AC Lloyd Homes object to the omission of a Proposed Amendment at paragraph 2 of the document. It is considered that this is an appropriate opportunity to amend the Plan period of 2011- 2029. It is considered that the plan period should be extended from 2029 to 2031. The current approach is considered 'unsound' as it does not conform with the provisions of NPPF which requires Plans to cover an appropriate time period, preferably a 15 year time horizon from adoption. Since the plan is unlikely to be adopted before summer 2015 at the earliest, this period appears too short. Extending the period to 2031 would ensure a 15 year period is provided for and also bring the plan into line with the housing evidence base i.e. the Joint Coventry and Warwickshire SHMA that has been used to consider housing allocations. This document makes provision for housing between 2011 and 2031.

Stratford on Avon District Council, a neighbouring Authority which has recently submitted its Proposed Submission Core Strategy, has extended its plan period to 2031 in recognition of this position and has noted that its plan could run the risk of being found 'unsound' at examination unless a period to 2031 was provided for. They are slightly ahead of Warwick in the plan process and consider that a time frame to 2031 is appropriate. Stratford altered the time period through a focused consultation process, so this is a recognized way of making an amendment of this nature through this process.

Deeley Group Ltd object to the omission of a Proposed Amendment at paragraph 2 of the document. It is considered that this is an appropriate opportunity to amend the Plan period of 2011- 2029. It is considered that the plan period should be extended from 2029 to 2031. The current approach is considered 'unsound' as it does not conform with the provisions of NPPF which requires Plans to cover an appropriate time period, preferably a 15 year time horizon from adoption. Since the plan is unlikely to be adopted before summer 2015 at the earliest, this period appears too short. Extending the period to 2031 would ensure a 15 year period is provided for and also bring the plan into line with the housing evidence base i.e. the Joint Coventry and Warwickshire SHMA that has been used to consider housing allocations. This document makes provision for housing between 2011 and 2031.

Stratford on Avon District Council, a neighbouring Authority which has recently submitted its Proposed Submission Core Strategy, has extended its plan period to 2031 in recognition of this position and has noted that its plan could run the risk of being found 'unsound' at examination unless a period to 2031 was provided for. They are slightly ahead of Warwick in the plan process and consider that a time frame to 2031 is appropriate. Stratford altered the time period through a focused consultation process, so this is a recognized way of making an amendment of this nature through this process.

see attached

I refer to both of the above consultations.

The County Council has responsibility for services across the whole of the County including: highways and transportation; schools provision; public health; waste management; community safety, libraries, support for elderly and vulnerable people and as the statutory planning authority for Minerals and Waste. In addition to these responsibilities the County Council is a principal partner of the Coventry and Warwickshire Local Enterprise Partnership and has statutory a duty to cooperate on County Council matters in working with all partners in the sub-region.

Comments in response to the "Focused changes" consultation

Strategic Highways impacts assessment update
The County Council is undertaking further assessment work for impacts to test the impacts of the focused changes, and what transport mitigation is required as a result. We intend to submit this information to the District Council later this month as a final iteration of the Strategic Transport Assessment.

Highways and Transportation matters

The County Council has worked in partnership with the District Council to identify the transport impacts and mitigation requirements relating to the WDC Local Plan. A series of Strategic Transport Assessments (STA) have been undertaken, STA4 represents the latest full assessment of the Preferred Options; further addendum work has been completed to identify impacts pertaining to the focused changes to the Draft Local Plan, and the implications these have for transport mitigation and the Infrastructure Delivery Plan.



The STA work has identified broad areas which require mitigation schemes, as identified in the attached image (n.b. some isolated schemes will fall outside these broad areas). The attached image contains a plan identifying the Strategic Transport broad locations and a revised schedule for the associated infrastructure.

The schemes identified through this process have been developed to a stage appropriate to the level of strategic modelling assessment and mitigate the impacts of Local Plan transport demands to a level deemed to be acceptable. A complete, current list of mitigation requirements identified in STA4/STA4 addendum is attached. This forms the latest position in terms of highway mitigation requirements to inform the Infrastructure Delivery Plan.

It should be acknowledged that the schemes proposed within the STA modelling have not been subject to any detailed design, costing or safety review at this stage. Furthermore, it should not be assumed that the schemes recommended through the studies are fixed and will be delivered in the form described within the reports. Rather it is intended that the schemes proposed are outline schemes which may change through further optimisation and detailed design that will precede their delivery. Scheme development will be informed through both the planning process for individual sites and through scheme development undertaken by the County Council. This position is documented with the STAs and acknowledged by the District Council.

Deliverability

The County Council seeks assurance that the cumulative impacts of Warwick District and Stratford on Avon District growth requirements are properly accommodated in both local plans. It is essential that a joint robust mechanism is considered to implement these cross border issues. One solution would be that joint and common infrastructure requirements are reflected in the respective Infrastructure Delivery Plans without "double dipping". Nevertheless, this is a matter for both Planning Authorities to agree a mechanism for implementation of its policy mechanism.

Comments on the proposed policy changes

It is for the District Council to determine and explain the sustainable deliverability of the Local Plan and in particular in relation to the changes for the proposed Europa Way sites. For clarification I refer to proposed changes to:
Para DS9; DS11; D14; and Policies Map: 2 Leamington, Warwick and Whitnash - amend remove employment allocation E1 at Land North of Gallows Hill.

Additional comments on Public health matters

We suggest that when the District Council commence its Development Management Documents', consideration be given for limiting new planning permissions in areas where there is already high concentration of hot-food takeaways and licensed premises.

Gypsies and Travellers Preferred Options Consultation Land at Stratford Road, Warwick

We support the District Council's proposal to allocate sustainable and affordable sites to meet the permanent residential needs of this District's Gypsy and Traveller Community and Travelling Show People through the Local Plan process. The current consultation sets out an alternative site option that is potentially suitable to take forward as an allocation in a Development Plan Document.

The County Council supports the District Councils' commissioned evidence through the Gypsy and Traveller Accommodation Assessment (GTAA) for Warwick District, undertaken by Salford University. The report was published in November 2012 and demonstrates a need for 31 permanent pitches to be provided over a 15 year period, 25 within the first five years and in addition, 6-8 transit pitches over the full 15 years.

The District Council has identified land off Stratford Road at Warwick, which currently lies within a 'cordon sanitaire' around the Sewage Treatment Works. Our records indicate that the site is outside the cordon sanitaire and therefore could be suitable. We suggest that further discussions should take place with the Environment Agency and Severn Trent to identify the extent and limitations of the cordon sanitaire.

Other matters we wish to comment on

Schools
The County Council has a statutory duty to ensure sufficient school places and this includes Academies within its planning. We seek assurance and certainty regarding the deliverability of supporting school infrastructure to meet the growth of the Local Plan and in particular that these matters are prioritised in the R123 list.

Delivering the Local Plan
The CIL Guidance published by the Government in June 2014 states that a Charging Authority, should be able to explain how their proposed rates will contribute towards the implementation of the relevant plan, and support development across their area.

Consequently, we welcome discussions regarding the delivery of the Local Plan and governance arrangements for passing on CIL monies to the County Council to enable us to deliver identified infrastructure in a timely manner.

We would be happy to discuss our comments with you. Please contact Mark Ryder on 01926 412811 should you wish to discuss any aspect.

see attached

I refer to both of the above consultations.

The County Council has responsibility for services across the whole of the County including: highways and transportation; schools provision; public health; waste management; community safety, libraries, support for elderly and vulnerable people and as the statutory planning authority for Minerals and Waste. In addition to these responsibilities the County Council is a principal partner of the Coventry and Warwickshire Local Enterprise Partnership and has statutory a duty to cooperate on County Council matters in working with all partners in the sub-region.

Comments in response to the "Focused changes" consultation

Strategic Highways impacts assessment update
The County Council is undertaking further assessment work for impacts to test the impacts of the focused changes, and what transport mitigation is required as a result. We intend to submit this information to the District Council later this month as a final iteration of the Strategic Transport Assessment.

Highways and Transportation matters

The County Council has worked in partnership with the District Council to identify the transport impacts and mitigation requirements relating to the WDC Local Plan. A series of Strategic Transport Assessments (STA) have been undertaken, STA4 represents the latest full assessment of the Preferred Options; further addendum work has been completed to identify impacts pertaining to the focused changes to the Draft Local Plan, and the implications these have for transport mitigation and the Infrastructure Delivery Plan.



The STA work has identified broad areas which require mitigation schemes, as identified in the attached image (n.b. some isolated schemes will fall outside these broad areas). The attached image contains a plan identifying the Strategic Transport broad locations and a revised schedule for the associated infrastructure.

The schemes identified through this process have been developed to a stage appropriate to the level of strategic modelling assessment and mitigate the impacts of Local Plan transport demands to a level deemed to be acceptable. A complete, current list of mitigation requirements identified in STA4/STA4 addendum is attached. This forms the latest position in terms of highway mitigation requirements to inform the Infrastructure Delivery Plan.

It should be acknowledged that the schemes proposed within the STA modelling have not been subject to any detailed design, costing or safety review at this stage. Furthermore, it should not be assumed that the schemes recommended through the studies are fixed and will be delivered in the form described within the reports. Rather it is intended that the schemes proposed are outline schemes which may change through further optimisation and detailed design that will precede their delivery. Scheme development will be informed through both the planning process for individual sites and through scheme development undertaken by the County Council. This position is documented with the STAs and acknowledged by the District Council.

Deliverability

The County Council seeks assurance that the cumulative impacts of Warwick District and Stratford on Avon District growth requirements are properly accommodated in both local plans. It is essential that a joint robust mechanism is considered to implement these cross border issues. One solution would be that joint and common infrastructure requirements are reflected in the respective Infrastructure Delivery Plans without "double dipping". Nevertheless, this is a matter for both Planning Authorities to agree a mechanism for implementation of its policy mechanism.

Comments on the proposed policy changes

It is for the District Council to determine and explain the sustainable deliverability of the Local Plan and in particular in relation to the changes for the proposed Europa Way sites. For clarification I refer to proposed changes to:
Para DS9; DS11; D14; and Policies Map: 2 Leamington, Warwick and Whitnash - amend remove employment allocation E1 at Land North of Gallows Hill.

Additional comments on Public health matters

We suggest that when the District Council commence its Development Management Documents', consideration be given for limiting new planning permissions in areas where there is already high concentration of hot-food takeaways and licensed premises.

Gypsies and Travellers Preferred Options Consultation Land at Stratford Road, Warwick

We support the District Council's proposal to allocate sustainable and affordable sites to meet the permanent residential needs of this District's Gypsy and Traveller Community and Travelling Show People through the Local Plan process. The current consultation sets out an alternative site option that is potentially suitable to take forward as an allocation in a Development Plan Document.

The County Council supports the District Councils' commissioned evidence through the Gypsy and Traveller Accommodation Assessment (GTAA) for Warwick District, undertaken by Salford University. The report was published in November 2012 and demonstrates a need for 31 permanent pitches to be provided over a 15 year period, 25 within the first five years and in addition, 6-8 transit pitches over the full 15 years.

The District Council has identified land off Stratford Road at Warwick, which currently lies within a 'cordon sanitaire' around the Sewage Treatment Works. Our records indicate that the site is outside the cordon sanitaire and therefore could be suitable. We suggest that further discussions should take place with the Environment Agency and Severn Trent to identify the extent and limitations of the cordon sanitaire.

Other matters we wish to comment on

Schools
The County Council has a statutory duty to ensure sufficient school places and this includes Academies within its planning. We seek assurance and certainty regarding the deliverability of supporting school infrastructure to meet the growth of the Local Plan and in particular that these matters are prioritised in the R123 list.

Delivering the Local Plan
The CIL Guidance published by the Government in June 2014 states that a Charging Authority, should be able to explain how their proposed rates will contribute towards the implementation of the relevant plan, and support development across their area.

Consequently, we welcome discussions regarding the delivery of the Local Plan and governance arrangements for passing on CIL monies to the County Council to enable us to deliver identified infrastructure in a timely manner.

We would be happy to discuss our comments with you. Please contact Mark Ryder on 01926 412811 should you wish to discuss any aspect.