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).