A.C.Lloyd Homes Ltd wish to support the allocation of 100- 150 dwellings within the Primary Service Villages of Bishop's Tachbrook and Radford Semele.

Paragraph 4.4.3 of the supporting text to this policy sets out a number of criteria for new housing within the Primary Service Villages. This includes the need to be located within the village envelope. The previous Preferred Options Local Plan recognised that there is a limited supply of land within the built up area of towns which necessitates the allocation of land outside the built up area on undeveloped land. The current Revised Development Strategy should recognise that there is a limited supply of sites within the current village envelopes and it should identify the need to build on undeveloped land adjacent to the built up area of villages. This will necessitate the altering of the current village envelopes to ensure that new sites can come forward to assist in meeting the District's housing needs.

With regard to Bishop's Tachbrook, Land to the West of Bishop's Tachbrook identified as site R22 within the SHLAA is an appropriate site for additional residential development to assist in meeting this identified Development Plan requirement for the village. The site comprises 2.39 hectares of land and adjoins the north western boundary of the village. The site is located north of Mallory Road and lies to the rear of existing properties along Seven Acre Close, St Chads Road and Rye Close.

The site is not located within either the open Green Belt or the Area of Restraint and it does not lie within the identified floodplain. It immediately adjoins the existing built up part of Bishop's Tachbrook and is in a sustainable location. The local facilities within the village are within a reasonable walking distance (within 2 km) of the site. These facilities include Bishop's Tachbrook Church of England Primary School which is 450m from the site, the Post Office which is 740m from the site, the Church on Mallory Road and the Public House off Oakley Wood Road

The majority of Leamington Spa is within easy cycling distance (5 km) of the site. Facilities in this locality include the local centre within the Warwick Gates development, the southern employment areas, Whitnash, the town centre and the rail station.

The closest bus stops to the site are located on Mallory Road, just to the east of Seven Acre Close only a short walking distance from the site. Routes X15, 77 and 67B serve these stops. They offer services between Stratford and Coventry hourly between Monday and Saturday; Leamington and Kineton between 7-9 trips per day in each direction between Monday and Saturday; and Leamington and Cubbington 2 hourly on Sundays.

In terms of access to the site, this would be from Seven Acre Close. The speed limit of Mallory Road changes from 60mph to 30mph with the presence of a gateway feature into the village. Visibility splays in a westerly direction can be achieved in accordance with the east bound vehicle speeds.

To summarise the site is in a sustainable location, adjacent to the built up area of the village of Bishop's Tachbrook. Access to the site is deliverable within either the existing highway or land controlled by A.C.Lloyd. Future residents of the site would have the opportunity to access every day facilities and key destinations by a choice of transport modes. The site is available and achievable and offers a sustainable solution to assist in meeting the housing requirement for Bishop's Tachbrook.

In respect of Radford Semele, Land South of Radford Semele identified as site R21 within the SHLAA is an appropriate site for additional residential development to assist in meeting this identified Development Plan requirement for the village. The site comprises 2.59 hectares of land and is located on the western edge of the village. The site is bound to the north by residential development with open countryside to the west and south west. Spring Lane marks the eastern boundary of the site which also forms its primary access point. Development of this site for housing purposes, would form an natural extension to the village and would effectively round-off the built form on the western side of the village. The site is not in Green Belt but is identified within an Area of Restraint (AoR) as identified on the Proposals Map of the Adopted Local Plan.

The site formed part of a larger site promoted during the previous Local Plan Inquiry. Whilst the site was not required for development at that time, the Council acknowledged that the development of this site would not erode the gap between Radford Semele and Leamington Spa by virtue of the fact that the site does not extend the urban edge of Radford Semele any closer to Leamington Spa. As such it is considered that the AoR, in the context of this site, does not represent a constraint to development.

The site would be accessed via an extension of Spring Lane/School Lane into the site at the existing turning head. This would accommodate the needs of pedestrians and cyclists as well as vehicular traffic. School Lane forms a priority junction with Southam Road to the north of the site, which provides connections to the remainder of the local highway network.

The local facilities within Radford Semele are all within close walking distance from the site. These include the Sunbeam Pre-School and Radford Semele Church of England Primary School, playing fields adjacent to the site, the Post Office opposite the Lewis Road / Lay Gardens junction, the church and a Public House. Some of the eastern parts of Sydenham are also within a reasonable walking distance of the site.

The majority of Leamington Spa is within easy cycling distance of 5 km from the site. Facilities in this locality include the town centre, rail station and Whitnash.

The closest bus stops to the site are located on School Lane and Southam Road only a short walking distance from the site. Route 63 operates between Rugby and Leamington. Route 64 provides services between Long Itchington and Leamington via Bishops Itchington. These routes combine to provide a half hourly service Monday to Saturday with Route 63 running four times on a Sunday. The Flexibus 498 runs between Radford Semele and Banbury providing one service each way on Thursdays. There is therefore a frequent nearby bus connection to a number of destinations, including Leamington Spa, Rugby and Long Itchington.

To summarise, the site is in a sustainable location, adjacent to the built up area of the village of Radford Semele. Access to the site is deliverable within either the existing highway or land controlled by A.C.Lloyd. Future residents of the site would have the opportunity to access every day facilities and key destinations by a choice of transport modes. The site is available and achievable and offers a sustainable solution to assist in meeting the housing requirement for Radford Semele.

We are pleased to see that the village categorisation has been "softened" to allow some local influence over actual housing numbers but note that the numbers are clearly grossly in excess of actual village needs or projections in most cases and will impose stresses on village infrastructure in many cases, especially relating to education and car dependency.

The following representation is made by Delta Planning on behalf of Diana Richardson and Peter Jones.

We wish to support the allocation of 70-90 dwellings within the Village of Leek Wootton over the plan period. Small levels of development are justified to support the village infrastructure and provide homes for the future.

In considering the options for future housing, we note that many of the options for the village considered through the SHLAA were rejected. One site not considered was land within our client's ownership west of Home Farm, as indicated on the plan attached. We request that this location be considered amongst the options for village growth in the forthcoming village options studies. It is considered that some new housing could be delivered in this location in a way that would be in keeping with the character of the village, and would have no impact on the Conservation Area. The land has no significant environmental constraints and is close to facilities within the village. Access could be achieved via land within our clients control.

I support the use of brownfield sites to increase the housing stock.

The Planning Inspector who reviewed the Local Plan 2006 stated that Woodside Farm should not be built on now or in the future.
WDC's landscape consultant R Morris stated in the LandscapeArea Statement 2009 that the land south of Gallows Hill should not be considered for urban extension and that the rural characters should be safeguarded from development.

Kingswood (Lapworth)'s designation as a Primary Service Village appears to be based on its score of 53 in the The Draft Settlement Hierarchy Report. However, this score would appear to be wrong for the following reasons: (i) There is not a daily bus service; (ii) The Post Office is for sale and considered very likely to close and, therefore, should not be counted; (ii) The Village Shop is very small, has no scope for expansion, has no car parking spaces at all, and is not in "a cluster of shops and services"; (iv) The Lees Chapel is a specialist denomination rather than CoE; (v) Kingswood has neither playing field nor sporting areas for young people; and (vi) The primary school is constrained. If each of these criteria were scored realistically, the overall score would not be 53 but a figure nearer to 40 which would make Kingswood a Secondary Service Village with a baseline target growth rate of 15%, ie 57 new dwellings.

It is understood from WDC that the reason that Lapworth in the 2012 Plan has become Kingswood (Lapworth) in the 2013 Revised Plan, is that it is WDC's intention to concentrate the development in Lapworth in the Kingswood area so that it is close to the existing amenities. This seems a questionable decision in view of the fact that, based on WDC's figure of 381 dwellings in the Kingswood area, the planned 100 to 150 new houses represent an increase in housing of 26% to 39% in the Kingswood area. It should be noted that these figures are inconsistent with the baseline growth rate of 20% for Primary Service Villages stated in Section 5.9 of The Draft Settlement Hierarchy Report which would indicate a figure of only 76 new houses. Hence, WDC does not appear to have applied its own guidelines to Kingswood (Lapworth).

It is inconceivable that the existing infrastructure of Kingswood could support an increase of 26% to 39% of the current housing stock for the following reasons:

i. It is acknowledged in Section 4.2.18 of the 2012 Preferred Options Document that the Lapworth village School, which is in Kingswood, is "at capacity" and "is sufficient only for village children. Any development in the village will require expansion of the school, ideally up to 1FE, but site is constrained. Further work required." Has the further work been undertaken to identify a suitable site for expansion of the school?

ii. Station Lane is a narrow road which is severely congested at the start and closure of each school day and when there is an event at the Lees Chapel. Has consideration been given to how Station Lane and the other roads in Kingswood will cope with the increased vehicular traffic emanating from 100-150 new houses?

iii. Local residents are very much aware of the surface water flooding which occurs in Kingswood. The surface water flooding map (Plan B2) in the 2013 Strategic Flood Risk Assessment Report does not appear to reflect local knowledge of the seriousness of the problem in Kingswood. In both the 2012 and 2013 Strategic Flood Risk Assessment Reports reference is made to surface water flooding and each report states: "The Environment Agency has asked that, should development take place in these areas, further work should be carried out to investigate the nature and scale of the risk posed, so that mitigation can be put in place and the areas can be targeted through appropriate policies for reducing flood risk". In view of the Meteorological Office's opinion that extreme weather events will become more frequent in the future, we trust that WDC implemented the Environment Agency's request for further investigation before it selected its sites in Kingswood. Perhaps WDC could confirm whether they did.


Furthermore, at a "drop in" session at the Lapworth Village Hall on 17 July 2013, lists of early site options were tabled by WDC with a lack of clarity over which of the sites would actually be made available for development by their current owners. Although I have been referred to the site selection methodology for strategic sites, I have been unable to ascertain either the criteria or methodology that WDC are employing to identify potential sites in Kingswood (Lapworth). In particular I should like to know whether the well-being of existing residents is a criterion.

I'm a resident who lives in Saumur way closer to farms. We moved to Warwick from London over 20 years ago. Within last few years we feel pollution has been increased and getting worse. Adding thousands of extra vehicles will make the air quality poor & simultaneously roads will become dangerous. There had been flooding on Saumur way and Myton Crescent, evidence has been presented to WDC.
I object very strongly to the consideration of Planning Applications at this stage for building on an Area of Restraint that has
not been authorised. Please respect our view & reject the New Local plan

The 12,300 overall target is based on a series of assumptions that mean it is not suitable as a figure to be used at this stage. Furthermore housing allocation is yet to be assessed with neighbouring Councils.

The assessment of capacity within and around villages is flawed and not yet advanced enough to inform target dwelling numbers per settlement. Targets should not be displayed or fixed at this stage because the Draft Settlement Hierarchy Report 2013:

1. Is a draft report as mentioned in the introduction by WDC,

2. Is, by admission, open to debate (paragraph 4.14)

3. Takes no account in its marking, whatsoever, of whether a particular settlement is within the Green Belt. This is a fundamental for a sequential test in determining suitable locations for development.

4. Requires more work, by WDC's admission, on site and planning policy constraints.

5. Is extremely arbitrary in its scoring system.

6. Is prone to inaccurate data affecting results (for example Hatton Park showed 2020 people, if this were 21 fewer then it would score 2 points less, putting it on a par with Bubbenhall which is a 'Small and Feeder Village' with no housing target - instead Hatton Park is a Secondary Service Village with a target of 70-90 dwellings).

7. Was not made available for public consultation.

Any development in primary or secondary service villages must involve full consultation with the communities involved so that development compliments existing provision and does not increase strain on local services. As previously stated, the future population projections must be robust and take into account the types of individual/family that are predicted to move into the area. If it appears that a significant proportion of population growth will comprise single people, young professionals or smaller households, this would indicate that development in villages would be inappropriate and that the priority should be town centre/brownfield development.

The concentration of the development in the south of the district - 4550 houses in sites on the edge of Warwick and Whitnash will cause severe strain on the infrastructure. Traffic is already a problem and the mitigation proposals do nothing to address the problems south of Warwick and Leamington. The road through Barford is already grid-locked at peak times with traffic avoiding the direct routes and further large developments in this area will only exacerbate the problem. A major new road to take traffic south from the proposed new development is required.

Thank you for consulting us on your New Local Plan Document. I can confirm that I am pleased to see that the former Ridgeway School is still included as an allocation. I can also confirm that we are also pleased to see that a number of other sites referred to as K23, K24, L24, L25, L44, L46, W17, W30, and W31 in the SHLAA process, are identified as Smaller Urban SHLAA Sites in the plan. These sites have not been identified because it was requested that they remain confidential for the time being. The County Council also supports the inclusion of the Leamington Fire Station site in the Small Urban SHLAA site category. I confirm that the County Council is still keen to progress these schemes forward during the plan period and that they will be deliverable.

I have been instructed by my client The Rosconn Group, to respond to the recent publication of the Core Strategy Consultation and would make the following comments.

We are in general support of the overall approach taken within the plan but would question the total number of dwellings required especially in relation to the creation of 10,200 new jobs. We have read and understand how the figure of 12,300 new homes has been arrived at, however with the ambition to create so many new jobs, coupled with changing demographics and in-migration we believe this number needs to be higher.

We welcome the allowance for development in rural areas both in terms of Primary and Secondary service villages as well as feeder villages and Hamlets. We believe that this will allow for economic and social sustainability within these areas and sustain the wider rural communities.

With regard to the Primary and Secondary Villages we believe it is important to draft the village envelopes as a matter of urgency and that these envelopes need to be genuine village envelopes rather than being drawn with pre conceived ideas of where development will go. The same is true for the feeder villages and Hamlets. Further detail needs to be provided as to how these settlements might be grouped together in hubs or networked clusters. There should be further consultation on these aspects.

Further clarification needs to be given in relation to what 'proportional' means in terms of numbers or scale of development. Will this be a percentage of units in the village; will it be a maximum amount of units etc.? We consider a critical mass of units is required to ensure there is a realistic chance of these villages regenerating and becoming economic and socially sustainable.

It is important to avoid a "free for all" or "a first come, first served" approach to development. Having given the issue much consideration and having looked at examples in other areas we believe that development should meet one of the following four criteria.
* Be on previously developed land
* Be community led
* Be for an identified local need, or
* Should demonstrate a business case that development will help a local service or amenity




















The other aspect, which we have concern about, is the definition of infill or small group of dwellings? Concern is related back to needing a critical mass to ensure that local facilities continue to operate. Three new units built as infill development is unlikely to keep a school open for example. Critical mass will be the key to the survival of some rural areas.

We look forward to receiving acknowledgement of receipt and receiving your feedback and comments in due course.

see attached

see attached

see attached

see attached

see attached

see attached

see attached

I would like to comment on the local plan,i do realise that more housing is needed the number being suggested however is unbelievable,as a bishops tachbrook resident i attended a meeting recently and when a representative was asked how the roads can possibly cope with such a huge influx of traffic we were assured a study had been done and indeed the roads could cope if improvements are made.Making the the Greys Mallory island larger and making Europa Way into a dual carriage way will help trafic along but it is still all going to finish up at the Ford island where it will back up for miles [has anyone seen the traffic backing up down the slip road to the motor way?]I suspect this is of little interest as the housing cannot possibly be just for "locals"[money for greedy developers]so it wil be for commuters going in the opposite direction ie.towards the motorway.I doubt whther this area would be anywhere near as attractive for development if it was not for the motorway,add to all this the already poor air quality being polluted even more our only hospital bursting at the seams ditto doctors surgeries where are the sick going to go?People live in villages because they want to live in smaller community and avery fine one we have here,we therefore do not want to be joined up to some sprawling suburb.there is something else that seems puzzling why is that it was origionally thought we needed 15 more houses in tachbrook and now it is
100 when there will be hundrds built little more than a mile down the road.to add insult to injury we also learn we are to take the lions share of the traveller sights around here[people are already worring about losing thousands on the value of their homes]it is a shame we cannot decamp to the north end of the town!it appears to be the favoured end.People here are very annoyed that they have been ignored when their way of life could be changed forever.


i am sorry that i ommited my name on my previous e mail however after attending the recent meeting i can only say that my concerns are jutified.There is no possible way that the local roads will cope with the huge influx of traffic,widening and improving will not stop the bottle neck at the fords island,this is not housing for local people we were told 50%is for migration 40% is for afordable housing isuspect few of the people allocated social will be from any where near leamington or warwick they will be people from coventry or birmingham and their councils either cannot or do not wish to house them,the bulk of the rest will probably go to immigrants.tachbrook has always had a wonderful community feel many people have lived here all their lives and enjoy a "village" life this will all end when we are all joined together in the suburban sprawl that is about to come thanks to the parks that will join us all up.I cannot understand the need for 100 new houses in the village when there are thousands being built a mile down the road!even people with family in the village cannot mind travelling that short distance.one of the proposed sites is behind holt ave the field next to it is one of those suggested for travellers!
do the council really believe people wil buy a house next to a travellers sight?
local people feel absolutely impotent-we all know that no matter how much we complain our way of life and peace of mind is about to be destroyed forever; surrounded by housing and land bought up by travellers who pay nothing whatsoever into the system and get everything out for free,the local school will have to keep several places free for their children (the ones they say do not exist)keeping local children out.All in all it is a very depressing future for people who have worked hard all their lives to see the fruit of their toil lose thousands off its worth and live in a very less pleasant and safe place.

see attached

Local Plan-Gypsies and Travellers June 2013
Norton Lindsey Parish Council
Pitches required forecast---25in 5 years and 6-8transit over plan period
GT14- this site has been the subject of numerous planning applications for a poultry sheds and has been successively rejected by the Planning Inspectorate after a campaign by the Parish Council, local villagers and the Local Planning Authority because of the dangerous access to the site amongst many other reasons.
The Parish Council do not support the inclusion of this site since it, in addition, fails to meet several of the policy criteria.
1. There is no GP surgery or public transport and the local school is already oversubscribed.
2. This area has been known to have excess surface water at times of heavy rainfall.
3. There is a dangerous access for larger vehicles to the site and it is not large enough for turning and servicing on site.
4. The site is in the Green Belt.
5. The Village is one of the few remaining hill top villages in Warwickshire and this visual entry to the village is one which has not been spoilt by development.
The Parish Council therefore reject this site as being a candidate.

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

1. Assumptions

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

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

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

2 Housing

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

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

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

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

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

3. Economic considerations and Employment

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

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

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

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

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

4. Infrastructure

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

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

5. Sustainable

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

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

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

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

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

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

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

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

I am writing to object strongly to the new 'Local Plan' and the disastrous impact that the implementation of this outrageous and unsustainable proposal will have on Warwick Town.
In particular, I would like to object to the amount of houses to be constructed on green belt and farm land between Warwick, Leamington and Bishops Tachbrook for the following currently already evident and problematical reasons:
* Currently Europa Way is gridlocked daily during rush hour and access to and from the M40 is nigh on impossible at peak times. Thus car-drivers seeking another route attempt to cut through Warwick which thus becomes jammed and cars move slower than walking pace. On top of this much traffic is force to come t Warwick on a daily basis due to the high concentration of schools in and around the town centre.
4,500 new houses will potentially lead to 9000 more cars on the already over-stressed road infrastructure and no manner of road or junction 'improvements' would improve the situation as there will ALWAYS be a bottle-necks to Warwick and Leamington Spa.
* Stratford District Council are also proposing over 4500 houses in the environs of Lighthorne and Gaydon, thus another potential 9000 car users - all within 9 miles. i.e. 18,000, yes - 18,000 more drivers on the local roads - mostly the Banbury Road. Many of these will be heading to Warwick for the schools; or will need to use the already overloaded M40 and the access points to the motorway system.
* Air Pollution is already a major problem and is at an illegal and poisonous level in the town centre of Warwick. No proposals or plans have been offered as to how this can be reduced or of how the impact of 9000 more cars in the close vicinity might make the current issue many times worse.
* The NHS Services and Warwick Hospital is already under much pressure to deal with the current needs of our district. More potential patients would add more back-log and create impossible targets for a sustainable and efficient service.
I see no provision in the 'Local Plan' to enlarge the hospital. In fact, even the car park cannot currently cope and so how would the site be able to cope?
* The greenbelt and farmland is a very important dividing area between the towns of Leamington and Warwick providing a 'green-lung' and open landscape. It is a thriving and successful agricultural business.
The view from the castle and the Avon Bridge would be destroyed by the urban sprawl of a modern estate, with a possible sea of solar panels and mixed heights of buildings. This will greatly diminish the current historic value of Warwick.
Tourism will be affected as the current charm and reputation of a day visit destination will be greatly impacted thus affecting local businesses.
* Parking is already an issue in the town centre and I do not see any provisions to alleviate this problem with the arrival of 9000 and more, new home occupiers who will be car dependant.
The verges of the farmland (SEE GALLOWS WAY) that is proposed for development are already littered with cars every day thus creating a dangerous hazard and also destroying wildlife habitat. This needs to be addressed URGENTLY. It also points to the fact that there are not enough provision for car spaces at the technological park and so where will more employees park?
There is also not enough parking provision on Tachbrook Park
* It is proposed that some land will be set-aside for new employment BUT the current Ford site has office building land available and 'APPARENTLY' no clients can be found to occupy this space? Why not use this area for housing? People need to be near the supermarkets and there are 5 in this area!!!! Who will occupy this new 'employeent' land?
* We need to look at more Brownfield sites for any local demand which is less than 6000 houses. The Pottertons site is a prime example of misguided and inappropriate development where many units are still not sold and several buildings have not been completed as the DEMAND IS NOT THERE.
The Pottertons site needs to be fully occupied and works completed which 'may' alleviate some of the new development issues.
In brief summary:
Too much pressure on infrastructure and roads; water supply and services.
Road capacity already reached.
Illegal levels of pollution.
Wildlife habitat destroyed.
Valuable food resources from agriculture - destroyed.
Tourism and local businesses - damaged and threatened.
Services overloaded.
Current housing not occupied or developments completed.
High concentration of supermarkets in one area necessitating car use for majority of home-owners.
Warwick will become an empty soul-less island in the middle of a giant car-park!
In short, I love my town and I do not want to see it drown beneath a pile of bricks and cars. The ''Local Plan' is ridiculous over-implementation in extreme and the quantity of new housing needs to be reduced by 50% for the future sustainability of the town and its' residents.

Attached

It is important that Warwick District Council stand firm on their refusal to allow building development on land to the north of Leamington. Land designated Green Belt was so planned for a reason, this being to provide 'lungs' between towns. If this land were built on now it is easy to imagine future applications for further development until Leamington and Kenilworth become one town. The area around Milverton is very special and should be preserved for future generations. We live on a crowded island and green spaces must be cherished.
That houses are needed is recognised but the suitable siting of any application must be very carefully considered , and Milverton is not such an area.
Any application from Coventry City Council to build to the south of their area should also be firmly resisted.

see attached

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

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

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


2. Principles of the Development Strategy

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

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

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

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

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

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

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

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



3. Proposed Locations for Housing Development

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

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

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

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

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


4. Gypsies and Travellers

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


5. Proposals for Employment Land

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

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

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

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

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

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

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


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

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

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

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

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

Table 4 Revised

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

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

H. Excess providing even more contingency and flexibility 8.9



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

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

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

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

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

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

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

see attachment

see attached