community cohesion and become suburbs of the two towns.

The figures showing a need for these developments have not been shown to justify these developments. They rely upon unproven demand for movement into the area. Locations to the south of the two towns have extra housing already allocated to them.

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

I write to object in the strongest possible terms about the local plans you are looking to impose upon the district.
After looking into the figures of houses and the locations in which you are proposing to allow construction on I object on the following basis
a) Why are the housing numbers so high
Over 20 years to 2011, population growth was 18% now you propose a further 20% increase in the local plan RDS within only 15 years allowing 12300 to be built. Using projections based on natural growth of the population and an allowance for migration only 5400 homes are required (Ray Bullen paper july 2012 updated using 2011 census data in 2013).
Your own consultans G.L. Hearn gave an economic and demographic forecast study in December 2012 and in their option Proj 5 arived at only 4405 new homes required.
The local area has an unemployment rate of 1.7% so if growth for jobs is the reason for building the new homes, this is not required. The 2012 strategic housing market assessment stated that overall "Warwick District had a very good job-homes balance.
b) Visual Impact
Currently Leamington Spa and Bishops Tachbrook are just visable to one another and these developments would in effect join up the two localities into one sprawling urbanisation. Loosing valuable agricultural land and irreplaceable views. The local planning inspector who reviewed the current local plan in 2006 stated that Woodside farm should not be built on now or in the future. WDCs own landscape consultant Rickard Morrish in the landscape area statement refered to the land south of Gallows hill concluded "this study area should not be considered for urban extension and that the rural character should be safeguarded from development. Why has the district council now gone against that recommendation.
c) Local Infastructure
The local plan RDS does not contain any evidence that the proposes infrastructure developments can be delivered from the developer contributions through section 106 and community infrastructure levy.
With so much unnecessary housing concentrated to the south of the town centres surrounding roads will end up severely congested causing pinch points of crossings of canal river and railways where there is no realistically deliverable solution to the problem. Will the village of Bishops Tachbrook have to contend with further volumes of traffic using the village as a rat run, with even more potential for speeding and accidents and potential fatalities.

With all this extra congestion and traffic surely the air quality will suffer causing more pollution being badly damaging to health. The local economy could also potentially be damaged by filling the streets with intolerable levels of traffic and fumes and not shoppers and visitors enjoying their qualities.
d) Housing proposed for village settlements
The local plan RDS also proposes new housing around village settlements. The allocation of housing is proportionate to the categorisation of the settlement. Bishops Tachbrook has been categorised as being one of the largest type, this means that Warwick District council proposes 100 - 150 homes to be built adjacent to the village envelope. Our own local housing survey found a local need for only 14 homes, 10 affordable homes and 4 "market homes" again the figures looking to be imposed on the village bear no resemblance to the local communities ACTUAL needs.
To conclude the local plan does not set a level of house building which meets population growth within the district building homes that people want and can afford. It is growth for its own sake not the local communitys. It does not make good use of brownfield sites for as much as possible for these developments but instead looks to use high grade agricultural land which is sheer madness with food production ever moving up the agenda, as a nation how can we feed ourselves if there is no land to grow food on. The local plan would worsen air quality in Warwick where the level of pollution is already illegal. The rapid growth being proposed would put heavy pressure on schools and the hospitals, perhaps even on water supplies and drainage. I srongly object to these plans and am disgusted that the local community might have these poorly thought out plans, forced upon us by faceless bureaucrats and big business with no regards for local wishes. The elected officials would do well to remember who elected them in the first place.
I strongly object to these plans and wish to place my views on record.

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1.1 In its Local Plan Revised Development Strategy, May 2012, the Council [in para 2.2] invites comments on the proposals. Here are the comments of The Warwick Society.
While the Society's main concern is that a better Plan must and can be proposed, these comments are necessarily framed as objections, to make it clear that the present proposals are unacceptable to many residents of Warwick and its neighbourhood as well as to the Society.
Just as the Revised Development Strategy [its para 1.4] focusses on the main changes since the Preferred Options proposals, so this response is to be read alongside the Society's letter of 27 July 2012 commenting on the Preferred Options, of which a copy is annexed, pages 6-10.
1.2 The Warwick Society, the town's civic society, was founded in 1951. It has as its first aim
to conserve, for the benefit of the public, or to encourage the conservation of,
the natural, artistic and cultural amenities of Warwick and its neighbourhood.
It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people. The history and the architectural character of Warwick, which make it one of the most distinctive towns of its size in Britain, were summarised in the Society's letter of 27 July 2012 .
1.3 The Plan and its Development Strategy give an opportunity to make the town and the district around it a finer place, and a better place to live in, to be educated in, to work in, and to visit. It is well-placed at the south-eastern corner of the West Midlands for sustainable development, prosperity and continuing attractiveness. The requirements for a Plan pursuing these ends were summarised in the Society's letter of 27 July 2012 . That letter continued :
The Preferred Options fail by a long way to achieve this. The Issues identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.4 We greatly regret that, in the face not just of the Society's objections but also of strong criticism from the overwhelming majority of respondents to that consultation, the Council proposes an RDS which would do even greater damage to Warwick and its neighbourhood.
97.5% of respondents objected to development of the land south of Warwick. The Council's retort has been to increase substantially the number of houses proposed for that area, postulating that public opinion carries little weight in such decisions.
The arrogant disregard of the Council for the views of residents and other interested parties is itself cause for objection to the RDS.
1.5 The RDS has many accompanying documents. It is a further sign of the attitude of the Council to public involvement that all have been issued simultaneously, giving residents and other interested parties only six weeks during the summer holiday period to understand, discuss and respond to material which has taken well over a year for many council staff and consultants to produce.
As well as much more material in the 'evidence base', these accompanying documents include:
Sites for Gypsies and Travellers, raising concerns for residents adversely affected by the RDS by proposing a majority of the twenty potential locations for the three sites needed throughout the District in the same concentrated area close to Warwick;
The Community Infrastructure Levy Preliminary Draft Charging Schedule, which is not referred to on the Council's webpage notifying us of the consultation on the RDS and G&T sites but only on a later, subsidiary page;
The Final Interim SA Report, which disguises its purpose - Sustainability Appraisal - behind its acronymous title, is neither notified on the webpage outlining the two 'main' consultations, nor referred to at any point in the RDS which it purportedly supports; and
The Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3, which proposes the reversal of existing policies to reduce the impact of traffic in Warwick Town Centre but is not itself the subject of 'consultation'. The County Council unilaterally abolished the Town Centre Forum late in 2012 and has done nothing in the intervening eight months to implement the new but less effective process of discussion with which it proposed to replace it.
1.6 We explain hereafter as briefly as we can our main objections to the Revised Development Strategy. We do not comment on the Final Interim SA Report nor the Warwickshire County Council Warwick Strategic Transport Assessment - Phase 3 or the other accompanying documents, but have many observations on their assumptions, analysis and conclusions which we will make separately.

2 Housing Need
2.1 The criticism of the methodology and the outcome of the housing need projections made in our objection to the Preferred Options , stands. The proposed figure of 12,300 new homes to be built is much too high. We note that it is a provisional figure, pending completion of the joint assessment being carried out with councils in Coventry, Rugby and Nuneaton & Bedworth. It must also be dependent on co-operation with Stratford District Council over its proposal for a new settlement at Gaydon, which might be superior to much of the proposed development south of Warwick in meeting housing needs for employment there.
2.2 You have yourself stated, at the Community Forum meeting held at Warwick Gates on 13 June, that half of those new houses would meet local needs and half would be for incomers . In our view, even less than half of 12,300, under 6,000, will be sufficient to meet local needs, and we refer to the analysis carried out and discussed with you by Ray Bullen for Bishop's Tachbrook Parish Council which supports our conclusion.
2.3 Forecasting as far into the future as 2029 is clearly very uncertain. By fixing now a single end figure, based on assumptions and trends and 'compound interest' - incurred by repeating small percentage differences over many years - the RDS projections can only have one certainty - that they will be wrong. Worse, by taking this single long-distant future figure and giving it short-term weight, in allocating greenfield land for development now, the damage of error will be immediate. This approach is akin to having no plan at all, allowing uncontrolled growth, leaving developers to decide what to build when, with our towns, villages and countryside blighted by the effects of false certainty and a National Planning Policy Framework which seeks development at all costs.
2.4 While the NPPF requires 'sustainable development' which meets an 'established housing need' to be approved , planning applications already made or imminent for much of the land south of Warwick meet neither of these criteria. A realistic forecast of housing need is that the District already has the required five-year +5% supply of sites. Using the exaggerated and uncertain RDS projections in support of short-term, expedient planning applications - which could over-ride the Plan process before it reaches Examination in Public - would open the Council to legal challenge.

3 Prudent use of Land and Natural Resources and
Protection of the Natural Environment and Landscape
3.1 The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint', designated at the time of the construction of the Warwick Technology Park, and intended to give permanent protection to this vital green gap. The Society has repeatedly suggested that it should be designated as Green Belt, but the Council has refused to implement this.
3.2 Building on it would merge the built-up areas, turning them into a single suburban sprawl. This would conflict directly with one of the principles of the Local Plan Strategy, 'avoiding coalescence' .The green space between the built-up areas to the south is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded as strongly.
3.3 Once developed, this green land could not be reclaimed. Its development would conflict with the basic principle of sustainability, 'meeting the needs of the present without compromising the ability of future generations to meet their own needs'

We use the term incomers as being less ugly than the technical term in-migrants, regretting that there seems to be no expression which is not pejoratively confused with the word immigrants; we refer to people moving into Warwick District from other areas, noting that encouraging the movement of better-off people from the West Midlands conurbation and Coventry may be one of the objectives of developers in Warwick District, and perhaps of the Plan.
Your word not ours; Revised Development Strategy, page 8, third point from bottom
Report of the World Commission on Environment and Development to the General Assembly of the United Nations, 11 December 1987
4 Sustainable Transport and Reducing the Need to Travel
4.1 Sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to the existing road network. While the Local Transport Plan gives priority to sustainable means of transport in the hierarchy - walking, cycling, public transport - the Transport Strategy assumes that these developments would have the same ratio of peak hour car use to housing numbers as every other development of recent decades.
4.2 Development at relatively low density cannot effectively be served by public transport. The low concentration of the population does not provide sufficient volume for a bus service to run viably at a frequency which makes it an attractive competitor with car use. The limited influence which the County Council has over operators of unsubsidised commercial routes make it unlikely that a bus service would survive after the first few years of developer subsidy, as has been seen at other sites including the Hatton hospital redevelopment.
4.3 Whatever the fine words about walking and cycling routes within the suburban developments, these sustainable modes will not make a significant contribution to meeting transport needs. Distances will be too long for walking, for example from the areas south of Warwick to the town centres or railway stations; and cycling will be very unattractive as soon as cyclists reach the road network on which the use of cars has been intensified. The putative designs of new junctions in the Transport Strategy make it clear that the design priority would be to maximise the flow of vehicles, with people on foot and cyclists diverted to circuitous routes, with secondary priority at traffic light controlled crossings.
4.4 The Transport Strategy concludes that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. The infrastructure plan proposes spending almost all of the potential developers' funding contributions on intensifying the use of the existing road network. The schemes that it labels 'junction improvements' and 'mitigation' would be improvements only in maximising the flow of vehicles; and mitigation only in reducing the increase in congestion, while increasing not reducing the impact of traffic on town centre streets. They would both make sustainable modes less usable and damage the historic and natural environment with the intrusive impedimenta of the highway engineer.

5 Air Quality and Climate Change
5.1 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 and business and residential amenity would be damaged.
5.2 No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, and in particular to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings, all require air quality to be given absolute priority.
5.3 It has been suggested by the Council's Chief Executive that the air quality requirement could be met after development has been approved by then considering ways in which traffic through Warwick town centre could be reduced. This approach would invalidate the Transport Strategy, as the only way to reduce the volume of traffic would be transfer to other modes or other routes, neither of which has been assessed in the Strategy. A transport plan which meets all the objectives, including protecting the historic environment and assuring air quality, must be agreed before development is allocated.


6 The Historic Environment and the existing built environment
6.1 Warwick's historic environment is vital both to the social goals of the plan, to give people a sense of place and belonging, and to the economic goals as the basis of its visitor economy. It would be directly damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's.
6.2 Development on the land between Europa Way and the Banbury Road would extend sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would directly damage the Castle Park, Grade 1 registered landscape; and the 'junction improvements' on the Banbury Road would damage its rôle as part of the Castle Park planned landscape.
6.2 The historic environment would also be indirectly damaged by the effect on the economy of the town centre streets being primarily a conduit for through traffic, constantly full of fumes and noise, and with their commercial premises split from each other by queues of vehicles. The damage to the commercial success of the town would lead to a longer term indirect effect of reducing the demand for such premises, residential and commercial, and a fall in their maintenance funding. There is a real risk of the town centre hollowing out, in a miniature echo of the great American cities, becoming a poor quality zone in a car-based suburban sprawl.

7 Other Infrastructure
7.1 While in theory development would be conditional on it funding schools, and healthcare facilities, strong concerns remain that the funding and provision would be inadequate, and that there would be risks to water supply, sewage and drainage.

8 Alternatives to this Plan and Development Strategy
8.1 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 ... many options exist but have not been given proper consideration in the preparation of the RDS.
8.2 Absolute priority should be given to brownfield sites, with greenfield sites only being allocated when there is a proven immediate need. This will ensure that more brownfield sites become available, their value increased by the non-availability of easy, profitable alternatives for the mass housebuilders.
8.3 While a year ago the IBM/Opus 40 site on the north-west edge of Warwick was to be used for office development, it is now likely to be proposed for housing. It provides a good example of the way in which long-term plans are by their nature crude, and that housing sites can be found on brownfield sites well-connected to the transport network.

9 Conclusion
9.1 In objecting on these strong and numerous grounds to the Revised Development Strategy, the Society offers its assistance to the Council in the necessary task of devising a better alternative, with the full involvement of a wide range of residents and business interests.
1.1 In its document Local Plan Preferred Options, May 2012, at para 3.3, the Council invites the views of all interested parties to help shape a draft Local Plan.
1.2 Here are the views of The Warwick Society. They refer to the Full Version of the Preferred Options and in some cases to some of the supporting documents made available on the Council's website. The Response Form, which we have not found effective for structuring our comments, uses the words 'support or object' rather than the Preferred Options' 'the Council is keen to hear the views'. While we have phrased our comments as views, it will be clear that many would be objections to firmer proposals, and will become formal objections if the next stage of the plan-making process does not respond satisfactorily to them.
1.3 The Warwick Society, the town's civic society, was founded in 1951, and has as its first aim to conserve, for the benefit of the public, or to encourage the conservation of, the natural, artistic and cultural amenities of Warwick and its neighbourhood. It seeks to improve standards of new development to benefit both the setting of the old buildings and the life of the town and its people.
1.4 Warwick is no stranger to development. The mediæval town was largely destroyed by fire in 1694, though many timber-framed buildings at its fringes survived. Rebuilding followed a plan to widen the streets and to improve fire-resistance with stone and brick walls. It took place at the start of the Georgian era. So the High Street, the Cross, Church Street, St Mary's Church and Northgate Street form an elegant and coherent architectural ensemble. It is the juxtaposition of the mediæval with the Georgian which makes Warwick distinctive. More recently, C19 industrial development based on the canal and then the railway has been followed by more extensive C20 sprawl based on the car and the road network. In the decade 2001-2011, the population of Warwick grew from 23,000 to 30,000, a rate of increase of 30%, among the very fastest rates of any town in the UK. Assimilating this growth and building new communities takes a generation.
1.5 The new Local Plan gives a new opportunity to make the town, and the district around it, a finer place, and a better place to live, be educated, and to work in. Its population may grow, because it is attractive, and well-located at the south-eastern corner of the West Midlands. Its future residents, and those who work here or visit, need a vision which ensures that it continues to be attractive, and to function well.
1.6 This means:
1 Developing the local economy sustainably, both facilitating growth in jobs and income and reducing the impact of climate change;
2 A pattern of development which reduces dependence on the car, congestion and pollution;
3 Transport and social infrastructure which enables people to live sustainably and economically;
4 Walking routes, cycle routes, schools, health centres and shops which allow people of all ages and capabilities easy and healthy access to them;
5 A mix of housing which meets local needs, especially affordable housing for families;
6 A rate of development which allows the towns and their communities to absorb change and make each a socially and personally contenting place to be; and
7 Protecting the natural and historic environment, especially the green hinterland of towns, green spaces within them, and the historic buildings which make them special places.
1.7 The Preferred Options fail by a long way to achieve this. The Issues [para 4.8] identified in the earlier consultation correspond quite closely to those that we have emphasised. But the preferred options focus heavily on growth and new development, disregarding the relatively low priority given to them by those who responded to the earlier consultation, and disregarding the negative effects of excessive growth and development on the matters that residents consider important.
1.8 In the following sections, we consider the three main ways in which the preferred options fail to meet the expectation of those who live in the District, and suggest changes which, if introduced to the draft Local Plan, could make it a very much better direction for the District to follow.

2 Population Growth and the Demand for Housing
2.1 The Preferred Options' emphasis on growth in jobs and housing, each matching the other [para 4.10], is founded on a circular argument and on mere assumptions.
2.2 The Strategic Housing Market Assessment [para 5.13] 'projects' (not forecasts) future growth in the District's population. It explains [SHMA figs 2.13 and A2.4] that 'in-migration' has been much the most important cause of population growth in the fifteen years 1996-2010. Of a total population increase of 18.9k (from 119.8k to 138.7k), 16.5k has been net in-migration, and only 2.4k the natural change. The report notes [para 2.33] that 'past migration trends will have been influenced in part by past levels of housing delivery.'
2.3 The SHMA assumes the average rate of in-migration of the last five of those fifteen years, 2006-2010, and projects it for the next twenty. There is no quantified analysis of the causes of the in-migration, nor any quantified forecast of its future level. It is simply an assumption.
2.4 The SHMA goes on to assume an age profile for the in-migrants, again basing its projection on neither evidence nor analysis, but on assumptions, in this case those of the ONS [SHMA para 2.17]. The projection of net in-migration is the difference between two much larger numbers, gross in-migration and gross out-migration, and the in-migration figure is produced only by adding that assumed net projection to the ONS assumption of out-migration. The projection is not a forecast, just an arithmetical exercise, and its predicted growth in population is no more solid than the assumptions and extrapolations on which it is based.
2.5 The extrapolations have as their base the after-effect of rapid housebuilding in the years before the market collapsed in 2008. All that they show - as described at the end of para 2.2 above - is that if houses are built, people will move into them; in a second circularity, if the mass housebuilders do not believe that their output will be sold, they build little. A third circular argument then enters the Plan as it stands: if the population rises, employment will rise, as those who buy and occupy the new houses are very likely to have jobs - without which they do not have the means to buy the houses.
2.6 We conclude that the preferred level of 'growth' is simply a bid for growth, rather than a forecast for which there is either evidence or action plan, other than almost free-for-all development with all of the negative impacts on existing residents and the environment that that will bring. The alternatives of more modest levels of growth, in both housing and employment, with much lower damaging impacts, would be equally valid for the Council to choose. We urge that it should reconsider its preference in the light of the absence of evidence in support of it, and take a broader view of both growth and all its consequences.

3 Infrastructure
3.1 The infrastructure proposals do not provide for sustainable development. The modelling of the existing network against possible locations for development consists only of modelling vehicle flows. It does not reflect the national polices and Local Transport Plan which require priority to be given to reducing the demand for transport, and to walking cycling, and public transport.
3.2 Except for the possibility of Kenilworth station (which would have a negligible impact on demand for road use in the peaks) all of the significant infrastructure proposals are for increases in the road network. They have been selected to deal with some of the local congestion created by increase in demand of the various housing site options. They do not provide a coherent transport network for Leamington, Warwick and Kenilworth, rather a continuation of the existing mismatch between traffic and the capacity available to accommodate it.
3.3 Good railway services are already provided at Leamington and Warwick Parkway stations. The level of service at Warwick station is significantly inferior to that of Warwick Parkway, even though it serves a much more substantial population within walking distance. Conversely, almost all access journeys to Warwick Parkway are by car. For journeys to and from work, Birmingham and London are significant destinations and there is some commuting in to Warwick and Leamington which is badly served by Warwick Parkway. The basis of a sustainable infrastructure plan should be to improve train services at all three of these stations, and especially at Warwick station, and to concentrate development close to them, minimising car use. This possibility does not appear to have been considered.
3.4 The conclusion of the modelling is that the existing level of congestion on the urban road network in Warwick, and elsewhere, will be worse than now for longer each day. No attention has been given to the requirement to reduce the impact of traffic on Warwick town centre, in particular to meet the Air Quality Management Area requirement to reduce the level of noxious emissions. This failure invalidates the infrastructure plan. The health of residents, as well as the town centre economy and the conservation of its historic buildings all require that the legal requirement to restore air quality should be given absolute priority.
3.5 Instead, the infrastructure plan proposes spending almost all of the potential developers' funding contributions on major expansion and 'improvement' of the road network. The lesson was learned decades ago that changes of this kind, increasing capacity on some congested sections, simply increases congestion on adjacent parts of the network, through the traffic that the improvements generate.
3.6 We are disappointed and concerned that the preferred options do almost nothing to allow transport demand to be met more sustainably, rather simply try to accommodate it at the expense of the environment and of existing residents and road users. We consider that the whole emphasis of the plan should be above all on sustainability of transport, not just for its environmental impact but also because the prosperity of residents of the district depends on accessibility to services without having to meet the increasing costs of car use.

4 Locations for Development
4.1 Much of the criticism of the Preferred Options has been directed towards the allocation of particular areas of greenfield land at the fringes of the urban area on which large-scale house building is proposed. These sites represent a major misdirection of development. We consider that, rather than the strategy of the Preferred Options, the pattern of development in the district should be dramatically different.
4.2 The total level of development should be substantially lower, of the order of 250 dwellings per annum, Option 1, which is sufficient to meet local needs and not to encourage in-migration.
4.3 Unbuilt existing permissions themselves provide nearly five years' supply to meet this level of requirement.
4.4 Beyond these absolute priority should be given to brownfield sites, as provided for by the NPPF. The Preferred Options propose only that brownfield sites should be used at the end of the plan period, the effect of which would be to consume greenfield sites rather than to bring forward brownfield sites by increasing their value. Some brownfield sites may provide for small numbers of dwellings, but these should not be dismissed: there are potentially many of them.
4.5 Brownfield development should include the intensification of existing development within the urban areas. We do not rule out 'garden development', which can often be in locations close to existing facilities and employment and easily served sustainably. There are extensive areas of development carried out mainly in the second half of the twentieth century where more intensive use of existing housing and employment land would be entirely feasible - were the market signals to encourage it. The proposals for much more intensive office use of the IBM/Opus 40 site on the north-west edge of Warwick go too far in this direction, but demonstrate that intensifying development on a site well connected to the transport network can be attractive to developers.
4.6 Only as a last resort should greenfield land be allocated. The suggestion that it can produce high-quality environments by applying the principles of the garden cities is spurious. The garden cities were planned around local employment and services (in the era before the car, competing supermarkets, choice of school admissions, and two-income households became the societal norm): that is not how we live now. All of the greenfield sites at the urban fringe would be largely car-dependent. As well as their damaging impact on infrastructure and on existing settlements, they would not produce stable, happy communities of their own. The rapid growth in population of Warwick in the last decade requires a period of much gentler growth while the new communities gel.
4.7 The allocation of land south-east of Warwick between the Banbury Road and Europa Way does exactly what the Preferred Options say that they wish to avoid, merging the built-up areas to their east and west. The northern part, north of Gallows Hill, would make Warwick, Leamington and Whitnash into a continuous, sprawling urban area. The southern part, between Europa Way and the Banbury Road would extend this sprawl beyond the natural existing edge of the built-up area, taking development over higher ground and visible from long distances. It would have a directly damaging effect on Castle Park, Grade 1 registered landscape.
4.8 The Green Belt was established to end the outward sprawl of the major conurbations. Circumstances change and there may be exceptional reasons for declassifying Green Belt land: the expansion of Warwick University may be a virtuous case of this. But it is essential that its edges should not be eaten into by extending urban sprawl, for example at Loes Farm and north of Leamington, in the opposite direction from that which it was originally intended to prevent. Similarly, when the Green Belt was designated land south of Warwick and Leamington was not seen as threatened by sprawl from the conurbation simply because the towns stood in the way. Now, that land requires the same level of protection as the post-war Green Belt gave to the edge of the Birmingham and Coventry built-up areas.
4.9 Instead, the Green Belt has become the guarantor of favourable surroundings for the few residents in and outside villages scattered across it. Given the severe damage to the existing urban areas that would follow from their outward extension, an entirely different approach is required to find acceptable greenfield sites. The possible 'Gateway' development around Coventry Airport is an example of this approach: it must concentrate employment and housing close to good transport links without creating undue pressure on the existing urban areas. Planned new or enlarged settlements outside Warwick, Leamington and Kenilworth, and in some cases outside the district - delivered through cooperation with neighbouring authorities - should also be preferred. The substantial employment at Gaydon is not matched by housing provision in the locality, rather met by car-borne commuting to it. Warwick Parkway station and the nearby A46 provide an opportunity not for an urban extension but for a new settlement outside the existing urban boundary, which would not damage what lies within it. Hatton and Lapworth, with existing railway stations, could also be the focus of much more extensive development than is proposed.

5 Conclusion
5.1 We have concentrated on the three main ways in which the preferred options would both worsen the quality of life of the district's residents and damage the historic environment.
5.2 In the copious supporting documentation, there are many more details of the proposed policies which we cannot support.
5.3 But we have limited our comments to these three main issues to try to persuade the Council that the eventual draft Local Plan must be very different from the Preferred Options now proposed.
5.4 We urge the Council to reconsider its preferences and to recognise its long-term responsibility to both the environment and the quality of life of Warwick district.

see attached

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

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

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

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

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

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

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

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

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

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

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

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

I am writing to express my horror at the new draft Local Plan and the threat it poses to the local area. This plan flys in the face of concerns expressed during the 2012 Local Preferred Options consultation and goes against the professed "Vision" and aims of Warwick District Council. If the Council goes ahead with this it is ignoring its own promises to local residents and the opinions of the local people whose taxes are funding the Council.

The new plan involves an excessive number of new houses concentrated in a small rural area, replacing agricultural land with an urban sprawl. Calling the development a "Garden suburb" will not change the fact that we are talking about thousands of houses on greenfield land. This many houses are NOT needed and certainly not in one place. The local need is for fewer than 6000 new houses by around 2030. This proposal is for more than double that, with 4500 of them south of Warwick. This is larger than the village I live in, which has grown gradually over hundreds of years. Building such a volume of housing all at once, in one area is reckless and unnecessary.

The Council states in its plan that it wishes to "Avoid development in locations which could potentially lead to the coalescence of settlements". Leaving a small section of land around the Tach Brook as the only space between a new sprawl of housing connecting to Warwick Gates, to Whitnash, to Leamington and Warwick is an insulting token gesture and does not address the concerns raised by residents of the area in the Preferred Options consultation of last year. Describing this land as a "Naturalistic open space/ buffer" says it all. We do not want a tiny strip of "Naturalistic" land, we want the natural landscape and agricultural land that is there now. To insinuate that this buffer will mitigate all the problems is at worst blatantly dishonest and at best woefully ignorant and naïve.

This volume of housing will cause an unbelievable increase in traffic and congestion through the area. We have already seen the effects of the Warwick Gates estate on traffic through the village and en route to Leamington and Warwick. This would increase pollution, road traffic accidents and make journey-times much longer. If new schools are added to the mix, traffic problems would be exacerbated further - it is already that case that traffic is about 10 times worse during term time than during school holidays.

The Council also states that it wishes to "Develop sustainable communities". How about protecting exisiting communities? As was shown in the recent consultation on parish boundaries, Bishop's Tachbrook is a strong and thriving independent community with a great history - again, this is being threatened by the plan to build thousands of new houses and practically link us up with the urban area that is Warwick Gates/ Whitnash / Leamington.

What the council is talking about is replacing agricultural and natural landscapes with a vast amount of housing, then as an afterthought, adding in so called "Community spaces" and "Country parks" - some kind of 'fake natural landscape' to ease developers consciences. This does not undo the damage wreaked on the landscape and wildlife. If the Council really cares about preserving the local area and making "Warwick District a Great Place to Live, Work and Visit", it should protect and celebrate its beautiful local landscape, not turn it over to the highest bidder to bulldoze. In building such a large number of houses in one area, you would also effectively be getting rid of any incentive on the part of potential new residents to live here. No one wants to live in a massive estate where roads are congested and overcrowded and local towns full of pollution. People come here BECAUSE of the countryside and relative quiet. Warwickshire is known for its agriculture and landscape and has been throughout history. The Council is also overlooking the impact on Warwick's historic town centre, which is already becoming highly polluted and congested. Don't forget that tourism is a key part of the local industry, being close to Shakespeare Country (I work for the Shakespeare Birthplace Trust) and having the ever-popular Warwick Castle in its midst. We should be aiming to preserve the countryside and local villages as these are part of Warwickshire's 'image/ brand". Tourists do not come here to see thousands of modern houses and villages that have been swallowed up by the growth of the urban landscape. Think how popular the Cotswolds is, with its country lanes, open fields and well-defined villages. If this plan goes ahead, I suspect many visitors will just bypass Warwick and Leamington and make do with visiting other places to avoid the traffic - after all, there won't be much left to see with all of the open fields gone and Warwick town centre reduced to a traffic island.

It is really quite illogical to build such a large number of properties in an area which is never going to be able to provide enough jobs for this many people. Anyone living on such a new development would be compelled to commute by car, when it would make more sense to build new housing on brownfield sites near existing industry. In an era when there is an increasing desire for ecological homes, minimising car journeys, cutting energy use and protecting the environment, this seems like a retrograde step.

I would therefore urge Warwick District Council to reconsider and:
1. Reduce the planned housebuilding for the District to a more reasonable level and not build for the sake of it.
2. Spread the development widely within the district - a few hundred houses at most here and there.
3. Use brownfield land rather than agricultural land and land which is a haven for wildlife.
4. Consider more suitable sites for housing e.g. near workplaces/ cities.
5. Work to reduce traffic, congestion and pollution within the area, rather than increase it.
6. Celebrate and protect our historic and beautiful landscape and make it more appealing to visitors, residents and potential new residents.
7. Stay true to its professed vision and mission and listen to the opinions of EXISTING taxpayers (I for one would not like to stay here if this plan goes ahead).

Everyone can see that this proposed development is completely out of proportion with what is sensible and what is required. This is too many houses, in the wrong places, without thought for the consequences. It is not too late for the Council to do something about this and save our local area and stand up for local people.

I wish to make comments on the proposed Local Plan, specifically the sites chosen for further housing development.

My objection is to the continued development of the areas south of the river. This area of Warwick District has already supplied much of the housing need for the District. In the last decade or so the Whitnash/South Leamington has seen substantial development; South Farm extension, Whitnash Allotments, Warwick Gates plus the industrial development and shopping provision in the area. All of these developments have put huge pressure on the existing infrastructure, and coupled with access to and from the M40, means that the area cannot take any further development. This part of the District has already taken more than its fair share of the District's new housing provision.

The development along the Tachbrook Road shows that the existing roads cannot take any increase in vehicle movement. I would say planning in Warwick District, especially in and around Leamington, is totally hampered by the constraints caused by the River Leam, the canal and the railway line. These are barriers that nobody seems to be able to address. It is difficult to get from South Leamington/Whitnash to the North of the town at peak times. It is difficult to get north/south via Warwick also. Additional development will make these moves even more difficult. Until someone can devise a way of getting over these obstacles there should be no further development south of the river.

The plans solution on dual carriageways to move traffic will not work as there will still be the bottle necks where traffic needs to cross the river, canal and railway. Whilst dualling the road out of Leamington might get traffic away more quickly, will not help ease problems for traffic coming into Leamington.

Until there is a properly integrated public transport system, that is reasonably priced, people will not use any public transport. I find it odd that you want to build on the Station Approach (I assume) car park. Where will train users park if that lane is built on? That will not encourage use of public transport. The plans for park and ride also seem totally hit or miss. There needs to be public transport, fully integrated (rail and bus), that is easily accessible for all users. Your plan does not seem to address this.

Warwick District is happy to breach the Green Belt for industrial/employment land, so why not for housing north of Leamington. It is entirely possible that the jobs created around Baginton Airport will be taken by people from the Warwick District area, or people who would want to live in the area.

I do not believe that previous decisions by the authority stand up to too much scrutiny in terms of overall planning. It is my view that the number of vehicle movements associated with the recent developments in and around Whitnash were seriously under estimated, and the impact on the local environment and community similarly under estimated. There is no room for any further development in this area.

A new Local Plan will be examined by an Inspector to ensure compliance with the NPPF.
6. says "The purpose of the planning system is to contribute to the achievement of sustainable development. The policies in paragraphs 18 to 219, taken as a whole, constitute the Government's view of what sustainable development in England means in practice for the planning system."
The plan will have to be sustainable in these terms.

2. The existing 2007 local plan is, by virtue of NPPF 211, "not to be considered out‑of‑date simply because it was adopted prior to the publication of this Framework." And further NPPF212. says "However, the policies contained in this Framework are material considerations which local planning authorities should take into account from the day of its publication. The Framework must also be taken into account in the preparation of plans."

3. NPPF215 requires that "due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework (the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given).

4. The existing local plan was adopted in 2007 following a Public Inquiry during 2006 into objections to the proposed plan. The Inspector produced a 562 page report. Some of the issues are relevant to the new local plan proposals. Some senior Planning Officers seem to be of the view that because the current local plan was adopted in 2007 under the 1990 Town & country Planning Act Part II, it is of less value than a plan adopted since 2004. It needs to be pointed out that the Planning & Compulsory Purchase Act 2004, which came into force on 13th May 2004, did, by virtue of Schedule 6 of that Act, amend the Town & Country Planning Act 1990 to take into account changes made by the 2004 Act. So, for the purposes of NPPF214, it was in accordance with the Planning & Compulsory Purchase Act 2004 when the current local plan was adopted in 2007.

5. The local plan was adopted only 6 years ago. It settled many questions of concern for the community, in effect setting a contract with the community, up on which many people made decisions about their lifestyle arrangements. The Revised Development Strategy with a dramatic change to the size of the district and the concentration of very large amounts of new housing on land that is currently subject to Rural Area policies, is seen by many as a breach of that contract. As a result there is much concern and indeed, anger, at the proposals being consulted on and in the way that the door has been left open by the District Council for planning applications to be made that negate the purpose of any local plan and the consultation process to establish it.
The purpose of Local Government is to serve the community in the district that it covers. It is not to impose in a dictatorial manner changes that will erode the quality of life of those that live in that District unless there should be a very good set of reasons that carry greater weight than maintaining and improving the Strategic vision of the authority. At the many meetings that I have been to in the last 6 weeks, I have not found anyone that supports the proposals.
6. Since the Inquiry was only 6 years ago, I would like to draw your attention to certain key findings of the inspector, particularly where he talks about the plan after 2011.
In paragraph 11.3.8, in respect of the housing land supply position and of the need to allocate sites for housing, he finds "This Local Plan only covers the period to 2011 in the absence of firm housing or employment figures for the period beyond. The housing figures derived from the RSS for 2011-2021 are indicative only. Nevertheless, the District Council is able to show that there is no need to identify further housing sites. The balance of 2,210 dwellings to be provided between 2005 and 2021 equates to 138 dwellings per year. The District Council's estimates of windfall sites (based on past trends and emerging Local Plan policy) equate to an annual average of 282 dwellings in the urban area and 11 dwellings per year in the rural area. On the basis of these figures, I am satisfied that the District Council is justified in not identifying sites to meet the requirement to 2021. "

In paragraph 11.3.10, in respect of whether the Plan should identify a 10 or 15 year supply of housing, he finds that "New Table 5 of revised Appendix 2 shows how the residual housing requirement for the period 2005-2021 can be met. This particular objection is therefore satisfied. "
Table 5 in appendix 2 of the 2007 local plan states the following

source Dwellings
RSS housing requirement 2001 - 2021 8,091
Dwellings completed 2001 to 2005 3,324
Remaining dwellings to be provided 4,767

By the end of 2011/12 the dwellings completed had increased to 6,084. Deducted from the original requirements this leaves 2,007 remaining to be provided by 2021.

If 2,007 is the plan for 10 years, then for 18 years until 2029 it might be 200x18= 3,600.
The latest Hearn figure for the 18 years is 8,500 persons (see section 8 below) or 3,705 dwellings, so it looks as though we should be getting back the anticipated plan.

This ties in with census findings

Census House
holds % increase Homes built Running % increase population % increase Running % increase
1991 (to 1995) 48,202 856 116,522
('96 - '01) 3,537
2001 ('01 - '05) 53,356 10.69% 3,324 125,931 8.07%
2011 ('06 - '11) 58,679 9.98% 2,760 21.74% 137,648 9.34% 18.13%

The 21.74% increase in households compares with 15.32% over the whole of England for the same 20 year period. So The District has not been lagging behind but has done more than most.

7. So how did 2,007 become 12,300? Somehow in 2008 the RSS came up with a figure of 8,300 for the next 20 years up to 2029. That caused demonstrations outside the Council offices. Then came the banking and economic crisis and a change of government, with the abolition, eventually, of the RSS. Views were sought from the public and 58% agreed low growth. The first consultation was for 10,800 homes, higher than the RSS. This was rejected by 87% of respondents. A reasoned assessment based on ONS data was done that indicated a figure of 5,400 homes by 2029 was the housing need for the locality. By this time we also had the Localities Act 2011. The intention of Government was to give local people a chance to influence the way that development grew. The NPPF, in describing the way that local plans should be prepared is clear that -
150. Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities.
151. Local Plans must be prepared with the objective of contributing to the achievement of sustainable development
152. Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued.
154. Local Plans should be aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where.
155. Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.

These are important matters that the plan so far fails to do. The vision and aspirations of the local communities, the definition and implementation of sustainable development to achieve net gains on all three dimensions thereof avoiding adverse impacts on any are not only not demonstrated, they seem to be ignored.
Local plans should be aspirational but realistic and address the spatial implications of change. If 2,007 homes by 2021 was considered to be realistic by the Inspector in 2006/7, and shown to be so by the District council at the time, what are the reasons for the unrealistic numbers now? This was only 6 years ago, so within living memory.

With regard to 155., local plans should as far as possible reflect a collective vision and a set of agreed priorities for the sustainable development of the area, collaborating with neighbourhoods, local organisations and businesses. A wide section of the community is engaged and would wish that it was proactively so. But this requires a listening district council.

8. 156. Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver the homes and jobs needed in the area.

Homes and jobs go hand in hand.

In December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn updated the forecast for population growth. It starts with the following statement
5.52 The projection based on past population trends (PROJ 5) indicates modest population growth of 6.2% over the 18-year plan period - an increase in population of around 8,500 persons. Comparing the trend-based projection in this report with that contained in the SHMA we see that population growth would now be expected to be lower. This projection suggests an annual increase in the population of 473 people which compares with a previous estimate of 914.

The reasoned assessment of 5,400 homes needed by 2029 included migration trends as well as natural changes due to births and deaths, totalling 590 persons per year. Now Hearn have used later data that shows 473 persons per annum. ONS data is based on 25th September 2012, 3 months before Hearns report. It should be expected that when it is brought up to date it will use the same data as Hearn or possibly even later.

The Economic and Demographic Forecasts Study prepared by GL Hearn also states that

4.5 The District has a jobs density of 0.95 - this means that for every person of working age (16-64) living in the District there are 0.95 jobs in the District. This is significantly above average for the West Midlands or England (0.75 and 0.78 respectively). Overall there is a relatively good jobs-homes balance currently.

The conclusion I draw is that until the joint SHMA is received, the 12,300 household cannot be considered as a valid consultation. Across the neighbouring authorities, jobs ought to follow unemployment so far as it is sensible to do. Since our unemployment count is very low, and job availability is still very fragile, then building a larger volume of homes than we have ever done does not seem to be a good strategy. It could give us a dramatic employment problem.

9. Duty to cooperate with Neighbouring authorities - I understand the Inspectors rejection of Coventry's proposed plan and it clearly ties in with the joint SHMA. I note that Stratford is not part of the joint SHMA and wonder whether, due to the Gaydon dimension, which will invalidate their plan and possibly our joint SHMA as well. Since Gaydon to Nuneaton is seen as the motor industry technology banana by the district, that may be the reason for the ambition for jobs and homes in Warwick. But if Gaydon has a new town for JLR, coupled with the proximity with Banbury, then Warwick's need to grow is less.

10. Maybe part of the plan is to grow homes to get new homes bonus. But this is not a material consideration in NPPF terms. It is not a good business plan either, because the infrastructure needed to support a 29,000 or so population increase has yet to be provided. I note that the CIL paper acknowledges that there will be a funding gap unspecified. I have no detail to work with, but some quick guesstimates indicate that there could be a £100m capital cost shortfall between total public infrastructure costs (County, District, NHS, & central government) compared with CIL, section 106 and other charges to the developers after accounting for 40% number reduction for CIL-less affordable housing and approvals already given.

With a reduced housing target of 5,400 the infrastructure need would to be less because it is a smaller volume and can be spread more evenly around the district spreading not concentrating infrastructure overload.

11. The planning Inquiry in 2006/7 looked particularly at sites both in Areas of Restraint and subject to rural area policies. The decision made then needs to be seen in the context of the NPPF54, 55, 109 to 125. In particular,
NPPF54 agrees with the existing local plan rural area policies by requiring that, "In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs."

NPPF55. Would extend those policies " To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby." To do this, the local plan should have specific rural area policies. It may be that neighbourhood plans would customise such policies for particular reasons relevant to that parish.

NPPF109 requires that "The planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
* remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

NPPF110 requires that In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework.

NPPF111. 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.

NPPF112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.

The sites selected for development to the south of Warwick & Leamington do not appear to meet these requirements. The councils own Landscape consultant in 2009 has some very strong recommendations that should be taken into account.

Looking at the particular sites the inspector made the following conclusions.

11.1 Woodside Farm should remain in an area of restraint. In a lengthy and detailed consideration he concluded that
10.11.41 The AoR designation has been carried forward from the adopted Local Plan. It was established to maintain separation between Bishops Tachbrook and Whitnash. When preparing the earlier Plan the District Council successfully argued that any extension of built development to the south of Whitnash, beyond the ridge line that defines the present edge of the town onto the south facing slope, would create a major incursion into the countryside that would be highly visible and intrusive. Since that time a number of physical changes have occurred in the locality. Extensive housing development has taken place at Warwick Gates on the opposite side of Tachbrook Road. Although anticipated through a Local Plan allocation, this has affected the character of the area by bringing development to the west as far south as Harbury Lane. In addition, playing fields, open space and woodland have been laid out to the east of the objection site giving enhanced public access, and overhead electricity lines have been put underground. The objector argues that in light of these changes the objection site should be excluded from the AoR. The request is supported by a Landscape and Visual Impact Assessment and a Development Principles Plan.
10.11.42 I consider that the AoR still performs essential functions. It helps safeguard the character and setting of Whitnash, prevents urban sprawl and assists in maintaining the integrity and separation of Bishops Tachbrook as an independent settlement. The objection site is an important element of the broader AoR. It occupies an elevated position with views of it obtaining from certain directions. They include limited views driving northwards along Tachbrook Road from Bishops Tachbrook, from Harbury Lane to the east and long distance views from public locations on the northern edge of Bishops Tachbrook. From each of these positions housing development would be clearly visible for many years while structural landscaping matures. This would intrude into the rural surroundings and noticeably reduce the open gap that remains between Bishops Tachbrook and the urban area.
10.11.43 I conclude that this land should remain open as part of a more extensive AoR and that it should not be allocated for housing development within the Plan period or be identified for longer term development.

I concur with the Inspectors view. It is an essential part of the distance between Whitnash and Bishops Tachbrook and an important part of the valued change from town to country along the Tachbrook and Oakley Wood Roads and in particular their junction with Harbury Lane going east rising up through the trees up a double incline hill some 15metres high as the road reaches Mallory Court on the right hand side. Housing on Woodside would be completely counter to the NPPF

11.2 Fieldgate Lane/Golf Lane should remain in an area of restraint. In a lengthy and detailed consideration he concluded that

9.4.16 I take a rather different view. Looking first at the boundary of the AoR, I acknowledge the previous Inspector's uncertainty about whether the golf course and land to the east contribute to the AoR objective of preventing Whitnash from merging with Bishops Tachbrook. However, the south-western part of the golf course is highly visible from Harbury Lane where it forms a backdrop to the new playing fields and pavilion such that any development there would significantly close the gap between these settlements. Moreover, while the rising nature of the ground at Fieldgate Lane/Golf Lane from north to south means that development would not be visible from Bishops Tachbrook, it would be clearly seen from southern parts of Whitnash where the land contributes to the rural setting of the town. It would also, I feel, be intrusive in long range views from east of the railway line. I find that the whole of the area (that is, the golf course and the land at Fieldgate Lane) contributes to the objectives of the AoR. The land has a role to play in the structure and character of this part of Whitnash, provides open areas in and around the town, safeguards its setting and helps prevent urban sprawl. In addition, the south-western section of the golf course maintains separation between Whitnash and Bishops Tachbrook. Consequently, I see no case for excluding the golf course or the Fieldgate Lane site from the AoR. As regards land south of Harbury Lane, this land forms part of the sensitive gap between Whitnash and Bishops Tachbrook. But I believe it to be less at risk of development because Harbury Lane/Gallows Hill provides a strong boundary to the urban area. In my view, there is no need for AoR designation to extend south of Harbury Lane.

9.4.18 Finally, the objector considers that as the Fieldgate Lane site is bordered by housing to the north and south it should be considered as part of the urban area, rather than one where the Plan's Rural Area Policies apply. I do not agree. As the District Council points out, all rural areas have an urban edge. In my opinion, that boundary is properly set by the suburban housing to the north of Fieldgate Lane.

9.4.19 The objector's proposals were subject of the Omission Sites Consultation undertaken in January/February 2006. Responses received from Whitnash and Bishops Tachbrook residents, CPRE (Warwickshire Branch) and Whitnash Town Council were against any removal of the golf course or Fieldgate Lane site from the AoR, any residential allocation at Fieldgate Lane and any exclusion of the proposed development site from the application of Rural Area Policies. I note that 251 responses were received against the Fieldgate Lane site and 496 objections in relation to the golf course (of which 240 were by way of a petition from members of the Leamington and County Golf Club). This is a clear indication of the strength of local feeling.

Residents of Whitnash agree with the inspector that the site is part of the Golf course, Woodside Farm Area of Restraint set out by paragraph 9.4.19 of the inspectors report. I agree and object to this proposal.

11.3 Grove Farm (called Harbury Gardens by the developer) should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & west of Oakley Wood Road.

In the 2012 consultation, this site was described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge as part of the separation of Whitnash and Bishops Tachbrook was welcomed. Dismay ensued with the current 2013 proposal for 200+ homes.

Reacting to an objection seeking this land be included in an area of restraint, the inspector found that

9.4.4 I agree with the District Council that a cautious approach needs to be taken in respect of the AoRs in order to avoid their devaluation and to ensure that they perform a specific function. Unlike the other AoRs included in the Revised Deposit Plan, much of the land identified by Bishops Tachbrook Parish Council (even with the reductions in area put forward at the hearing) is relatively remote from the urban area and not under immediate threat from urban expansion. The gap between Harbury Lane and Bishops Tachbrook is about 1.4km compared with only 300m or so between Leamington Spa and Radford Semele. Although there are objections before this inquiry that seek to allocate or designate sections of the land in question for other uses, and anecdotal evidence of options taken by developers, this is by no means unusual when a Local Plan is under review. I consider that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for additional protection. It is not the function of AoRs to give an added layer of protection to open countryside where appropriate policies already exist to control development. Should land have to be released in the future for urban expansion then the District Council says that this exercise would be done by a review of options on all sides of the urban area including sites subject of Green Belt and AoR designation. Land south of Harbury Lane outside an AoR would, it is argued, be placed at no disadvantage.

9.4.6 I conclude that while additional development has taken place to the south of Leamington Spa during the last 10 years or so since the previous Local Plan Inspector reported, his findings remain pertinent. Given the strength of the Rural Area Policies of the Plan, the current housing and employment land supply position and the degree of protection afforded to the most critical areas by the AoRs already identified in the Revised Deposit Plan, there is no need for a further AoR south of Gallows Hill/Harbury Lane. To designate such an area in the absence of any serious threat would be premature at least and at worst a misuse of policy.

The Inspector clearly considered that rural area policies were strong enough to prevent such development. Nothing has changed that alters the communities view. Housing in this location will be very visible across the Tachbrook Valley from the south, being on the ridge line as can be seen from this photograph. Housing will be prominent half way down the field in the distance. The top of roofs to Warwick Gates can just be seen behind the hedgerow on the horizon and stretch from the coppice of trees on the left side of the picture to Grove Farm buildings to the right of centre of the photo. The photo was taken from the public footpath to the Asps from St. Chads Church and this is a prominent view along most of the path. The suggested country park to the south of the housing, because it is on the slope down to the brookstray will not hide the housing as it will be the same height as the trees that can be seen running along the Tach Brook from left to right. The NPPF paragraphs quoted at the head of this section are intended to conserve, protect and enhance landscape such as this wonderful piece of Warwickshire.



It is essential that this piece of landscape is protected as there is no credible case for housing in this location. So we object to the proposal in the 2013 consultation and support the 2012 consultation to keep this area as a green wedge. In my view, however, it does not need to be converted into any sort of country park, at considerable cost no doubt, as it is perfectly acceptable as it is. This would retain a valuable piece of agricultural land, meeting the needs of the present without compromising the ability of future generations to meet their own needs.

11.3 Lower Heathcote Farm should remain in the current rural area. It is an expansive piece of Grade 2 agricultural land on the northern top of the Tachbrook valley, south of the Harbury Lane & east of Europa Way.

In the 2012 consultation, this site was also described as a green wedge, protected by rural area policies to be considered as part of a possible peri-urban park. Keeping it as a green wedge running from Castle Park in the west through to Radford Semele incorporating paths along the side of the Tach Brook presents recreational potential for village and urban walkers. Dismay ensued with the current 2013 proposal for 720+ homes.



The photograph shows the view north across the Tach Brook Valley from New House Farm. Housing will come down from the hedgerow along the Harbury Lane covering the top half the field between that hedgerow and the trees along the brookstray, the tops of which can just be seen. The undulating form is a 'trademark' of the rolling Warwickshire countryside that is part of the tourist attraction experience on the approach to Warwick Castle from the south and is seen as a backdrop along the Banbury Road. It is highlighted in the Morrish Landscape consultants report of 2009.

4.4 Paragraphs 109-125 of the NPPF outline conserving and enhancing the natural environment. They state that the planning system should contribute to and enhance the natural and local environment by protecting / enhancing landscapes; by recognising ecosystem services; by protecting/improving biodiversity; by avoiding pollution or environmental degradation and by remediating degraded land. LPAs should set criteria-based policies by which to judge potential impacts to wildlife, landscape, etc. and set out a strategic approach to green infrastructure in local plans.

This requirement expects that the new local plan will have such policies and implement them.

The landscape consultant also advises

5.1 Some of the elements that contribute to landscape character include the shape and scale of topography, the presence and pattern of natural geology, outcrops, water bodies and vegetation and, the patterns and features of man's intervention - including land management and settlement.
How and from where the landscape can be viewed greatly influences how it is perceived - so that the availability of access becomes influential in determining landscape character. A variety of views (long vistas, wide panoramas, framed focal points) generally adds to our enjoyment of a landscape. Landmarks are of particular value/interest in any landscape - even if they have disputed amenity value (e.g. Eden Court flats at Lillington).

This paragraph describes exactly the situation with this site. The landscape value of this area is very high. It has a large variety of views, long vistas wide panoramas and framed focal points. It shows an interesting shape and scale of topography. The brutal insertion of the development proposed is totally insensitive, tantamount to municipal vandalism. The existing landscape is an asset that everyone in Warwick District can enjoy and is part of the package that makes Warwick District a Great Place to Live, Work and Visit.

The Inspector "consider(ed) that this extensive tract of open land south of Gallows Hill/Harbury Lane is sufficiently well protected by the Rural Area Policies of the Plan, which are stronger than those in the previous Local Plan, without the need for the additional protection of an Area of Restraint. This set of policies should be included in the new local plan to meet the NPPF clauses referred to above.

11.4 The former Severn Trent Sewage Works between Lower Heathcote Farm and Grove Farm to the south of Heathcote Park is listed in RDS 5 and shown on Map 3. It claims to provide 225 homes.



This photo shows the site from the site across the Tach Brook Valley. It is the central greener area. At the top of the hill on the skyline there is a mature area of trees which provides a wildlife oasis to a number of mammals including deer, birds and woodland insects. The former sewage tanks are, according to old plans, many and closely aligned. The tank depths and ground contamination is likely to make this a difficult site to develop for housing and add to that the steep fall as the ground slopes down towards the brook it is unlikely to provide any practical housing land at all.

The site would however be an ideal site to develop as woodland as part of the low carbon environmental sustainability objective of the Councils Corporate Development Strategy. Carbon dioxide sequestration of woodland is calculated on the basis of 25m2 absorbs 1 tonne of CO2 per annum. If a normal house produces 4 tonnes of CO2 per annum, this provides sequestration for about 1000 of the homes to be built. Bishops Tachbrook Neighbourhood Plan is seeking sites of this nature within its boundary and will be including this site in discussions with neighbouring towns and parishes as part of its duty to cooperate with them. AS far as the NPPF is concerned paragraph 109 requires development to conserve and enhance the natural and local environment by remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

11.5 Land south of Gallows Hill between Europa Way and Banbury Road, north of the Tach Brook.

The northern section is the other half of the Tachbrook Valley and to build upon it would detract from the southern part which it has been accepted should be kept. Given that the RDS does accept that the Asps is an important part of the Warwick Castle approach, so is this northern section. it can be seen from the Warwick Castle Towers and the mound. Any development on this site will have a direct impact on the views available to visitors to the castle.

This photograph was taken from the top of Guys Tower in Warwick Castle, looking south-east, earlier this year and shows the site south of Gallows Hill in the foreground with two oak trees in the centre of the field and the hedgerows running along Europa Way. Behind the hedgerow there are fields of yellow oil seed rape which is the site south of Harbury Lane in 11.3 at Lower Heathcote Farm. To the right of the poplar tree on the left of the photo is the farm cottage to the former Heathcote Farm with, to its right, the roofs of the bungalows in Heathcote Park, mostly hidden in the trees. Beyond that are the trees bordering Oakley Wood Road with the hill rising behind them, through the Grove Plantation rising to Highdown Hill Plantation on the skyline. This is a view that has been available to Kings, Earls and visitors since 1395 when the Tower was constructed, so is significant for Tourism and should not be lost to development. No amount of landscape 'mitigation' will compensate.



The 2009 Landscape area statement by the councils Landscape Consultant Richard Morrish clearly concludes that

This study area is principally well preserved farmland that creates an attractive rural setting for the south side of Warwick and should be considered an important part of the setting for Castle Park. Any development that 'jumped' the Heathcote Lane / Gallows Hill frontage would set a major landscape precedent in extending the urban area so far south. Although it is considered that the Warwick Technology Park has possibly diminished the value of the Area of Restraint north of Heathcote Lane, its general style of low density development in a strong landscape setting makes for a reasonably successful transitional environment on the urban fringe - as do the adjacent school sports fields. To extend the urban area beyond these sites would make for a disjointed urban structure and possibly encourage intensified development at the Technology Park and around the schools. Smaller blocks of isolated development are also likely to be incongruous in this landscape.
Our conclusion is that this study area should not be considered for an urban extension and that the rural character should be safeguarded from development.

The Inspector at the 2006/7 Public Inquiry considered this site for employment purposes. In a lengthy and detailed consideration he concluded that

10.3.49 The objectors maintain that the Gallows Hill site would provide continuity in the forward supply of employment land beyond 2011. However, I believe it would be inappropriate to identify such sites now when the future employment requirements of the District are uncertain pending completion of the sub-regional employment land review and the partial review of the RSS. Until then, the RSS requires that greenfield sites, like this land at Gallows Hill, should only be released when there is no alternative previously developed land available. The WMRA, commenting on the Omission Sites Consultation, remarked that new sites being promoted involving the development of greenfield land "appear to be inconsistent with the principles of the RSS" and requested that the Inspector rigorously scrutinise such proposals. I agree with the District Council that as and when further greenfield land releases are necessary this should be done through a DPD where a full comparative assessment of all potential sites can be made in the context of a sustainability appraisal and following a process of public consultation. In this regard, I note that the objection site is classified as very good (Grade 2) agricultural land and that a full Transport Assessment would be required in respect of development on this scale. I believe that the ad hoc release of a large greenfield site like this located on the urban fringe and currently in agricultural use would not be in the best interests of the District. The Council's Local Development Scheme commits it to begin preparation of a Core Strategy DPD immediately following adoption of this Local Plan. That will tie in with completion of the partial review of the RSS, enabling up-to-date employment requirements for the District to 2021 to be accommodated.

10.3.50 I conclude that land at Gallows Hill should not be allocated under Policy SSP1 for employment (Class B1) purposes, nor should the site be excluded from the rural area defined on the Proposals Map. To do so would result in an over-provision of employment land relative to the Structure Plan requirement, at the expense of the surrounding countryside.

The site is shown in the RDS as residential and employment but this we believe is wrong because all the advice is that it should be retained as agricultural land with a high landscape quality, hidden for the most part behind hedges on Harbury Lane but with occasional glimpses through it at gates and breaks in the hedge. It is on the only high quality approach road to the Castle

12 Separation of settlements.

The District Council to date has rigorously resisted any development that reduced the gap between Bishops Tachbrook and Whitnash/Warwick. We believe that the NPPF requires the district to continue to implement those policies as part of the social role within sustainable development, supporting strong, vibrant and healthy communities.





13 Conclusion.
We strongly request that you reconsider the quantity of housing needed by the plan, limiting it to no more than 5,400 homes by 2029. This will produce all the homes needed by the locality, gives achievable 5yr land supplies through the plan period, reduces the infrastructure cost and spreads traffic volumes, avoids the need to take valuable greenfield sites and restores the confidence of the electorate in the local authority. It has been produced as an objective assessment, that takes all the requirements of the NPPF as well ONS projections into account, establishes a realistic employment strategy that recognises greater problems in neighbouring areas but allows a controlled and realistic amount of economic growth.
That should then mean that we have a sustainable local plan that will fit well into the limited space we have available.

The Local Plan 2013 will see the end of life as it is currently known in the South Leamington Area. I am writing to object in the strongest terms 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.

It is totally inappropriate that 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. This is unacceptable. Such applications should not even be considered until such time as the Local Plan has been clarified and the public consultation completed. I would like the Council to explain why this is occurring.

The council is claiming that 12,300 new homes need to be built. This figure is being strongly contested by many objectors to the Local Plan. Where is the evidence that we need this many new homes? I am aware that a local councilor is working hard to get to the truth of this figure and that 5,400 over the next 15 years is a far more appropriate number for local needs. Which brings me to the point 'Local Needs' is a key phrase. It is my belief that this excessive housing has nothing to do with local needs but the desire for developers to tempt people, who are not local to move to Leamington. This will only add further to the burden currently being inflicted on pressure points on the roads in Warwick & Leamington & all its infrastructure. This is development for developments sake & it does nothing to aid affordable housing . Warwick Gates is a prime example of this, where many of the people living there are commuting long distances, and the vast majority of houses are privately owned and are not affordable to most first time buyers. Far better to build the houses where the jobs are. This would be a far more sustainable solution.
Therefore can the council please tell me where the 12,300 jobs are in South Leamington?

The council mentions in its proposals that 22.5 hectares are being set aside for new employment land. Can the Council please provide me with the name(s)of the business(s) & type of employment likely to be offered.

WDC does not have the right to ask that people only object to sites adjacent to their homes, this is an issue for the community and not just those closest to the sites as the impact will affect all of us. I strongly request that the council explains itself. Clearly the council fears the amount of responses it is going to receive, if the council cannot cope than this plan is unsustainable and should be rejected.


This revised local plan unfairly places the bulk of the proposed housing in one concentration to the south of Warwick/Leamington and around Whitnash. When it was seen for the first time in public it has appeared as a statement of intent and not as a suggestion with alternatives.

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

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)
W/13/0464 - large Retirement Community development on Gallagher Land near Heathcote
W/13/0858 - upto 100 homes at Fieldgate Lane/Golf Lane, Whitnash

I hope Warwick DC would also refuse any new applications relating to the following:

Myton Garden Suburb - upto 1250 homes
Further development South of Gallows Hill - upto 260 homes
Former Severn Trent Sewage Works - 225 homes
Further development at Grove Farm - 375 homes
Whitnash East/South of Sydenham - 500 homes

I wish to raise objection to the Revised Development Strategy for the Local Plan for Warwick.

1. The number of homes proposed far exceeds the number required to meet local need. Taking account of births and deaths, a statistical analysis shows a projected figure of 5,400 homes. (ref.The Warwick Society) These could be dispersed throughout the area without the need for a concentration to the south of Warwick. Rather than encouraging in-migration, housing numbers should focus on meeting local need, giving absolute priority to using brownfield and infill sites near schools , shops and railway stations as well as building homes close to jobs to ensure that traffic is kept to a minimum. This could be done in co-operation with other local authorities, instead of competing with them for development.

2. At present unemployment in the area is just under1,400. Any further influx of incomers would drastically increase this, making the proposed increase in population, an unsustainable development.

3. While the National Planning Policy Framework requires the approval of 'sustainable development' to meet 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 alreadt has the five year supply of sites, balancing housing with employment growth and matching the housing market.

4. The land between Warwick, Whitnash and Bishop's Tachbrook is rural and agricultural .It has so far been respected as a buffer zone being an area of restraint. Building on it would create a single suburban sprawl effectively joining Warwick and Leamington and destroying the unique character of each. This green land is as important to both towns as the Green Belt to the North of Leamington and Warwick and it should be safeguarded just as strongly.

5. Suburban sprawl is inevitably car-dependant. Transport strategy is car-based, just squeezing more traffic on to an already congested road network. A recent survey indicates that over 70% of traffic in Warwick is through traffic. Widening Europa Way and various traffic islands including the Myton Road/Banbury Road Junction would not solve the problem as traffic would still need to cross the narrow bridge over the River Avon,and proceed through the narrow historic streets of Warwick town including The Butts, in order to complete its journey through the town. Stopping on road parking in order to facilitate two-way traffic (as has been suggested for Smith Street) will only succeed in killing our beautiful historic town. This is not what visitors come to see. They don't come to sit in a traffic jam as they pass slowly through a congested polluted town devoid of atmosphere and charm. This is not sustainable development!

6. Regarding air quality, pollution from car exhausts in many streets in Warwick town centre and some in Leamington already exceeds legal limits. The District Council is required to improve air quality to meet its legal obligations but this plan would actually exacerbate the situation damaging the long- term health of residents. Recent research indicates that pollution from traffic fumes is closely linked with increased incidence of asthma and is implicated in some forms of cancer. Children walking to and from school and visitors to the town will all have their health threatened by this deterioration in air quality as well as those who live and work in the towns. The District council is legally obliged to ensure that is does not happen and that pollution is decreased rather than being increased.


7. While in theory development would be conditional on it funding schools and healthcare facilities, the Councils predicted funding is insufficient. Additional teachers and Healthcare workers will need to be paid in the future as well as the long term costs of maintaining and heating the buildings. There is also the question of whether the water supply , sewage and drainage could cope with additional demand as well as the very real concerns regarding potential flooding.

For the reasons outlined above, the Revised Development Strategy is unacceptable. It is not 'sustainable development'.

The people of Warwick deserve better.

I have serious concern over many of the proposals made in this plan.
The stated aim of this New Local Plan is "to make Warwick District a Greater Place to Live, Work and Visit." I was born in Leamington and have lived all my life here. However over the years I have seen many lost opportunities, and mistakes, to make the area more environmentally acceptable.
While I have to accept that areas regarded as Urban Brownfield Sites should be developed for Housing and some of the smaller Greenfield Land, ie Kenilworth (Thickthorn) and East Whitnash provide natural extension of existing housing areas. However the overdevelopment of the area South of Leamington could eventually become a planning disaster.
Taking the Plans objectives in a slightly different order:-
Work
The outlook for British Industry will not be as it was in the past. Large Industrial Plants, like Automotive Products will not be sited in this area of comparative affluence. The Government, no matter who is in power, will provide incentives for any such major plants in area of high unemployment. The future for Industry in this area will be in small to medium units supplying other major manufactures. One only has to see the units on the old AP site are Distribution Warehouses and the many empty units on the Heathcoat, Sydenham and Queensway sites. In fact the Queensway site is being cleared of existing Industrial units to build retail units (Aldi) and Housing Association Units. If there is a demand for Industrial Units why have the planned units on the Ford Foundry site been abandoned?
One has to question why we want all the new Housing Developments. Even with the large number of available factory units the Unemployment Rate for the area is 1.7%, some 1,340 people. It could be assumed that even a modest improvement in the Economy would absorb most of the people.
"A Grater Place to Live"( Traffic)
The Projected 12,300 new homes are much too high. Particularly when one considers that the majority of this building will be on the south of both Leamington and Warwick. This in itself will cause traffic problems but when combined with Stratford District Councils plans to expand LIghthorne Heath, KIneton, Southam and Wellesbourne by a total of 4,800 dwellings which will all used Leam/Warwick for many of their shopping, recreational and school journeys, the increase in traffic will be considerable.
The ability of all this traffic moving about is seriously restricted by the number of bridges that cross the Avon and the Leam. There are 4 in Leamington, Willes Road, Victoria Terrace, Adelaide Road and Princees Drive. Of these Bridges the first 3 have reasonably free flowing traffic as they are not directly connected to the north/south route through the Town. However the Princes Drive Bridge is another matter, being directly link to the M40 by Europa Way. It is further complicated by the restricted height involved in the 2 Railway Bridges that are in the vicinity of the Bridge. This junction with its "unique" road makings which are open to various interpretations, within days extra mini cones had to be installed to prevent illegal turns. In addition the misleading lane markings that results in Europa Way traffic having to get back into the correct lane has resulted, so far, in only minor collisions. The congestion coming into the area therefore funnels a large amount of traffic onto the Banbury Road Bridge over the Avon at Warwick. How long this Bridge will withstand this traffic is a matter of conjecture but it must be a matter of concern to the Highways Department. (To appreciate the possible volumes of congestion you only have to witness the problems in Warwick when there is a road accident in the vicinity of Warwick on the M40 or the A46.)
While Air Pollution in Leamington is at a Low Level at the present during a holiday period with the Schools closed, a spike in the level of Nitric Oxide have occurred in the last week, Nitrogen Dioxide has been recorded at 30 m/metre cubed and Particular Matter 40m/metre cubed. (Ricardo AEA). If the full number of projected house were to be built it could conservatively be consider that an extra 20,000 private vehicles would be added to the daily movement which at peak times of the day would escalate the volumes of pollution.
Studies across the World have linked short term exposure to Air Pollutants to the increased admissions to hospital and increased cases of Heart Failure. (The Lancet)
A Great Place To Visit
While in the process of composing this letter I had to travel through Warwick from the Stratford Road to the Banbury Road, at midday on a Summer Friday. It was chaos, Jury St was packed from end to end with one must assume on a summers day were visitors to the Town. It would have been quicker to walk from West Gate to East gate. There were 3 delivery vans parked half on the pavement, and as I approached East Gate an Ambulance had to force its way through the traffic taking the opposite carriageway.
It is indicated that Traffic Improvements are to be made to the Jury St, Butts, Smith St, road junction. Well practically what can be done, nearly all the Building are Grade 1, or 11 Listed, and whichever way the traffic is going it passes into a further restricted highway.
The remaining life blood of Warwick is its Tourism. Over my lifetime I have watched it disintegrate from a thriving Market Town of great charm with many interesting streets and shops. It is now has County Hall and the Castle with limited parking, which on any reasonably busy day most tourists have to park in Myton Fields and walk into the Town.
Surely Warwick is a place that many Tourists only visit once, and do not recommend to their friends. The building of more Factory Units and Residential areas south of the Town can only make the situation worse.
Location of Traveller and Gipsy Site south of Warwick and Leamington
Anybody who has a plot of unfenced land lives in dread of this problem. I have had personally experience of the disruption, filth and sheer antisocial result of a Travellers site. I presume that the situation at Meriden in the last few of years has resulted in the pressure to accommodate a site in this area of the County. If the County Council is forced by Law to make provision for such a site why is it necessary to have 3 sites in this area and so many of the potential sites in the area south of Warwick and Leamington?
Conclusion
It is the nature of our society that the building of dwelling places is cheaper on open land. The fact that the land to the South of Warwick and Leamington, while being good agricultural land is not designated as Green Belt, and therefore can be developed with minimal legal restrictions. This is unfortunate because the expansion of our small conurbation over the Harbury Lane towards the M40 I feel is a mistake. The Government has applied pressure for reason that I will not explore to make more sites available for building and this wrongly has been taken as a the easiest option without the infrastructure to support the addition buildings successive Administrations have always taken the easier, and above all cheapest option. Hospitals, Schools and Main Services can be adapted and enlarged after the expansion of our Towns. If the Heathcote area produces flooding of the Myton Road after a thunderstorm the drainage can be modified.
However once the Application is approved, the increased traffic starts moving there is no going back. The health and quality of life of Warwick and Leamington will be forever irreparably damaged.

Effect on the town of Warwick of the Revised Development Strategy

I am writing on behalf of my wife and myself to express our grave concern with regard to the Warwick District Local Plan, in response to the Consultation which closes on 29 July 2013. We have attended a number of meetings held by WDC and other interested parties over the past two years. At these meetings, virtually all present have been equally concerned by the extent to which the current Plan will have a detrimental affect on the lives of Warwick residents and will inevitably have an irreversibly damaging effect on the environment surrounding and within the historic town, causing harm to its residents, its buildings and its tourism industry. We find it inexplicable that WDC has continued to ignore the views of its residents and businesses and has persisted with what seems to be the least justifiable and most damaging of all the options available to it.

Land to the south-and south east of Warwick (Site 6)

The most serious problem with the Plan seems to be caused by the excessively high concentration of housing planned to the south-east of Warwick on what is currently agricultural land and rural 'green space'. I note that of the 12,300 homes planned in total, sites have been allocated at present for 6,630 homes, with 3,195 of these in this south-east area. Clearly this number would increase very significantly as the overall number is built up to 12,300 and the impact in Warwick of this degree of development will be compounded by that also intended by the Stratford District.

I understand that WDC has failed to identify any 'exceptional circumstances' that would enable it to build on Green Belt land to the north of Warwick and has therefore concentrated the planned development to the south-east, on this green 'Area of Restraint'. Whereas I would not advocate building on Green Belt land, the Green Belt was put in place to prevent urban sprawl from the West Midlands encroaching into the area and not because of Warwick's own potential plans. The Area of Restraint to the south is therefore equally important to the protection of Warwick's rural setting, and should be afforded the same level of protection as the Green Belt.

Projected housing need

There is no rational reason for planning so high a number of new homes as 12,300 at the present time. I understand that the actual needs of the local people over the 15-year time period have been calculated as around 5,300 homes - much less than half of that figure. There is presently no housing shortage and no demand for additional business premises, as is demonstrated by planned business developments that have not come to fruition and by, for example, the number of vacant premises on the Technology Park and other business sites in the area.

Such a quantity of extra housing would depress prices and attract incoming population, not for any reason that would have an economic advantage to the area, but simply because Warwick has the advantage of being a pleasant place to live. If all these houses are built then people will come for their own benefit, not Warwick's. It has been increasingly obvious that the town's infrastructure simply cannot support such a large increase in population and some of the issues it would raise have no clear solution, as will be noted below.

Whereas the housing demand may change in the future, a 15-year forecast, from any current projection, is unlikely to be realistic. I think we can be certain that similar forecasts made in 1998 for a period of time up to the present day would have been hopelessly wrong due to the unforeseeable degree of intervening economic and social changes. There is no reason to believe that today's estimates will be any more reliable. If a far more restrained Local Plan were put in place there is ample time, over the next decade, to make any adjustments that might prove necessary should an actual demand, from either the housing or the business sector, manifest itself.

Transport and road infrastructure

Such out-of-town developments will clearly be car-dependent, and this is where the greatest issues lie. Even if good public transport were to be provided, which seems unlikely on a commercial basis, the modern preference is always to use a car, as is evidenced by Warwick's existing problems with traffic congestion. The development to the immediate south-east of Warwick alone is likely to add 10,000 cars to Warwick's roads in due course, increased by those planned under the proposed Stratford Plan. This is an intolerable number that the local infrastructure cannot possibly accommodate.

The road enhancements planned cannot solve this problem and will only add to congestion, both in the town itself and on its outskirts. The extra lanes planned at the Myton Road/Banbury Road junction would clearly be disastrous for the town. This junction is already horrifically overcrowded, as can already be seen at any busy time. The vast majority of the traffic from Myton Road currently turns right into Warwick; likewise the vast majority of that from the Banbury Road travels straight on into Warwick. All of this traffic is immediately funnelled over the narrow, weight-restricted Avon bridge, which provides an insurmountable obstacle to traffic flow. Any additional traffic that does manage to cross the bridge will just make the present congestion in Smith Street, The Butts and Jury Street/High Street worse than ever. Creating extra lanes and introducing traffic control at that junction may shorten the length of the queues leading towards the town, but the result will be that as well as the added congestion in the town itself, traffic density on the roads immediately surrounding Warwick will certainly be far worse than at present.

Creating new business premises as a part of the new development will only make matters worse. Whereas it may be convenient to assume that incoming population in the area south-east of Warwick might also work in that area, examination of other developments, such as the Technology Park, demonstrate that this simply is not the case. The Technology Park attracts staff from all directions over at least a 30-mile radius, and many of these people travel through Warwick to get to work. Examination of the work-related travel of many people living in the Warwick area will show the reverse pattern; that many of them work outside Warwick, often on the opposite side of the town. These commuters form a significant part of the 80% of traffic that passes straight through Warwick and causes the present congestion. There is no reason to believe that people living or working in the proposed new development to the south-east would show any different patterns of travel, and Warwick will just grind to a halt. I can only imagine what effect a town that is constantly grid-locked with traffic will have on Warwick's tourism industry.

All in all, these major issues surrounding the impact of traffic in and around Warwick cause the Local Plan to fail on all three criteria for sustainability - environmental, economic and social. In these circumstances, WDC should consider a revised, and far less damaging, approach.

Air quality and pollution

I have been horrified to learn during the course of development of the Local Plan that car exhaust pollution in Warwick town centre is already higher than is legally permitted. It would seem irresponsible of WDC to contemplate developments that will make the situation worse without having any means of addressing this problem. Surely the Health and Safety of Warwick's residents and visitors should be WDC's primary concern and is a legal obligation? Bringing larger amounts of traffic closer to the town due to the road enhancements can only extend the pollution problem over a greater area. Close to Site (6), the first to suffer will be our younger generation whose schools and playing fields are immediately adjacent to the main roads.

As well as the poor air quality, pollution due to traffic noise and vibration are an increasing problem within the town. Living in Bridge End, the traffic noise has become very noticeably worse over the (almost) 25 years I have been a Warwick resident. This situation must be far worse for people actually living on the main roads or in the town centre where, as well as the noise, vibration from the traffic will be a significant factor. Not only are the people living in Warwick affected, but our historic buildings are being damaged. Any further increase in traffic would clearly make the situation intolerable and once again this will have a significantly adverse affect on tourism.

Health infrastructure

As well as the road system and traffic, such a significantly increased population will put additional strain on other infrastructure. A primary concern is whether health and hospital services will be able to cope. In particular, Warwick Hospital's (already stressed) A&E services will need to cope with a much larger population over a greater catchment area. Those needing the existing Warwick hospital from Site (6) will need to enter and cross the town by the existing congested route over the Avon bridge. As well as Warwick's own plans, the ambitious plans that I understand Stratford District Council is forming for its own large developments, just outside Warwick District, will also need to be supported by Warwick's A&E department. I have seen no evidence that this joint impact has been taken into account when considering the sustainability of WDC's plans.

As a retired person I should like to see Warwick preserved for future generations to enjoy, both for its residents and for visitors to the town. This does not necessarily mean that it should remain unchanged, but all development should be in keeping with its status as an historic county town - on a scale with, and in harmony with, its setting and environment. I fear that WDC's current Local Plan does not achieve this in any way and would urge that full consideration be given to the points raised above, with a view to producing a sustainable Plan more in keeping with the needs of the town and its residents, rather than the development aspirations of those less directly affected by the proposals as currently planned.

I have read the draft plan for the District and attended public meetings in connection with this.

I am fully aware that we need some additional housing in the Leamington/Warwick area and accept that the area south of Leamington should take a share of this development. However, the level of proposed development south of the town and the majority of it on agricultural land is excessive. As I understand it, the local need was for 6000 new houses by c. 2030; why has the District Council now proposed 12000?

My concerns are on three fronts in particular:

* Traffic congestion: whatever is done to widen Europa Way and any other roads leading in from the motorway and surrounding towns and villages, there will inevitably be a bottleneck as the railway bridge/river crossings into the centre of Leamington, causing a build up of traffic both entering and leaving the town.
* Pollution: increased traffic will increase pollution. This will be detrimental not only to historic buildings in Warwick town centre but more importantly to the health of the people also affected.
* Population: the rapid growth in population will put great pressure on hospitals and schools, to say nothing of the inevitable rise in the number of car journeys as children are ferried backwards and forwards (despite plans for school developments on the Harbury Lane site)
I would like to know where this demand is coming from? 4,000 + houses south of Leamington will attract many people currently living and working in Birmingham and other commutable distances so it is not for the benefit of local people and encouraging more car use seems very out of kilter with sustainable development. Do the local planners wish the towns and villages south of Leamington to become one large urban sprawl? Would it not be preferable to have smaller developments throughout the District which would not have such an impact on the current local communities?

In conclusion, I wish to express my strong opposition to the proposed Local Plan as it currently stands. The number of homes proposed, most of them in one area, would be detrimental both to the residents south of Leamington and Warwick and to the future of the towns themselves.

RESPONSE TO REVISED DEVELOPMENT STRATEGY - LOCAL PLAN & SITES FOR GYSPIES AND TRAVELLERS
I have read the draft plan for the District and attended public meetings in connection with this and have severe concern about this revised plan. Whereas I appreciate the need for additional housing within the area including the provision of sites for Gypsies & Travellers, I contest that the scale, location and impact on the local community are totally inappropriate and not sustainable.
In more detail:
o SCALE - the housing numbers are excessively high, the RDS proposes 12000 new houses by 2030 whereas the local need is for fewer than 6000. Projections, based from the last 2011 census, by Ray Bullen (Parish cllr. Bishop's Tachbrook) show only a need for 5400, and the WDC own consultants (G. L. Hearn) for the Economic and Demographic Forecast Survey of December 2012 estimated only 4405.
For Bishops Tachbrook, the housing needs survey produced for the Parish Plans of 2010 showed a requirement for roughly 14 homes however the RDS proposes a 10-fold increase for up to 150 houses. I object to the RSD figure of 150 houses and think that 20 - 30 would be more appropriate.

o LOCATION - From the last Core Strategy survey of 2010, local residents gave a very strong response that large development south of Leamington & Warwick was not acceptable. The concentration of many 1000's of new houses in this area would cause immense pressure on the road infrastructure and lead to high levels of pollution and congestion. Distributed development over many sites and with a lesser number of houses is preferable.
The crossing points from this area to the town centres of Leamington & Warwick are limited to only 4 and whatever infrastructure improvement that are planned, these bottle-necks will persist and worsen hugely. The WDC's Strategy Transport Phase 3 Assessment (Appendix E) shows traffic speeds of 0 - 10 mph in large parts of Warwick.
Development south of the towns uses prime agricultural land currently in crop production. The transfer of this use to housing development in certainly not in the line with future needs to preserve UK food production for the future. The development would have a huge visual impact and diminish the landscape south of Harbury Lane and Gallows's Hill - in contrast to the WDC's Landscape Statement of 2009 by Richard Morris "... this study area should not be considered for urban extension and the rural character should be safeguarded from development..." .
Though the area of land south of the towns is not Greenbelt, it is not obvious why it was not designated such, and I feel that development in this area will inevitably lead to more urban sprawl to include the village of Bishop's Tachbrook.
o SUSTAINABILITY - As was evidenced by the Warwick Gates' development, new houses in excess of the local need will generate migration from larger and distant conurbations such as Birmingham, Coventry, Oxford and even London. This will produce pollution and congestion from long distant commuting either by road or train.
The population growth resulting from the plan would also put great pressure on hospitals and schools, but the RDS does not contain any evidence to show that proposed infrastructure improvements in these areas can be delivered from Developer contributions.
o GYPSY & TRAVELLER SITES - I object to the proposed sites at location 5, 10 and 15, they would put increased demand for primary school places at Bishops Tachbrook which is at capacity numbers already. And all these sites are on major and busy roads and would not present safe access.
In conclusion, I see the proposed Local Plan as a blueprint to make the towns and villages south of the Leam into one large urban sprawl. The consequent increase in congestion, pollution and pressure on services would be to the detriment both to the residents south of Leamington and Warwick and to the future of the towns themselves.
I ask that WDC takes serious concern of the views of the local residents and prepare a revised plan that has genuine democratic legitimately. As it now stands, I wish to express my strong opposition to the proposed Local Plan.

I dispute the need for over 12,000 houses in the local area as independent evidence suggests that local needs are half this number.

* It is wrong to forecast up to 2029 and allocate green land now. It is akin to having no plan at all, allowing developers to uncontrolled growth, just leaving developers to decide what to build and when.


* This plan is not about meeting local housing requirements but is designed to attract thousands of extra residents into an area where there is not enough work for them or the infrastructure to support the numbers.

* Stratford District Council have announced plans to build close to Gaydon which will provide homes for workers at Jaguar/ Landrover which was part of Warwick's plan, so we already have a double count on housing needs.


* The proposed housing development by Stratford District Council and the Warwick District Council plans could not be supported by the infrastructure in Warwick especially the hospital and roads.

* Such a massive development would turn the historic town of Warwick into an urban sprawl and destroy the view from Warwick's most valuable asset - the castle.


* The already overstretched infrastructure cannot cope with what would be a massive increase in traffic; being an out of town development most people would have a car, working couples possibly two. The road bottlenecks at Castle Hill and the viaduct at Princes Drive cannot cope with thousands of extra vehicles. Turning Europa Way into a dual carriageway would be a large car park at peak times as the traffic tried to filter through the viaduct.

* I object to large areas of farmland being built on as this will have a
serious impact on wildlife with the removal of hedges.


* I dispute that no building can take part on the green belt to the north as the council have already indicated their support for the Gateway project which uses green belt land. I believe that the plan to build in the north of the town was changed when residents of the Blackdown area threatened legal action.

* There also a serious risk of flooding in the Aragon Drive / Saumur Way area if the adjacent farmland is built on.

* Allowing traffic to access any new building behind Saumur Way will increase the risk to the many school children who use the cycle path that runs across the end of Saumur Way.

* I am led to believe that the air quality in Warwick is already worse than the legally permitted levels - a situation which can only get worse with the introduction of thousands of extra vehicles passing through the town.

* This is a developers charter not a plan for the benefit of the citizens of Warwick and as such requires an independent investigation into how this plan was put together, the involvement of all concerned in the council and the Henry VIII trust and the real reasons for stopping any development in the North.

I wish to make the following comments in objection to the new local plan;

* The land between Warwick and Whitnash / Bishop's Tachbrook is rural in nature. This green land is important to the aesthetic nature of the town and any building upon it will destroy the 'feel' of the whole area. Previous developments have detracted from the town rather than improved it. The town thrives upon tourism and anything that detracts from the aesthetic qualities of the town will damage business. Current policies on protecting green land should be maintained.
* The number of houses is too high. Projected population growth in the area does not demand it. It takes no account of other developments, such as at Gaydon, and the pressures that this will place on Warwick and Leamington infrastructure.
* The District already have enough sites supporting sustainable development.
* The increase in traffic will cause many problems, particularly pollution, delay to emergency vehicles, greater danger to children and other road users and added time travelling. It will cost residents more in fuel due to traffic increasing.
* Roads are currently in poor repair and additional use will make this worse.
* Road drainage is very poor at the new Morrison's site, the Lidel site and at Warwick school. There can be no confidence based upon this evidence that any new development will improve road drainage and in fact it will make it worse.
* Development on this higher land around Warwick will have a significant effect upon rainfall run-off and will create a flood risk where none exists today. Residents will face increased insurance costs. Warwickshire DC will face significant legal and damages costs if these developments do cause flooding or other damage. This will ultimately cost the council tax payer.
* Air quality is already poor. Warwick is close to the M40 and A46. It is also very busy with through traffic and local traffic. Local transport services are poor. The new development will bring more cars and more pollution. This is a health risk and is proven to increase respiratory illness. This then costs the health services in additional care. Are these cost factored into the plan?.
* Noise pollution is also a serious issue. The constant hiss of traffic from the M40 is always evident. There is also the noise of traffic on the Myton Road and at night it is very loud coming from the roundabout at Morrisons. Additional traffic will make it worse.
* All these types of pollution will drive out residents and businesses from Warwick. Will the council tax charges decrease to reflect the poor quality of life that we will experience?
* There are many better alternatives on brown-field sites.
* I am deeply concerned over the ethical / political questions raised by this planning process. There seems to be a lack of fair representation. There also seem to be a number of cases of conflict on interest. I feel that it should be raised to your compliance officer and an independent enquiry held.

In summary I feel that the proposed development in Warwick is poorly thought through and of detriment to the community as a whole. We will suffer from higher risk to our safety and health, we will face higher council tax payments, it will cost us more to travel and insure our property and it will no longer be a nice place to live. All of this to develop land for houses that are not required.

Additionally I would like to object to the plans for the traveller sites. These persons are seldom true gypsies. They are usually itinerant Irish travellers who make a living and do not pay tax and do not contribute to society in any way. They also tend to participate in criminal activity crime increases in areas that they have sites. It is also true that they dump rubbish and cause damage to property. This costs the council tax payer, but they make no contribution. Their vehicles are rarely taxed and insured. This places ordinary citizens at risk and insurance cost will rise near their sites. Have the council any plans to compensate residents, or decrease their council tax?. If they must have sites then these should be kept as far away from green land and from law-abiding people.

Apologies for the somewhat rambling nature of my objections, but I think that this is a very serious matter and judging by the feeling of local people it is a matter that Warwickshire DC should give very careful thought about.