Object

Publication Draft

Representation ID: 6820

Received: 14/09/2009

Respondent: Mr Stuart Boyle

Representation Summary:

Please accept this letter as my formal objection to the "Core Strategy Preferred Options" document dated June 2009. I specifically object to development of the following 'Green' sites and the focus of my discussion concerns the 4,000 houses proposed on these sites:

1) Land at Lower Heathcote Farm, south of Harbury Lane
2) Land at Woodside Farm, north of Harbury Lane, Whitnash
3) Land west of Europa Way, Warwick
4) South of Sydenham, east of Whitnash

I believe that many of the issues associated with the above 'Green' sites also apply to the following 'Amber' sites:

5) Former Fords Foundry, Leamington
6) Station Approach Leamington
7) Warwickshire college, Warwick New Road

Subject to satisfactory resolution of the traffic, education, health and employment issues attached I do support the proposals to develop the following areas:

8) Thickthorn, between Kenilworth and the A46
9) South of Finham, west of the A46

Other developments in the west of the district close to the M40 corridor should also be considered.

My views are based on the following areas which I describe in more detail in the attached appendix:

* Emissions
* Amenities
* Traffic
* Utilities
* Education
* Flooding
* Low Cost Housing
* Employment

The Preferred Options Paper does not address these areas of concern adequately. Nor do I believe that the council has adequately consulted the relevant agencies, if at all. I appreciate that many of these issues are outside of the control of the District Council, but nonetheless it is the duty of the council to consult the affected agencies and to commission impact assessments and feasibility studies to ensure that its proposals are realistic and achievable. The council has a duty of care to its current and future residents to ensure that quality of life in the district is not reduced by its proposals. Therefore it must fully address these issues before proceeding with its proposals.

Please acknowledge receipt of this letter and outline how the council will address these issues before it adopts the proposals.

Yours sincerely


Stuart Boyle

Appendix

Emissions

The preferred options paper refers to the Code for Sustainable Homes requiring all new homes built after 2016 to be zero carbon. It is disappointing that the proposals will allow a large development to the West of Europa Way to proceed ahead of this deadline and thus add to the district's emissions.

The paper fails to grasp the significant issues surrounding zero carbon developments and the need for a holistic approach in planning to ensure that objectives are met. It is unlikely that new housing will have a gas fired boiler in each property as is common at the moment. Other more novel solutions will be required.

Such large developments offer the opportunity for district heating and hot water schemes supplied from a central combined heat and power station. The power station could be fired by gas or by renewable or semi-renewable fuels such as bio-fuel, bio-gas or refuse. The Princes Road site has existing refuse management infrastructure and presents an opportunity to develop such a plant to supply heat to the Station Approach, former Ford Foundry and Warwickshire College developments.

However, the Europa Way and Harbury Lane developments are too far away to be supplied with heat from the Princes Road site and the use of part of this land for power generation will be unacceptable to nearby residents due to noise and the noxious nature of renewable fuels. For these sites the widespread use of heat pumps and solar hot water heating, should be considered, using gas boilers only in the coldest months. Ground source heat pumps are preferable as they are quieter than air source devices and also more efficient. However, ground source heat pumps require large plot sizes to avoid the ground freezing in winter.

The council should commission an energy study into the new developments in the context of zero emission housing. The study should consider alternative heating solutions and whether it is feasible to accommodate the proposed number of houses.

Roughly a third of emissions come from transport. It is therefore important that the Council considers why residents use their cars as they go about their daily activities. The plan should be strategic rather than reactionary and consider how housing, schools, shops and employment are combined to reduce car journeys and the need to use vehicles at all. This particularly concerns the school and employment issues described below.

Amenities

As an edge of town development the existing Warwick Gates development is remote from many day to day amenities such as schools, hospitals and shops. Consequently many residents are reliant on cars. The proposed development on the south side of Harbury lane will be similarly remote from local amenities and these residents will also be dependent upon their cars.

For this reason the proposed developments are less suitable for non-car users such as pensioners, the disabled and the socially deprived and therefore these developments are less suitable for low cost housing.

Traffic

During morning and afternoon rush-hours, there is frequently congestion on Myton Road, Harbury Lane and Gallows Hill. Europa Way is congested from Myton Road to the M40 Junction 14 resulting in stationary traffic on the inside lane of the M40 which presents a significant hazard to motorway traffic.

The new A46 flyover under construction at M40 junction 15 will ease traffic flow between the A46 and the M40. However, I believe that this will increase congestion on the south side of Leamington as traffic destined for the business parks and industrial estates on the south side of Leamington and Warwick will approach from the M40 rather than through Warwick.

The addition of 4,000 properties south of Warwick Gates will add around 8,000 cars to these already congested areas. The creation of residential and/or business access along Europa Way and Harbury Lane coupled with noise and safety related demands for lower speed limits on these roads will further impede the flow of traffic.

The District Council must consult with the County Council and Highways Agency on traffic flow on local main roads and the M40 before confirming their proposals. Particular attention needs to be given to how traffic flows through Warwick during M40 incidents and how the river and railway barriers to traffic in Warwick can be eased. I believe that the A46 corridor to Coventry and the M40 corridor to Birmingham are more suitable areas for development.

Utilities

Much of Warwick and Leamington is supplied with water from Strensham, near the M5/M50 Junction. 4,000 new houses will almost certainly require additional pipelines to Strensham and development of the Strensham site. The sub regional water cycle study should consult Severn Trent on the feasibility of supplying these developments in the proposed timescales and what interaction there is with development proposals elsewhere in the West Midlands.

E.ON Central Networks and National Grid should also be consulted on the feasibility of supplying gas and electricity to these large developments. In particular will the Emscote Road substation need enlargement to accommodate the new load and by what route will the cables to supply the new developments be routed? The use of heat pumps on both gas and electricity demand also needs to be included in those consultations.

Primary Schools

The Warwickshire School Organisation Framework 2005-2010 assumes approximately 3 pupils per year group per 100 houses developed. Thus the proposed development of 4,000 houses on the south side of Warwick and Leamington will require approximately 120 places per year group. The council must consult with the Local Authority on schooling for 840 additional primary pupils.

The table below lists primary schools within three miles of the proposed developments. There is spare capacity for around 35 pupils per year group at primary level but only at the further and generally unpopular schools in the area. It is reasonable to expect that if children from the new developments attended these schools then they would travel by car.

2005 capacity (7 years) Number on Role in 2008 Approximate capacity per year group (7 years)
Bishops Tachbrook 210 202 1
Briar Hill/ St Margaret 270+360 266+356 1
St Josephs 210 208 0
St Patricks 210 143 10
Whitnash 280 115 23
Total 35
Given the limited land and often restricted road access to existing schools it is unlikely that these schools could be expanded to accommodate further classes.

The intention should be to educate children at local schools to allow the establishment of new communities on the proposed developments. Failure to do this will means that neighbouring children attend disparate schools, as has happened on Warwick Gates, which impedes the building of a local community among neighbours. The new schools should be central to the proposed developments to give focus to the community. Children will also have shorter journeys to school and will be more likely to walk or cycle in line with government health and emissions policies.

Importantly, the new schools must be completed and available with the completion of each phase of housing. If housing is completed before school facilities then children will be forced into schools much further from their homes. It is unlikely that parents will relocate their children back to a 'local' school once they have been established elsewhere.

Secondary Schools

The council must consult with the Local Authority of the location of schooling for approximately 960 additional secondary pupils.

The following table lists secondary schools in Leamington and Warwick within three miles of the proposed developments. It shows adequate capacity within this distance but all of these schools are a considerable distance from the proposed developments.

2005 Capacity
(6 years) Number on Role in 2009 Approximate spare places per year (6 years)
Aylesford 1189 774 69
Campion 845 471 61
Myton 1330 1330 0
Trinity 1279 937 57
Total 187

The new North Leamington School has spare capacity of approximately 300 students. This new school together with Trinity represents considerable capacity in the northern half of Leamington Spa. Therefore new developments on the north side of Leamington and Warwick such as at Milverton would be more appropriate.

Flooding

The proposed development areas south of Harbury Lane extend to the Tach Brook between Bishops Tachbrook village and Warwick Gates. The council should not permit housing so close to a natural water course due to the risk of flooding, not only to the proposed developments but also downstream due to faster run-off from developed land compared to the existing fields.

The current climate already produces a number of heavy rain events each year which can lead to flooding. The number of these events is expected to increase over the next few decades due to climate change and therefore water retaining buffer areas around existing water courses should be preserved.

Low Cost Housing

The council has stated that it requires 50 percent of the new developments to be low cost housing. I object to the creation of up to 2,000 low cost houses in one area. Such a development would create an area of relative depravation and poverty. It would have a high concentration of health and crime problems and would increase demand on local services for little additional council tax income.

New low cost housing should be dispersed for better integration with the community. It should also be developed closer to town centres to facilitate habitation by non car owners. The ex Ford foundry, Station Approach and Warwickshire College sites are more appropriate for low cost housing development.

Employment

Companies such as National Grid and Wolesely have moved large offices and warehouses into Warwick District during the last decade. However, often this hasn't created new jobs in the district but instead relocated jobs from outside. Consequently we now have several thousand employees living outside the district who commute into it to work. This dislocation of employment from housing exacerbates traffic congestion, increases emissions and wastes a lot of resident's time.

I object to the creation of an additional 10,800 new properties within the district where there is no plan for increasing employment by a similarly large scale. Indeed, the recent economic crisis has significantly reduced employment in the district due to the contraction of the automotive industry. The proposed developments will create dormitory areas for people working outside of the district, chiefly in Coventry and Birmingham. It would be more appropriate for new housing to be created closer to these conurbations and where people work.

Development along the A46 nearer to Coventry at Thickthorn and Finham is appropriate. Consideration should also be given to creating new communities in the west of the district along the M40 corridor to Birmingham. The council should also consult with the regional development authorities on how to create employment within the district rather than how to import employment and traffic from elsewhere.