Thank you for the opportunity to provide feedback to the proposed policy.

Network Rail is the "not for dividend" owner and operator of Britain's railway infrastructure, which includes the tracks, signals, tunnels, bridges, viaducts, level crossings and stations - the largest of which we also manage. All profits made by the company, including from commercial development, are reinvested directly back into the network.

Network Rail has the following comments to make.

Hatton Station - Network Rail would highlight that proposals to provide additional housing in the village should be accompanied by S106/CIL developer contributions towards improved access/passenger facilities at the station, given that development is likely to increase patronage with increased footfall at the station as a result of the increased number of dwellings.

Shrewley - sites identified for housing are positioned at the top of a railway cutting. Developers will need to seek advice from our asset protection team to ensure that the necessary measures/advice are in place to prevent any proposals from impacting upon the safety, integrity and operation and performance of the railway..

Where growth areas or significant housing allocations are identified close to existing rail infrastructure it is essential that the potential impacts of this are assessed. Many stations and routes are already operating close to capacity and a significant increase in patronage may create the need for upgrades to the existing infrastructure including improved signalling, passing loops, car parking, improved access arrangements or platform extensions. As Network Rail is a publicly funded organisation with a regulated remit it would not be reasonable to require Network Rail to fund rail improvements necessitated by commercial development. It is therefore appropriate to require developer contributions or CIL contributions to fund such railway improvements; it would also be appropriate to require contributions towards rail infrastructure where they are directly required as a result of the proposed development and where the acceptability of the development depends on access to the rail network.

The National Planning Policy Framework states that councils should, "work with...transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development...or transport investment necessary to support strategies for the growth of ...other major generators of travel demand in their areas." Also, "encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Local Plan, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport."

The likely impact and level of improvements required will be specific to each station and each development meaning standard charges and formulae may not be appropriate. Therefore in order to fully assess the potential impacts, and the level of developer contribution required, it is essential that where a Transport Assessment is submitted in support of a planning application that this quantifies in detail the likely impacts on the rail network.

To ensure that developer contributions can deliver appropriate improvements to the rail network we would recommend that the Warwick - Local Plan Consultation - Village Housing Options and Settlement Boundaries include provisions for rail. The policy should include the following:

A requirement for developer contributions to deliver improvements to the rail network, including any development that occurs as a consequence of the Warwick - Local Plan Consultation - Village Housing Options and Settlement Boundaries.
* A requirement for Transport Assessments to take cognisance of impacts to existing rail infrastructure to allow any necessary developer contributions towards rail to be calculated.
* A commitment to consult Network Rail where development may impact on the rail network and may require rail infrastructure improvements. In order to be reasonable these improvements would be restricted to a local level and would be necessary to make the development acceptable. We would not seek contributions towards major enhancement projects which are already programmed as part of Network Rail's remit.

Improvements to rail transport contribute to the public good and railway developments should not be expected to support other public projects. Our infrastructure projects and station developments and improvements support regeneration, increase the attractiveness of settlements and benefit communities.

The plan at the moment appears to place unrealistic emphasis on sites which are close to the railway line with resultant likelihood of only attracting particularly low cost housing with questionable potential uptake. This raises questions re WDC support for local parishes and local industry as well as recognizing the reality of the closeness of Warwick Parkway links to London and the housing needs which that link alone creates.

There is however a need to consider that current Shrewley or indeed Rowington residents with either large or difficult to maintain homes (perhaps older properties or homes with large gardens) do not necessarily wish to move to small two bedroom homes or to new village developments.

Shrewley parish like Rowington parish is quietly dying due to a lack of new middle age residents because of the lack of suitable new housing. Parish council, village hall and various clubs are all losing and failing to generate new members with membership profiles becoming generally older. This is despite the desirability of the area to potential buyers seeking homes in the area.

WDC need to fully consider the actual needs of the parish rather than simply fulfilling numbers of new homes with disregard to residents objections and needs.

Meanwhile management and employees of high growth companies such as Jaguar Land Rover fail to find suitable homes in the very same area.

Shrewley and Rowington parishes are quite centrally located re the various sites of some of these companies including JLR and its suppliers (main sites at Gaydon, Solihull, Coventry and Birmingham). Key management drawn from all parts of Europe are not seeking starter homes.

In many instances such employees are forced to live at places such as Rugby, Northamptonshire, Oxforshire, Worcestershire and even Wiltshire.

The only key planned preferred sites within the current local plan are unlikely to meet the needs of many current residents or indeed provide housing opportunity for potential younger middle age / middle class families.
Without such stimulus communities such as Shrewley will continue to die re lack of younger, vibrant participants in village activities who often come from management style roles.

The current proposal has failed to take heed of opportunities re sites which were suggested (at Pinley) which would modestly help this current imbalance. There is a need for greater distribution of housing to include smaller sites.
There are other and greater opportunities to create modest housing sites by very slight modification of parish boundaries.

A proposal was made re a site at Pinley (Grid reference Easting 04208335 / Northing 02664706).

This site has to date been regarded as being within Shrewley and has to date been subsequently dismissed due to not being fully adjacent to current development within Shrewley but with modification of perimeter of unused land at Coley Irons has the potential to create a mid range level of housing which local residents will confirm is much needed.


With very minor perimeter change this total rather than partial site could be fully accommodated within Shrewley parish.

Apart from having potential good access onto the main B road the nominated site is on the edge of a development which is within realistic walking distance of the local school, a nursery, doctors surgery two churches and the shops, pubs and post offices of two villages (Shrewley and Claverdon) as well as the Ardencote manor leisure facilities.

Hatton and Claverdon railway stations are both accessible by foot.
The site additionally provides quick and easy access to the village halls of four local villages ie Claverdon, Shrewley, Hatton and Lowsonford not to mention Rowington. A bus route passes the door and the local collection point for school buses re children is circa 100 yards away.

This site is discreet and virtually unseen from the roadway and surrounding area being shrouded by trees on all sides with a variety of further trees growing to the frontage to help provide additional screening. It is additionally not in a potential flood area unlike some of the proposals currently being focused upon by WDC which are drawing considerable public opposition.

The site in question has been used domestically for 15 years and is currently under appeal re Lawful Development Certificate.

SHREWLEY COMMON SETTLEMENT BOUNDARY
There has been little comment about the settlement boundary, probably because it follows the backs of residents' gardens closely and the PC accepts the proposal.
SHREWLEY COMMON - SITES 1 AND 2
The Parish Council (PC) has concerns about the number of dwellings proposed for each site which would make it difficult to maintain the linear development character of Shrewley Common. Cramming so many homes on to these small sites is not at all in keeping and could mean that two cul-de-sacs are proposed, which could create an inappropriate dumbbell effect at the end of the village.
The average age of the population of the village is currently high, with a large proportion of retired couples and elderly single people. The PC feels it would be an advantage if some of the new dwellings were priced in a bracket accessible by first time buyers, together with some retirement bungalows. The Village Stores, the Village Hall, and the Durham Ox public house would be pleased to see new people coming into the village to increase footfall.
During the past 20 years the volume of traffic through the village has increased significantly. Many of the residents complain about the traffic volume and speed, and that driving in and out of their entrances to the road is becoming increasingly hazardous. Residents near the Village Stores are particularly concerned as vehicles often either restrict their view of the road dangerously, or even block their drives completely. Public transport is virtually non-existent and access to private transport is vital. More homes in the village will of course increase the traffic and parking problems and the design of the developments will need to ensure that the on-street parking is not further aggravated.
There are several mature trees and evidence of badgers on the sites, both of which will need to be protected. Evidence of a Roman settlement on one of the sites will need an archaeological survey report before any development is commenced. Development plans will also need to ensure that access is maintained to the fields behind both sites.
HATTON STATION SETTLEMENT BOUNDARY
The PC proposes that the settlement boundary should NOT include the dwellings to the North of the canal, ie maintaining the status quo, with the whole area to the North being washed over by the Green Belt as there are no suitable sites for development.
To the south of the canal, the boundary should be drawn at the bottom of existing gardens, as indicated on the map. If any of the sites 1, 2 and 3 are not chosen for development, then the boundary for Site 1 should be at the bottom of existing gardens, and for Sites 2 and 3 at the curtilage boundary of 106 Station Road. If any of sites 1, 2 and 3 are developed, then it is expected that the boundary will be drawn at the bottom of the gardens of the new dwellings.
HATTON STATION SITE 1 - Land to the rear of Antrobus Close
The PC disagrees with WDCs recommendation that this is a preferred site, unless an up to date housing needs survey clearly shows there is a need for new housing in Shrewley Parish, (in contradiction to the recent Parish Plan survey) which cannot be satisfied by developing the two preferred sites in Shrewley Common.
Also the proposed number of new dwellings on this site is disproportionate to the overall size of the adjoining estate. 20 houses added to the existing 35 represents a 57% increase. The impact of such an increase on existing housing is NOT acceptable. However, we propose that IF new housing is required on this site, there should be an upper limit of 10 dwellings, which would represent an increase of up to 28%. The impact on existing dwellings would therefore be significantly reduced. We also strongly support the principle of protecting and enhancing the environmental diversity and civic amenity of this site. By reducing the number of dwellings to a maximum of 10, it would create an opportunity to enhance the natural environment and meet residents' concerns. We would expect that IF any development took place on this site, WDC would insist that there was adequate on-site parking, so that there would be no impact on existing dwellings.
We also acknowledge WDCs statement that "the sewerage and drainage systems of Hatton Station are at capacity and that any new scheme will have to manage its impact and avoid adding to local problems."
HATTON STATION SITE 2 - Land to the west of old Station Road
The PC disagrees with WDCs recommendation and proposes that the site loses its preferred status because the close proximity to the M40 means that "A comprehensive approach to alleviating motorway traffic noise" is not feasible and this is also a GREENFIELD site.
HATTON STATION SITE 3 - The Dell
The PC agrees with WDCs recommendation that this site should not be considered for development for both reasons given in WDCs site appraisal, on access and the impact on existing housing amenity. This is also a GREENFIELD site.
FINAL COMMENTS
The proposal for about 45 dwellings in Shrewley Parish on four preferred sites represents a 20-25% increase in dwellings in both settlements. A recent survey conducted for the Shrewley Parish Plan, which had a response rate of over 60%, showed that the majority of residents (55%) felt that no new housing could be accommodated within the Parish in the future. However, the Parish Council (PC) does not object to some development but believes that the proposed increase in the number of dwellings is unsustainable. The Shrewley Parish settlement scoring (Hatton Station 18 and Shrewley Common 33) indicates that both settlements have few local services for residents. The PC also considers that development on this scale would be detrimental to the character of both settlements and that the narrow lanes in the Parish, particularly Station Road in Hatton Station, will have difficulty coping with the increased traffic.
The PC is also concerned over the phasing of any new developments. The Local Plan needs to provide capacity to increase housing supply incrementally over the next 15 years. However, developers are likely to want to build much more quickly. The PC strongly opposes any plan which would mean mass building of new homes in the early years, leaving no capacity to increase in the future. The PC proposes that the Shrewley Common sites are developed first to satisfy any local housing needs which are supported through an up-to-date housing needs survey. WDC must ensure that the requirements of Section 4.4.6 of the Revised Development Strategy June 2013 as restated below are met in full and require developers to agree to phased development to cover the whole period through to 2029:
"... The scale of development will need to be carefully managed and it is the Council's intention to introduce capped proportional growth rates for the smaller settlements, subject to further consultation with parish councils and in light of ongoing work on green belt, ecology and landscape considerations. Locally agreed growth rates will allow parish councils to support development which is of a proportional scale to their settlements and help places maintain their distinctiveness and character."
The PC re-emphasises the importance of WDC ensuring that the requirements of Section 4.4.7 below are met before any detailed planning proposals are determined.
"... limited infill housing development of an appropriate proportional scale will only be acceptable where it can be demonstrated that:
* it is supported by the parish council and/or neighbourhood plan;
* a registered social landlord is supportive of the development;
* it is supported through an up-to-date housing needs survey covering local affordable and market need;
* it is located within a defined village or settlement envelope;
* it would deliver clear improvements to local services and facilities."
Finally, following agreement on the new settlement boundaries, there must be assurances that there can be no further boundary changes for the duration of the Local Plan, so preventing creeping expansion and further development in the Green Belt between now and 2029.