Para 2.1 - COMMENT
The Sustainable Community Strategy (SCS) should clearly inform the spatial vision and objectives in the Local Plan, leading to policies that embrace elements wider than traditional land-use planning and which focus on the distinctive characteristics and challenges of different parts of the District. However, we believe that the vision should not simply repeat the SCS vision, without at least articulating the spatial elements of that strategy.

We consider that the vision in the Local Plan should be spatial and locally distinctive, and, without being over-long, should provide more detail including references as to how important issues will be addressed and how towns, villages and communities will under go positive change over the course of the plan period, and how in particular well planned extensions to the main urban areas will help meet the District future development needs.

The strategic allocation of land west of Europa Way ('Myton Garden Suburb') is supported and we consider development at this location has a central role to play in delivering the (spatial) vision.


Para 2.5 - COMMENT
Broadly support the key principles for development of the Local Plan. However, to ensure that the principles are consistent with policies in the plan we believe that the proposed key (Environment) principle of "Distributing development across the District" should be replaced with the following text:

"Concentrating most new development within and/or on the edge of the main urban centres, with some also directed towards named sustainable village locations".

This change would bring the principle in line with Policy PO3: Broad Location of Growth which state's that the Council's preferred option is to "concentrate growth within...".

While we acknowledge the importance of seeking to maintain the identity of existing communities through "avoiding coalescence", we consider that this principle should be qualified so that it relates to coalescence between the urban area and nearby settlements. We also consider that avoiding coalescence should not be at the expense of other policy objectives in the plan and ultimately in delivering the most sustainable development strategy for the District as a whole.

In recognition of the opportunity for new development to provide an off-site financial contribution to help improve existing local community infrastructure ('Emphasis on Infrastructure') it is suggested that with regards education the key principle should be re-worded to read:

"ensuring new or improved education facilities are provided to meet the needs generated by major new developments"


As the spatial strategy should respond to the local context, current and anticipated issues over the course of the plan period, we consider that the spatial portrait and issues section should come before the vision. To support and achieve the Local Plan vision, the Council can then set the objectives that have been developed.

COMMENT
As the spatial strategy should respond to the local context, current and anticipated issues over the course of the plan period, we consider that the spatial portrait and issues section should come before the vision. To support and achieve the Local Plan vision, the Council can then set the objectives that have been developed.

COMMENT

The 'Population and Spatial Portrait' section of the plan provides a useful summary of some of the key social characteristics of the District. However, we believe that both a fuller description of these characteristics would be beneficial together with information presented on other characteristics of the area which are necessary and relevant to the plan. For example, an explanation of the settlement hierarchy, a broader overview of key demographic data and trends, a description of physical features that influence development in the area, access to services and facilities and transport links.

We are unsure why there is a focus on population in the sub-heading to this section of the report. The Council may wish to amend the sub-heading to better reflect the wider topics covered here, topics which should be equally important in describing the characteristics of the District.

COMMENT

The list at para 4.8 provides a useful summary of many of the issues facing the District. However, this section of the Local Plan would benefit from a description of the implications of the changing population structure and the latest household projections as the two issues clearly have a significant bearing upon the direction of the emerging Plan.

We also believe that the Council should consider restructuring this section of the plan so that it sets out, in addition to issues, the problems and challenges facing the District, together with identified opportunities. Regarding the latter, the Council identifies 'opportunities' at para 4.8 as something which the local plan should also address but currently provides no information on what these opportunities are.

COMMENT

Generally support the Objectives presented in the Local Plan, and in particular Objectives 2 and 4. Objective 2 seeks to provide for a sustainable level of housing growth within the District by, amongst other things, identifying and maintaining a flexible supply of land for housing. With regard to Objective 4, recognition is given to the importance of making sure that new developments are in places that will reduce the need for people to use their cars.

The Europa Way Consortium and Warwickshire County Council (Physical Assets-Resources) are jointly promoting the development of land west of Europa Way and north of Gallows Hill as one of the strategic site allocations in the new Local Plan, and consider that development at this location will contribute significantly to achieving both Objective 2 and 4. Our clients' site i.e. the proposed 'Myton Garden Suburb', is uniquely placed to offer the most sustainable location for accommodating a significant share of the District's development needs up to 2029. Not only is land at this location within easy walking distance of existing schools, shops, and employment opportunities but also lies adjacent cycle paths, bus-based public transport corridors and is within easy access of both Leamington and Warwick railway stations, and town centres. In the Council's own Initial Sustainability Appraisal of the Local Plan Preferred Options (May 2012), the site obtained the highest sustainability ranking of all potential greenfield development sites.

We specifically support the Objective 11 which seeks to enable organisations that provide community infrastructure, such as schools, to provide and maintain improved facilities and services in locations where people can get to and they meet people's current and future needs. For example, we have been investigating opportunities to help deliver improvements to Myton School, which is located adjacent to our clients' site; improvements which would be of benefit to existing and future students of the school, as well as to the wider community of Myton /Myton Garden Suburb development.

SUPPORT WITH RECOMMENDED AMENDMENTS TO PO1

Having regard to existing and forecast housing need, plus the latest identified capacity of potentially suitable, available and achievable housing sites within the District over the period to 2029 (as presented in the SHLAA, May 2012), we consider that the Preferred Level of Growth under Policy PO1 should be a MINIMUM delivery requirement, net of demolitions, and not an absolute target i.e. a housing requirement that may be exceeded where justified by evidence of need, demand, affordability and sustainability considerations.

The proposed Plan Period, 2011 to 2029, is supported and is considered consistent with advice in the NPPF which calls on local authorities to draw up their Local Plans over an appropriate time scale, preferably a 15-year time horizon, and to take account of longer term requirements.

CORRECTION to information in para 5.18
The Preferred Options consultation document incorrectly states that 11,410 potentially suitable housing sites have been identified by the Council in the latest SHLAA (May 2012). The correct figure is, in fact, 13,385 dwellings (refer SHLAA, page 11, Table 2).

COMMENT
The proposal to utilise a Community Infrastructure Levy (CIL) in the future to fund new infrastructure considered necessary for the delivery of planned growth in the District is supported in principle, although we reserve the right to comment on this once further details of the proposed charging rates, supported by an appropriate evidence base, are available for public consultation.

SUPPORT - but recommended re-wording of the policy.


The Europa Way Consortium and Warwickshire County Council (Physical Assets-Resources) support the District Council's decision to concentrate growth within, and on the edge of, the existing urban areas. However, in order to avoid any unnecessary confusion surrounding the spatial strategy we believe Policy PO3 (Broad Location of Growth) would benefit from some re-wording. Re-wording is considered necessary for the Council's 'Preferred Option' cannot be to both "concentrate growth" in one area and, at the same time, "distribute growth across the District"; that is unless at least one of these two statements is qualified.
We recommend that Policy PO3 is re-worded and re-ordered to read:
It is the Council's Preferred Option to:
* concentrate growth within, and on the edge of, existing urban areas
* allow for some limited growth across the rural area of the District, based on a hierarchy to include:
- a higher level of growth within and/or on the edge of named Category 1 and 2 villages i.e. those villages with a broad range of services and public transport to the town; and
- a lower level of growth in on brownfield land within named Category 3 villages in order to meet local need and help support existing services
* avoid development in locations which could potentially lead to the coalescence of the urban area with nearby settlements.

In response to consultation on different spatial options during preparation of the Core Strategy (no equivalent undertaken as part of the new Local Plan) respondents favoured concentrating development within and/or on the edge of the main urban areas within the District. A spatial strategy based on urban concentration also performed best under the sustainable appraisal. For this reason we consider that references to a decision that the Local Plan should "distribute development across the District" (para 7.13) should be suitably qualified.

We broadly support the stated justification for Policy PO3, but consider that the Council should also recognise the importance of making best use of existing infrastructure (including social and community infrastructure) and taking this into consideration as a basis/ rational for choosing the most suitable and sustainable development locations, and to also in determining how development sites are phased over the plan period.

Being well integrated 'within' the existing urban area of Warwick and Leamington Spa, proposed development on land west of Europa Way ('Myton Garden Suburb') can take advantage of existing infrastructure including highway, bicycle and pedestrian infrastructure, existing local secondary school and utility services. New infrastructure will clearly be needed to help deliver the full scale of development proposed in this location, however, the presence of existing infrastructure means that development can be brought forward and delivered more quickly and, in line with principles set out in NPPF, is inherently more sustainable.