Object

Village Housing Options and Settlement Boundaries

Representation ID: 61020

Received: 18/01/2014

Respondent: Ann Jennings

Representation Summary:

I object to the proposed Radford Semele village Plan as I consider it wholly inappropriate in terms of the huge and unacceptable traffic impact that such a development will have on an already highly congested section of road. Furthermore I believe that the chosen option for consultation was incorrectly assessed compared to other discounted option sites. The proposal does not equitably share the Local Plan impact across the village through Social responsibility and Sustainable Development principles and also our Parish Councillors were not consulted about this particular site, raising significant issues about the democratic and legal process.

Full text:

Detailed objections by WDC Criteria Factors

* Scale of Development: Radford housing needs & Numbers proposed
- The WDC sustainability assessment has not been scored adequately and shows Radford to have a 65% higher '-' negative scoring than '+' positive, based on the 16 NPPF criteria categories which should have down-graded the village from the Local plan or reduced the housing allocation based on Gov Sustainable Development principles.
- Decisions based upon WDC's simplified subjective assessment summaries have not used quantative data or any comparison matrix of all the sites to make a valid choice.

* Needs & Wants of local urban residents.
- WDC has chosen its proposed site purely on the 'Needs' of WDC to meet its Local plan 'Wants', combined with the Developers 'Wants' to use the simplest site. This does not protect the 'Needs' of village residents or give importance to our viewpoint through its social responsibility as required by Government Sustainable Development principles.
- No account has yet been taken of the importance weighting of the impact to residents.
- WDC assessments are based on a higher importance weighting for flow of through Traffic and relative Landscape impact for the rural view seen from cars travelling East to & from the Fosse, rather than any importance of the residents viewpoint on these factors, when making a decision on the proposed option.

* Landscape Impact, Greenfield function
- WDC has chosen proposed site 1 as having lesser visual impact than each of 3 other village sites based on a subjective assessment in the SHLAA, not any quantifiable data. However, taking the number of surrounding dwellings as a measure of existing residents visual impact, the picture is very different:
Site 1 has the highest visual impact with 32 houses in direct view and 15 in partial view of the site, Total 47.
Site 2 has 16 houses in direct view and 10 in partial view, Total 26.
Site 3 has 5 houses in direct view and 1 partial view, Total 6
Site 4 has 32 houses in direct and 2 in partial view, Total 34.
Therefore site 1 has an 87% higher visual impact than site 3, a 64% higher impact than site 2 and a 58% higher impact than site 4. Site 1 cannot be justified as the best site.

* Traffic Impact, site access
- WDC has rated its traffic assessment of site 1 as being of lower impact than sites 2 or 3 based on insufficient 160m 'Y' visibility splay distance due to the 50mph speed zone. But if the speed zone were 30mph then a reduced 70m 'Y' splay easily could be accommodated and the traffic impact then reduced due to sites 2 and 3 being out of the village centre.
- Traffic impact for sites 2 and 3 to the east would be lower as additional commuters from any new housing would mostly travel away from the village towards the Fosse Way and south to M40 for employment.

* Strain on Radford local infrastructure and services
- Housing population in Radford is static and of mixed age groups not needing a large 250 (13%) influx of new residents for existing services and having to travel outside the area for work.
- The primary School is already over-subscribed, meaning there is already a sustainable village population and a further large influx of younger families is not necessary for growth

* Environmental & Character Impact
- Drinking water, drainage & sewage
- The proposed site 1 is already defined as a "High risk drinking water protected area" by the Environmental Agency which means that the quantity of new houses must be reduced - This has not been taken into any account by WDC assessments.
- Any development of the site will increase the drainage issues faced by the village. Poor drainage has led to open sewage being seen in School Lane. This land acts as a natural drainage point for the dwellings on Offchurch Lane, Chance Fields, The Greswolds, Southam Road and School Lane. Housing on this site would interfere with this natural drainage increasing the risk of flooding in the area of the Church and its environs. There are known sewage, drainage and flooding risks within this area. Any further pressure risks pollution of the natural aquifers of the canal and the River Leam.


* Sustainable Development appraisals
- The WDC sustainability assessment has not been scored adequately and shows Radford to have a 65% higher '-' negative scoring than '+' positive based on the 16 NPPF criteria categories which should have removed the village from the Local plan or reduced the housing allocation based on Government Sustainable Development principles.
- The WDC sustainability assessment shows site 1 to be of low Ecological value and less than the other sites due to having fewer hedgerows - however, this neglects the site being high grade registered Organic farmland, including large trees and bushes higher than 1 metre thus giving it a 3 times 'Yes' score as land of Ecological value in Government Sustainable Development principles.
Option site 2 has the highest future Eco sustainability due to its South facing incline for solar heating and PV electrical generation and greater open South-West prevailing wind aspect to allow for wind turbine electric generation.

* Site comparison using a quantative Matrix
The conclusion from the comparison matrix below, assessing the relative difference between each site taking the WDC proposed site 1)as a baseline, shows that Option 3) and 5) are the better and most positive and that Option 1) and 4) are the worst and most negative sites.


Option Site 1 Land North East of Church Lane , ref RS4
*Traffic Impact, site access;-
- There are significant traffic access issues both onto the A425 and in Church Lane to access to housing plots at the North end of the site, thus bisecting the site and contravening the open aspect required for the Church setting. Also Church Lane would have to be widened for 70 metres to meet the 'Y' visibility splay from the A425 junction thus again contravening the open aspect required for the Church.
- The additional vehicles from 100+ homes travelling during morning and evening rush hours and trying to access the A425/ Church Lane/ School Lane 4 way junction cannot be accommodated at this accident black spot, particularly at times of peak traffic flow through the village.
- A traffic assessment of the A425/Church Lane/School Lane junction was made in summer 2013 during the holiday period and whilst the road was closed in the centre of Leamington Spa. Therefore the data collected does not represent peak flows regularly seen throughout the year.
* Landscape Impact, Greenfield function;-
- Visual impact is very high if trying to build all the 100+ houses in one development as this visually affects 47 surrounding dwellings. Also it does not give sufficient space to provide the required open rural aspect setting for the Church.
- To reduce impact, the quantity of housing should be reduced and located at the North end of the site, however traffic access would still bi-sect the Church aspect.
- Site 1 is a large area of high grade Organic registered farmland which would be totally lost.
*Scale of Development:
- Should be reduced from 100+ capacity due to high landscape, traffic and drinking water protection impacts which are of high importance weightings.
- Reduced Option 1a), locate at northern end = 1.4ha giving 36 houses, with impact to 10 dwellings.

Option Site 2 Land South of Southam Rd , ref RS1
*Landscape Impact, Greenfield function;
- Impact is high but not of any higher importance than site 1 because the environmental assessment score is based on rural open impact from 'The Grange' Farm towards the Fosse and site 2 accounts for only ~5% of the total.
- Visual impact is high if trying to build all the 100+ houses in one large development as this visually affects 26 surrounding dwellings.
--Site 2 is lesser standard grade open farmland compared to site 1 and will be only partially lost.
*Traffic Impact, site access
- WDC has rated its traffic assessment of 2 as unacceptably high as there's not a 160m 'Y' visibility splay distance available due to a 50mph speed zone. But if the village speed zone were 30mph as required by Dept of Transport circular 1/06 then the 'Y' lower splay required of 70m can be accommodated and the site becomes viable.
Consequently a speed limit of 30 MPH should apply as the village boundary will need to be moved out along Southam Road to include any new housing estate on either side of Southam road.
*Scale of Development:
- Should be reduced due to the rural and traffic impacts of high importance weighting.
Reduced Option 2a adjacent to A425 = 3ha giving 75 houses, impact to 11 dwellings
*Sustainability;
- This is the best option site for future Eco sustainability due to its South facing incline for roof solar heating and PV electrical generation and greater open South-West prevailing wind aspect to allow for wind turbine electric generation at each household.

Option Site 3 Land North of Southam Rd , ref RS1
* Comments for Option 2 equally apply to this site.
*Scale of Development:
- Can be expanded without further impact to 1.59ha as per the Sharba homes proposal which increases capacity to 40-50, making site more acceptable.

* Landscape Impact
- Visual impact is lower than site 1) or 2) as this visually affects only 7 surrounding dwellings.
- Site 3)is of lesser quality grazing farmland than site 1.

Option Site 4 Land South West of Spring Lane , ref RS3
This site should not be discounted purely based on coalescence as it does not extend beyond the village boundary at Slade Meadow.
*Traffic Impact, site access;
- housing capacity should be reduced to 40-50 to solve traffic access from Spring lane and school lane to the A425.
* Landscape Impact, Greenfield function;
- Visual impact is high if trying to build all the 100+ houses in one development as this visually affects 34 surrounding dwellings.
*Scale of Development:
Reduced Option 4a at northern end to 2.1ha giving 50 houses, impact to 19 dwellings

New Site Option 5 Land West of School boundary, Environmental ref RS08
This new site is highlighted in the WDC Environmental report as a potential site of lesser impact than others and as such this must be considered further in comparison:
*Scale of Development:
- site area = 1.65ha giving 42 house capacity
*Traffic Impact, site access;
- Simple site access viable from Kingshurst to existing A425 junction for lower additional traffic volume from site..
* Landscape Impact
- Visual impact is Medium from the WDC environmental report. The site has a lower residential visibility ratio where 42 house capacity affects only 7 surrounding dwellings and the school.

Option 6) Combining of 2 or more reduced capacity sites;-
By combing two sites of fewer individual houses to achieve 80-100 capacity required gives a lower overall impact.
A) - Combining 2a and 5, gives 100+ capacity with lower impact to 18 dwellings, good traffic access
B) - Combining 3a and 5, gives 80+ capacity with lower impact to 12 dwellings, good traffic access
Option 1a) = 1.4ha giving 36 houses, impact to 10 dwellings
Option 2a) = 3ha giving 75 houses, impact to 11 dwellings
Option 3a) = 1.59ha giving 41 houses, impact to 5 dwellings
Option 4a) = 2.1ha giving 50 houses, impact to 19 dwellings
Option 5) = 1.65ha giving 42 houses, impact to 7 dwellings

Comparison of all Option Sites using a scoring Matrix
This is a comparison matrix of the option sites, (which WDC has not carried out in its assessments) using a business 'Pugh Matrix' method to gauge the relative difference between sites and produce a total scoring to judge the best options. The WDC proposed site is taken as a baseline and each of the other sites is scored against each criteria as being either the same 's', or better '+' or worse '-'. The importance of each criteria is also included to give better weighting.
The conclusion is that Options 3 and 5 are the better and most positive sites whilst Options 1 and 4 are the worst and most negative sites.