Transport

Object

Representation ID: 65685

Received: 27/06/2014

Respondent: Sir John Egan

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I object to the plan in the strongest terms. As you acknowledge there will be a great deal more traffic being generated in the town of Warwick. Your mitigation measures are there to facilitate the increased traffic ,in the meantime the quality of life in Central Warwick will deteriorate. Where is your plan to improve pollution ? Where is your plan to calm traffic down and make life easier fir pedestrians ?

Support

Representation ID: 65870

Received: 24/06/2014

Respondent: Highways England

The Highways Agency broadly supports the strategic transport objectives set out at Para 5.31 of the Publication Draft Local Plan, particularly the need to carry out improvements to major congestion hotspots and to fostering a more sustainable transport pattern.

Object

Representation ID: 65889

Received: 23/06/2014

Respondent: Mr Dennis Michael Crips

Legally compliant? No

Sound? No

Duty to co-operate? No

The STA has not been undertaken in accordance with a clear specification and has not be coherently managed. It is therefore unsuitable as evidence. It has resulted in proposals which could make traffic conditions worse.

Previous work to achieve goals of the LTP and improvement for Warwick Town Centre has not been taken in to account. There is inconsistency in approach with approaches to both reduce and increase traffic volumes being pursued. Options to increase traffic volumes give no consideration to pedestrians and residents. The transport proposals are not therefore credible.

The local authorities have failed to cooperate and WCC has failed to exercise it obligation as the highway authority to provide independent advice. There has not been enough objective analysis. The Plan therefore fails the requirements of legality and cooperation.

Previous local plans right through to the LPT (2011) seek to reduce traffic flows in Warwick. However these proposals seek to increase traffic flow. This will impact on air quality and the historic environment (especially Avon Bridge). This is contrary to local and national policy.

The SA acknowledges air quality as a problem but expects the problem to have disappeared by 2029. This does not deal with the urgent problems faced now. The plan is not therefore sustainable.

Object

Representation ID: 66070

Received: 27/06/2014

Respondent: Historic England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Although we support this policy, it is not clear that the implications for the historic environment arising from major development to the south of Warwick have been fully addressed in accordance to such a commitment.

Object

Representation ID: 66176

Received: 25/06/2014

Respondent: CWLEP Planning Business Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Rail links - Warwick Parkway/Leamington stations should be identified and the implications should be considered. There could be opportunities to encourage sustainable interchange facilities and at Leamington there could be issues associated with the gyratory at Old Warwick Rd/Bath St/Spencer St/Lower Avenue

Support

Representation ID: 66544

Received: 27/06/2014

Respondent: Friends of the Earth

Number of people: 4

Proposed Policies TR1 - TR6 (Transport)
We support these proposals. However we do have some comments:
We support the proposals in the Sustainable Transport Technical Note (Appendix D of the Strategic Transport Assessment Stage 4), particularly the mention of the proposed Kenilworth to Leamington cycle route (K2L), though we do not agree that 'the cycle network within the Warwick and Leamington area is reasonably well developed' - we believe that it could be considerably improved. There should be the aim to provide exemplary cycle and walking routes within and near to all new developments in order to maximise cycling and walking in those areas. Links to all town centres and railway stations are particularly important.

Object

Representation ID: 66675

Received: 28/06/2014

Respondent: Sworders

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

TR1-5; these policies all add additional burdens and requirements which are not contained in the NPPF. These are in conflict with the NPPF presumption in favour of sustainable development at paragraph 14 and Chapter 1, Building a strong, competitive economy and Chapter 4 promoting sustainable transport.

Object

Representation ID: 66681

Received: 27/06/2014

Respondent: Save Warwick

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66843

Received: 03/07/2014

Respondent: Patricia Hollis

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66902

Received: 03/07/2014

Respondent: Colin Sharp

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66910

Received: 03/07/2014

Respondent: Ms Alison Cox

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66918

Received: 03/07/2014

Respondent: Alison Kelly

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66926

Received: 03/07/2014

Respondent: Andrew Cliffe

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66934

Received: 03/07/2014

Respondent: Angelo Cugini

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66942

Received: 03/07/2014

Respondent: Barbara Groves

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66950

Received: 03/07/2014

Respondent: Professor Bob Ireland

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66958

Received: 03/07/2014

Respondent: Christopher Paden

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66966

Received: 03/07/2014

Respondent: Elizabeth Cliffe

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66974

Received: 03/07/2014

Respondent: Mrs Kay Cugini

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66982

Received: 03/07/2014

Respondent: Mr David Ramsbottom

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66990

Received: 03/07/2014

Respondent: Mr David Drinkhall

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 66998

Received: 03/07/2014

Respondent: Ian Frost

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67006

Received: 03/07/2014

Respondent: Mr Geoff Reynolds

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67014

Received: 03/07/2014

Respondent: John Griffiths

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67022

Received: 03/07/2014

Respondent: Justin Richards

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67030

Received: 03/07/2014

Respondent: Louise Kalus

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67038

Received: 03/07/2014

Respondent: Paul Kalus

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67046

Received: 03/07/2014

Respondent: Mr Bernard Hollis

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67054

Received: 03/07/2014

Respondent: Mr R Komarasinha

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).

Object

Representation ID: 67062

Received: 03/07/2014

Respondent: Caroline Komarasinha

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The transport strategy is ineffective and unsustainable. There is evidence to show that the transport assessment (important evidence for the Plan) is flawed. There are major issues in respect of accommodating traffic through Warwick generated from new estates south of the river.
Adverse impacts on air quality and health have not been satisfactorily assessed or tackled. Background evidence for the Plan is considered to gloss over the importance of Air Quality Monitoring Areas of Warwick, Leamington and Kenilworth where illegal levels of nitrogen oxide generated from traffic are prevalent. The Plans evidence claims that the problem will be overcome in the future by cleaner motor vehicles. This is disputed by a number of scientists and considered a risk.
The Plan is also considered unsound for the following reasons:-
1)The traffic consequences of the proposals in the Plan would be disastrous for Warwick and the statistics used to predict the impacts of traffic have been manipulated so as to ensure they can fit the plan.
2)In reality measures proposed do not deal with the anticipated transport impacts of the development and the intended development areas are not in the right place (are unsustainable)
3)The traffic consequences of the Gaydon development in Stratford District have been underestimated.
4)Development areas have not been located where the need to travel has been minimised. The impact of traffic generated by transport movements related to the development proposals has been ignored

*The representation sets out and highlights a series of what are considered key references from the NPPF regarding traffic and transport related matters and associated infrastructure requirements, these can be viewed in the full submission.
*The Save Warwick Group, together with the Town Council, The Warwick Society and Bishops Tachbrook Parish Council were concerned that the approach to transport adopted in the Local Plan was seriously flawed. They jointly commissioned Royal Haskoning DHV, the UK branch of the independent international engineering and project management consultancy with special expertise in Transport Planning, to undertake a peer review of the Strategic Transport Assessment 4. This can be seen in full at www.savewarwick.co.uk.
The report confirms the concerns of the campaign groups and provides detailed evidence to provide the background for the matters raised in this submission below.
*Wrong Strategic Decisions
The fundamental flaw leading to many of the transport issues is the decision to locate most of the major new development areas south of the River Avon. This strategy will not satisfy the needs of the NPPF "to ensure that development that generate significant traffic movements are located where the need to travel will be minimized and the use of sustainable transport modes can be maximised". The plan does not satisfy the "need to focus significant developments in locations which are or can be made sustainable".
The peer review states the following
-The £34 million worth of mitigation proposed will be insufficient to address all the transport impacts
-The methodology used for the TA (Traffic Assessment) for the local plan has a series of shortcomings and is considered unsound.
-The will be left by a legacy of congestion which will damage health , heritage assets and have negative economic impacts on Warwick.

*Shortcomings of the STA4 Traffic Assessment
-It is incomplete / unfinished
-Despite 27 proposed Improvements for traffic mitigation the traffic modelling has shown network failure and increased congestion in key areas, particularly in Warwick. There is concern that leaving decisions regarding town centres to separate strategies is inappropriate/ ineffective.
-The interpretation of the data does not give the full picture; traffic growth has been' capped'/ reduced so as to make traffic 'predictions' fit the series of indicative proposals.
Education trips have been excluded, trip discounting assumes 22.5% of trips will be subject to mode shift, peak spreading assumptions have been made assuming that people and institutions will change their working hours and travel times
-The report admits that the current indicative schemes will not solve the problems and goes on to say that "without a full, and potentially increased schedule of highway improvement schemes" the development allocations as proposed cannot be accommodated under the proposals in the current assessments.
-The assessment includes simplistic 'inception design solutions' for the mitigation but has not gone into detailed proposals - without sufficient detail how can the proposals be trusted to deliver what is necessary?
-The traffic assessment report is also considered unacceptable because it concludes that the proposed transport strategy will only mitigate 'in part' the potential impacts and that 'some residual impacts will still occur'.It is considered that further work is required to refine and assess the details of the mitigation schemes and that the order of delivery/ prioritisation of particular elements are agreed.
-The Traffic Assessment acknowledges that in spite of the application of the proposed mitigation measures not all of the impacts are fully mitigated. In the opinion of the campaign groups it is believed that this is unacceptable and that the current plan strategy is therefore flawed/ cannot be accommodated.
-The STA4 report recognises that sustainable transport options will have to be provided / improved to reduce traffic impacts and that work is on-going with regard to this matter. There is no evidence to support that sustainable transport measures will significantly reduce car trips (borne out by DFT research), therefore the methods/ assumptions employed by the traffic assessment are questioned/ argued not to be sufficiently robust.
-The modelling used in the assessment is unreliable / subject to problems issues of reliability. The ability of the network to cope with 2028 traffic is questioned.

*The Cumulative Impact Assessment which looks at combined Warwick and Stratford District traffic issues/ cumulative impacts has been completed too late in the process to effectively influence the proposed development patterns for Warwick District.
-The Lighthorne/ Gaydon proposals are seen as having a significant effect on South Warwick as it is the area through which many of the residents will travel to work.
-The CIA does not include information and analysis of the proposed schemes in detail, nor does it comprehensively identify the full scope of impacts and benefits that occur as a result of the allocation strategies. It merely identifies what strategic elements of infrastructure are likely to be required to ensure the growth can be accommodated upon the existing network.
-The deliveries of capacity enhancements to the M40 corridor are essential to ensure local networks are not overloaded. The plans and their allocative strategies are prejudiced if this does not happen.
-It is suggested that the methodology for undertaking the modelling exercise has required a 'capping procedure' that produces model instability and concern over the outputs presented as a consequence.
-Journey times and congestion times are predicted to increase despite mitigation, this will have adverse effects on air quality
-There is little or no evidence / regard given to the effects of the damage the proposals will do to the historic fabric and heritage assets of Warwick town centre.
-There is little or no evidence on the impacts of the traffic proposals on health, air quality in Warwick town centre will deteriorate even more which will be damaging to health and the environment.
The representation also attaches detailed supplementary information on traffic congestion statistics and air quality matters (see appendix 2 and 3 of the full submission).