Whilst AC Lloyd (Homes) Ltd support the identification of Radford Semele as a Primary Service Village where additional housing is required; they consider that due to the sustainability credentials afforded to the settlement, that the level of housing proposed should be a minimum and in fact the village could support more new dwellings to assist in meeting the District's requirements.

Whilst AC Lloyd (Homes) Ltd support the identification of Bishop's Tachbrook as a Primary Service Village where additional housing is required; they consider that due to the sustainability credentials afforded to the settlement, that the level of housing proposed should be a minimum and in fact the village could support more new dwellings to assist in meeting the District's requirements.

I refer to your letter dated 5th December 2013 about the above loacal plan.

I have delayed replying to your letter to ensure that I have given my reply proper
consideration rather than respond from a "knee jerk" reaction.

Whist I understand that there is a need for additional housing and that central Government
has made certain demands on local authorities, I do think that an additional 12000 homes
in the district is way over the top.

Just think for a while at the roads and infrastucture overload we already have in the area
and consider what impact a further 40/50,000 people will do.

Taking the roads - our towns are not able to be altered to accommodate a large increase
in traffic. The Police would certainly have to be increased in numbers not to mention the
Fire Service which is being reduced in size as we speak.

But my main concern is the Hospital, I have a particular interest in the support our very
well respected hospital provides to the community and I am sure that it cannot be increased
in size to support another 40/50,000 people. Neither can Coventry take on this extra load
on top of the additional houses planned for their area.

So far the plan put out for consulation both for the Towns and the Villages do not have any
proposals for enlarging the essential support services I outline above and until such propsals
are forthcoming it is my belief that any substantial increase in housing should be postponed.

I would welcome your acknowledgement of receipt of this message and confirmation that my
concerns will be propoerly addressed.

It is proposed that Barford is to take 70-90 houses.
The proposed options and others makes 80 + 6 with outline permission + 1 applying for permission = 87
This is already at the high end and adding for windfalls, additional affordable homes needs in the future will take the village into Primary Service Village status.

The interim level of growth of 12,300 homes has not been evidenced as being demonstrably correct. This is at the extreme upper end of the estimates. A more realistic needs assessment is of the order of 5,500 homes. The estimation was completed in 2012 before the significant downturn in the economy was experienced.

The classification of Hatton Park as a secondary service village is incorrect based on the calculations in draft settlement hierarchy report. At best it is only a tertiary service village and the number of allocated new dwellings should be reduced accordingly

This latest version of WDC's local plan seems much the same as last summer's one. An attempt to distribute some of the dwellings seems to have slightly reduced the number proposed for the area just south of Leamington and Warwick. This number still comes to 4550 dwellings.
Stratford's proposed allocation at Gaydon will further aggravate traffic.Wider and maybe more roads are essential for the proposed 4550 dwellings south of Leamington and Warwick. Bus services improvements are planned but past experience is that users are reluctant to use them. Buses in this area are expensive. Rather than putting a very high proportion of the development in one place and rely on road 'improvements' to support it, WDC should distribute more of the developments along rail corridors. WDC should look at one or two eco-towns each built around a new (or perhaps existing) railway station on the lines to Solihull and/or Coventry. An eco-town of around 1700 dwellings would allow all residents to be within 400m of the station. This could also be the site of the local health centre, primary school, shops and other community facilities. This approach would be more sustainable and help residents cope with rising fuel prices.I suspect this approach is ruled out simply because it means building on green belt which seems to be sacred.WDC should pursue such a development policy while seeking reform of green belt laws and designing the towns to preserve the overall concept of green belt and ensuring the development is truly sustainable.

Whilst the Council acknowledge that the 12,300 homes for the District between 2011 and 2029 is an interim figure and refer to the Coventry & Warwickshire joint Strategic Housing Market Assessment (SHMA), the significance of this emerging evidence cannot be understated. The SHMA has already been published though regrettably not reported to Warwick DC Executive Committee ahead of the close of this consultation. It has found that the housing need in all of the authority areas, including Warwick District, is likely to be higher than that currently planned for, i.e. 720 dwellings per annum, as opposed to the planned for 683 dwellings per annum.

This is a significant increase and could have considerable bearing on the number and/or density of sites required. We appreciate that this is only part of the evidence base feeding into the emerging Development Strategy which is yet to be tested and consulted upon, however, it gives a strong indication of how the housing requirement is likely to evolve. Furthermore, the NPPF states at paragraph 158 that Local Plans should be based on adequate, up-to-date and relevant evidence. Therefore, any objections received to specific site allocations should be considered in light of the fact that those sites currently proposed are likely to be the minimum that the District will have to allocate in order to meet the full objectively assessed need and boost significantly the supply of housing as required by paragraph 47 of the NPPF.

AC Lloyd (Homes) Ltd support the identification of Hatton Park as a Secondary Service Village where between 70-90 homes are required.

I do not accept a further 12,300 houses are required within the plan period. These homes are not required for local people and will be taken up by incomers utilising transport links to employment elsewhere in the Midlands, London or Europe. This may well improve the economic status of the District, but at the expense of its unique character.
In particular the split of 15% for the villages underestimates their capacity, at the expense of large extensions to the built up areas of Warwick and Kenilworth, where the same tests of landscape impact do not seem to have been employed.

Deeley Group Ltd support the identification of Leek Wootton as a Secondary Service Village where between 70-90 homes are required

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General commentary about proposal in Hampton Magna - OBJECTIONS
Housing Numbers and Duty to co operate with other district councils - the outcome of the Gateway and other research initiatives into housing numbers particularly the JSHMA may well change the housing needs in the district. This is acknowledged in the document but importantly any reduction in numbers of houses deemed necessary through this must immediately lead to removal of any building on village green belt areas without debate.
Parish Councils view important - The document highlights the importance of agreeing any development with the Parish Council. Budbrooke PC have been communicating their objection since the start of the process against the development including its scale yet are not being listened to
Residents View - Planners and the council must stop ignoring the opinion of residents in these consultation processes. The voices of 830 resident in Hampton Magna who signed a petition with good arguments against proposals in the village have been cast aside despite reasoned argument and local knowledge of the issues faced.. To quote Cllr Caborn on the local plan website ".....it is important that we move forward as quickly as possible with our local plan and these consultations will give us the chance to do that with an understanding of what people think...." So what is the point to the process if opinion is ignored ?
Road Links - I do not support any possible proposal for a direct link with the A46 into Hampton Magna. I understand that it was considered too dangerous when Warwick Parkway station was built and the same applies even more now. Any such link has the potential for gridlock and the use of the village as a cut-through to surrounding locations.

Village discrimination - it is biased and therefore unfair that villages are having houses built on green belt land when other potential development areas such as Milverton have been removed from the proposals due to green belt issues there. Again an independent review of the decision making process is necessary.
Sustainability - the proposed level of growth in Hampton Magna is unsustainable with infrastructure and transport unable to cope. As stated in Chapter 2 Hampton Magna has had considerable expansion in past years. In addition there have been many developments in the surrounding district impacting on sustainability of the area. The scale of the development is at best too large.
Infrastructure - There has not been sufficient planning and analysis of infrastructure issues to be able to make a reasoned judgement on the viability of the potential sites. Sewerage and Drainage issues have been a particular concern consistently from many residents who have experienced the problem. The sewerage and electricity systems in Hampton Magna make the village a special case as they are already in need of major upgrading and the proposed numbers of additional housing will make matters even worse. There are major problems with the drains all over Hampton Magna. Even when they were newly built Severn Trent refused to accept them because of the standard of construction. The electricity system dates back to the old Barracks and is inadequate.

Transport/congestion - A major issue that has to be considered in choosing a site is the increase in traffic which if brought within the village estate would be dangerous (see comments under specific site sections later). Equally planners rejecting residents previous consultation comments about transport issues by saying and i quote "advice from transport experts at the county council suggest that the development proposal can be accommodated" is ridiculous. The only way to know for sure is for proper analysis and research to be undertaken by an independent party , not the council and this would reveal how transport and the dangers around the village and particularly the preferred site would stop the development.

Village development in green belt - It is a concern that the proposal has more houses proposed on green belt compared to non greenbelt villages - this position must be reviewed again for other non green belt opportunities. By default development on green belt cannot be justified under the "exceptional circumstances" caveat within government policy when there are so few houses proposed on green belt around villages compared to the total 12 000 district wide presumed housing need. Just 500 houses across village green belt (100 in Hampton Magna) cannot be so important in the overall total number to justify green belt destruction. Common sense must prevail.
Local school capacity - This is already undergoing expansions with plans for further classrooms. School run parking is already leading to traffic congestion and safety problems. Additional numbers will add to this problem

Sharing development with Hampton on The Hill - Hampton on the Hill adjoins Hampton Magna and utilises its amenities, so it is not clear why there is no option to develop any housing at all in Hampton on the Hill. Although opposed to any disproportionate housing expansion in Hampton on the Hill, some additional expansion should be seriously considered. If it is not considered appropriate then the reasons for this should be fully explained in detail. I refer to the National Planning Policy framework 2012 (paragraph 55) and the WDC Local Plan P - 9. Hampton Magna infrastructure facilities should be considered as shared with Hampton on the Hill as residents from this village use them and there is no natural boundary e.g. road or river between them. Also see comments on the specific site options later regarding site 6.

Independent Inspector examination of the site options - Planners opinions should be independently tested as the planning departments site conclusions are too "blinkered"


Hampton Magna Site Area 1 Preferred location (land south of Arras Boulevard) - OBJECTIONS - site is not considered appropriate against others

Land Usage and Covenants - The site has previously had footpaths in existence. It is also believed that there are covenants in place restricting use of the land through the original land Endowment to King Henry VIII Endowment Trust.
Transport - Access to this site is dangerous if Arras Boulevard is used to access the site and significant changes to roads are against policy in the current LP (chapter 8) RAP10 which states that 'development would not be permitted which would require major modification to surrounding rural roads'.. Importantly there are 3 blind corners along Blandford Way and the southern part of Arras Boulevard adjacent to the site where presumably access to the houses would be . Also the exit from Curlieu Close is a blind sharp exit on a corner itself which would be dangerous with increased traffic volumes up and down Blandford Way/Arras Boulevard. There have already been motor accidents at this location. It should also be noted that Driving Schools use Arras Boulevard extensively and also worryingly conduct manoeuvres between and around the blind corners. Bringing large increases in traffic through the village estate roads when children walk to school and to the recreational park area at the end of Curlieu Close would create considerable dangers. Curlieu Close is used by many as an alternative drop off point to the school because of the congested area immediately outside the school which will only get worse at it is forced to expand - more dangers and residential impact.

On Left
Blind access route up Blandford Way

On Right
Further blind access route Blandford into Arras

On Left
Further blind access route Arras - adjacent to site 1 access point
On Right
Blind corner on Curlieu Close - Arras right and Blandord Way left



Dangerous manoeuvres on Blandford Way and between blind corners on access road to site 1

Flooding - Whilst not on the Environment Agency flood map the field regularly floods and this would only be worse with development on it. Increased numbers of houses on the scale proposed could increase this risk and so a full study of flood risk should be undertaken so that residents are not subjected to greater risk of flooding from large amounts of the area being concreted over.



Flooding in the preferred site field December 2013 and another example of the open character countryside of the village that would be lost.



Ecology - There are bats in the hedgerows which are protected under legislation , this has been highlighted by the two land owner investigations in summer 2013. There are also wild birds and birds of prey and wild foxes. Animals were "moved on" when the Warwick Parkway Station was built (on green belt) and should not be disturbed again. Protected species of frogs, toads, newts etc. are also known to be in the area. A thorough study should be undertaken and the rules applied to individual householders should be applied equally stringently to developers

Residential Impact - The report implies that residential impact will be minimal. Closer inspection would show that this is not true with at least 60 houses being impacted (for just 100 new ones on the site). It should be noted that Site 5 has been eliminated due to residential impact yet that impact is little different to that felt at site 1. Planners should review again the residential impact which is acknowledged as an important factor.

Landscape Impact - contrary to the report the impact on the landscape would be significant with fantastic open views across the countryside looking outward to the South. That open character should be protected in line with the NPPF paragraph 86.


Site 1 green belt field and the open character views of the village across the south




Site of Special Historical Interest - The Gog Brook ponds and ancient hedgerows should be preserved and protected. They are one of the few remaining links with the past and belonged to the old monastery which used to stand there

Buried armaments from the old Barracks / First World War Hospital - Hampton Magna is built on the site of the old Budbrooke Barracks and therefore has a unique problem with buried armaments. Several have been uncovered over the years. The Copse on the preferred site should have entry forbidden as, it is believed, armaments are buried there. A First World War hospital was situated on the proposed site and as a result there may be buried bodies in the surrounding area. These factors are not recognized in the Consultation and their impact must be assessed

Conflict of Interest -The land is owned by King Henry VIII Trust who also partly own a critical piece of land to the Local Plan around Europa Way and which the local district plan attaches great importance to developing. It was known in Hampton Magna circles that Site 1 (land South of Arras Boulevard) was a preferred location for building before commencement of any consultations. A fully independent review of the decision to prefer site 1 in Hampton Magna should be undertaken to ensure there has been nothing prejudicial to the process from such conflicts of interest.

Hampton Magna site area 4 (West of Stanks Farm) - OBJECTIONS - site has not been equally considered against others

Detachment from the village - The statement in the report that this area is detached from the main settlement is incorrect. On review of the map it is clear the area is as close to the school and park as other areas of the village to the south west of the village apron verging on Hampton On The Hill.
Landscape impact - impact would in fact be relatively low with use of appropriate screening along perimeter road on access to the village area under the railway bridge . Some natural screening already exists. This site would also naturally extend the village housing perimeter along the main access road.



Village main access view of site 4 , screening easily possible as already in part


Ecology - Low impact on wildlife compared to other sites. Much of the wildlife was disturbed and has moved on and resettled following building of the Warwick Parkway Station.
Coalescence - Site has a natural permanent break from further expansion to other areas with the railway , Parkway Station and main Birmingham Road infrastructure between Warwick and Hatton.
Residential Impact - relatively low plus the land naturally falls away from existing housing.
Location - Being close to the train station would attract professional people (a quoted reason for expansion) who commute to Birmingham/London without the need for driving/parking at the station reducing congestion and alleviating further car parking pressures on the station facilities.
Traffic - the site would significantly reduce dangerous traffic flow as vehicles would not need to travel along the estate roads themselves if access was provided from Old Budbrooke Road. A junction off there would also slow speeding traffic along Budbrooke Road.

Hampton Magna Site Area 6 (Maple Lodge) - OBJECTIONS - site has not been equally considered against others
Residential Impact - minimal due to the position and outlook of existing houses on the estate.
Landscape Impact - the report commentary is incorrect. There is already natural "screening" from the main road so impact on landscape views from the village and Old Budbrooke Road is very little. There are also few houses or main approaches to the village on the North West flank of the proposed site so visual landscape impact is small. The falling nature of the site will help here as well. Use of this site would protect the open character of the village (NPPF paragraph 86).
Traffic -A further 100 to 150 houses using their vehicles through the single carriageway main access to the village would put a vast amount of strain on these minor roads, as a result they may require modification, this would be against policy in the current LP (chapter 8) RAP10 which states that 'development would not be permitted which would require major modification to surrounding rural roads'. It is suggested that site 6 is much more appropriate for development as there is access via the A4189 onto Hampton Road rather than just the traffic controlled railway bridge and minor roads. The same principle would reduce dangerous traffic impact as vehicles would not need to come through the centre of the village unlike the preferred option site 1. There is good access off the main perimeter road to the site as entry would be off straight piece of road near Maple Lodge lending itself well to a roundabout system with existing estate road. Other access plans could also be formulated. This would also help break up the speeding traffic rat running through to Warwick Parkway Station or when there are problems on the M40/A46. There is also an alternative access to the area off the main Birmingham Road via Ugly Bridge which would help to a degree with traffic diversification in addition to the access off Hampton Road.




Perimeter road access area into Maple lodge site 6 and showing natural screening



Site Suitability - this site should be one of the most relevant sites for any development to occur as it conforms to many of the existing policies outlined in the LDF and policies contained within the LP which are still in existence. In particular chapter 8 of the LP (Rural area policies) sets out some key policies for rural development that are still in use, RAP1 states that development will only be permitted where it is on previously developed land within limited growth villages (Hampton Magna is one of these limited growth villages). All of the selected sites, bar sites 3 and this site 6 are previously undeveloped sites, therefore if the new housing development is to conform to this policy it should immediately make site 6 much more attractive to the LPA than any of the other 4 sites. WDC states that it is because site 6 is located within a very sensitive landscape area as its reason for dismissing the site, however , all of the sites around Hampton Magna are sensitive landscape areas, all are zoned as greenbelt with no additional policies or protections (such as SSSI or Site of Nature Conservation Interest) on any of the sites. Further to this site 6 is an area already developed (25% of the site already contains buildings/development of some sort), therefore the impact on the current landscape will be much less on this site than on any of the green field sites, and as this is the only reason given for dismissing this site it MUST be reconsidered.

It is also mentioned several times within both the LDF and the LP that any development should prevent towns from merging together, the NPPF also states that two of the 5 purposes of greenbelt land are to 'prevent neighbouring towns merging into one another' and to "'check the unrestricted sprawl of large built up areas" (Paragraph 80). It could be argued that development to the North, South or East of the village will bring the border of the village dangerously close to Warwick, whereas to the West there are no towns within close proximity, this again would make site 6 a preferred site. Although it may be suggested that development will serve to merge Hampton Magna with Hampton on the Hill these two developments have already merged to a degree. There has been a lack of a thorough consideration of the site in the first instance.

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It would be an equitable and rational proposal to distribute the housing required to meet whatever target for the next 15 - 17 years is decided upon for the Warwick District, throughout the towns and villages. I therefore support planning for growth in our villages and support the proposal that the mix of houses should include sufficient affordable housing. This would enable the rebalancing and revitalising of village communities to avoid the progressive ageing of the population, withdrawal of services and all the other disadvantages this would bring.
Since there is such an issue over the provision of suitable sites in our main towns, there is a strong case for extending the policy beyond the ten Primary and Secondary Villages so that villages take a larger proportion of the whole. It is noted that many of the settlements are in the green belt and there is reluctance to breach the green belt policies. However, it should be recalled that forty years ago when it was created the intention was to avoid urban coalescence. It has been successful in doing that but at the same time it has also contributed to the arrested development of villages and other settlements to their detriment. The Minister has conceded that the greenbelt may be amended where there are exceptional reasons to allow development and it is clear that unless housing targets are reduced for the district or more development is allowed in villages there will be damaging pressures to develop in our towns with serious consequences to heritage and conservation not to mention the impacts caused by excessive traffic. Surely the exceptional reasons required for a change.
It is arguable therefore that the plan to deliver 1000 dwellings ( 15.1% of the total) through village development is under ambitious . Looking at table 2. Villages and Number of Dwellings - if we take the upper figure shown for the Primary and Secondary Villages we are looking at 1200 dwellings not 1000. If you looked for building opportunities in the next 10 villages surely a further 300 houses could be added to the total bringing it to 1500 dwellings raising the village contribution to 22.6% of the overall requirement. Housing in the smaller villages should help encourage and/or support the facilities and services these rural areas need.
Turning to the allocation of housing shown under 2.14 Under RDS4 of the revised Development Strategy, we see that:
Brownfield sites are to yield 380 dwellings ( 5.7% of overall requirement)
Sites on the edge of Warwick, Leamington and Whitnash - 4550 dwellings( 68.6%)
Sites on the edge of Kenilworth - 700 dwellings ( 10.6% )
Village development - 1000 dwellings ( 15.1% )
At the latest count Warwick had a population of 30,114 and Kenilworth 22,413. It is inequitable that Kenilworth should get away with such a low figure in comparison. In our towns there are not the same criteria for expansion as in the villages. Different factors come to bear and the question is not about supporting services but more of finding areas suitable physically and environmentally suitable for development and an equitable plan would be for our towns to take new development in proportion to their size rather than overwhelming Warwick with the product of new developments whether it be traffic, school children or patients for our doctors' surgeries. The green belt is used as an expedient excuse for dumping of 4500 houses on the southern edges of Warwick, Leamington and Whitnash. After 40 years the time is overdue for a review of the green belt. It has become anachronistic and it is clearer by the year that there is a need to re-balance our communities where the imposition of the green belt has inflicted an out of balance settlement pattern on us. Just look at Leamington, where successive developments forced to the south leave its southern suburbs artificially remote from the core services they need which are to be found in the town centre.
Sadly, the imposition of these out of date green belt policies is now seen by many of us living in Warwick and the south as being used as an excuse used by politicians from Kenilworth for pressing more development on areas far from their homes and wards in Warwick and other southern settlements.
All in it together? No way in this case.

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