3 Strategic Vision

3.1
To make WDC "a great place to Live Work and Visit" I am not sure the new "urban roundabout"/ signals and employment land at Thickthorn will give a great impression to a tourist on his/her way to Kenilworth Castle.

3.4
How will you manage to get the developers to have eco friendly /low carbon/zero carbon housing? bearing in mind their great need for profits.

3.5
Previous employment land has been used for housing eg Kenilworth-Dalehouse/Common lane so now we move employment land on to the green belt. Town centres are facing difficulties for 2 reasons a) out of town shopping malls b) car park charges are too high

The Strategic Vision "..to make Warwick District a Great Place to Live, Work, and Visit" will not be achieved by building houses on open farm land and thus increasing the already overcrowded road network and the extra pollution likely to follow. Point 3.5 mentions proving homes for the elderly but this only seems to be by proving Extra care homes. Nowhere is there any mention of provision of Bungalows.

We support the general strategy - in particular the efforts to REGENERATE run down areas, the PROTECTION of all areas of "significance", especially listed buildings and Conservation Areas and we would support efforts to ensure "High Quality Design" although in our experience this seldom actually happens, being lost in the later stages of planning process.

There is too much emphasis on GROWING the local economy - the local economy is just fine, much better than many others and with a very, very low unemployment rate. Growth will come with massive costs in terms of environmental damage and quality of life. More business will demand more people who will need more houses - is that what we really want? - I think not! Best ease off the gas and use up what we have before we BLIGHT more of our lovely area, especially the areas south of Warwick and Leamington.

The council's vision is to make Warwick District a Great Place to Live, Work and Visit. It is not clear how the proposed reduction in green land, increase in housing and the consequent increases in pollution and traffic congestion will achieve this vision.

Royal Leamington Spa Town Council broadly welcomes the Revised Development Strategy and in the attached document gives a more detailed response to items within it.

The economic benefits of sport in the West Midlands is also recognised and a Sport England survey in 2008, showed continued growth from 2002 with over £2.1 billion spent on sport-related goods and services in the region in 2008. In the same year, consumer expenditure on sport accounts for 2.9% of the total expenditure in the region, the highest percentage among the English regions. Compared with 2005, there is a 39% increase in sport-related consumption. During the period 2003-2008, the proportion of total consumer spending on sport has increased from 2.4% to 2.9%.
Sport and associated industries are estimated to employ 54,200 people in the West Midlands. This represents an increase of 23% over the period 2005-2008. During the aforementioned period, the percentage of sport related employment in the region increased from 1.8% to 2.2%. Employment linked to the sport-retailing sector increased very strongly during the 2005-2008 period, reaching 5,400 people employed. The region bucked the recession trend in all sport related indicators. Sport therefore plays a vital role in the economy in the West Midlands.
Whilst Sport England does not have evidence on the economic impact that sport has on Warwick DC, given the amount of sport played in and around the District, the economic value of sport to Warwick DC should not be overlooked.

Commercial indoor five aside, commercial indoor cricket, have been growing markets even in the most recent recession, creating employment and training opportunities on business parks. D2 uses therefore should be considered along side B1 uses, just as a number of gyms such as Virgin and Fitness First have been on business parks elsewhere in the country. E.g. Wolverhampton Business Park , Wolverhampton.

There is usually more employment opportunities generated through a commercial gym, e.g. David Lloyd Gyms or commercial football e.g. Football First D2 use, than a 100,000m2 B8 use.

This is not such much an objection to the local plan, but more an advisory comment aimed at making the new developments a better place to live.
I have been a resident on Chase Meadow for nearly seven years, living in a new build house and suffer the consequences of poor direction from the district council on planning. The Chase Meadow estate was badly planned, with narrow roads that restrict access for residents and emergency vehicles, which itself is made worse by the lack of appropriate parking for homes, meaning more people park on the narrow streets. Chase Meadow is a family estate with many young children and the narrow streets with the parking issues make it very dangerous to cross roads.
The estate has also suffered from insufficient parking around the shops and pub, with many people again parking on the roads.

The new community centre, although a welcome addition to the estate will exacerbate the parking issues, with space for up to 500 people at events, there will be even more on-road parking particularly along The Marish.

The roads still have not been adopted by the council, even though areas of the estate have been complete for the best part of 10 years.
The plots are very small with many of the newer houses having tiny gardens.

When the new estates in the local plan are being designed, I hope that the council planning officers will learn from the mistakes made on Chase Meadow, and make them a better place to live.

Warwick is already a great place to live, work and visit so don't spoil it with such a large volume of housing in one area. There is no requirement to grow new jobs as unemployment is only 1.7% and current is judged to have a good job-home balance.

By putting economic growth as the first item in the vision, this drives the other elements. I question that further economic growth is required - certainly not so much as it should drive an inward migration of 12,300 new homes. This will totally overwhelm our existing environment. Change needs to happen at an acceptable level, and be assimilated. The growth should be spread evenly across existing communities. This plan will turn the district into a building site for the next 10 years. It will ravage the environment that it claims to want to maintain with the road improvements sweeping away hedgerows and conducting huge numbers of cars across Castle bridge onto High Street Warwick, which is struggling to cope already. The growth north of Warwick should be re-instated and levels south drastically reduced. The homes are for outsiders and will do little to provide housing for local people. The use of the term "garden city" is just so misleading and deceptive.

I am happy with *Regeneration of areas in need of improvement.
*Protection of areas of special significance.
*High quality design.
but do not think we should be encouraging more growth than is actually required just to stimulate the local economy or fund infrastructure defficiencies

It is easy to forget that each of the proposed houses, will need to become a home. That is not achieved by facilities alone, but many years of growing a shared spirit that engenders support and fellowship across all ages in a community. It is my considered view that this Plan fails to support this vital endeavour.

The NPPF (2012) wants people back in planning. WDC only talks to developers. It has completely ignored the self builder. It opens WDC up to legal challenge.

NPPF wants innovation to drive standards. Developers are only interested in placing as many houses as possible on the land as witnessed at Hatton Park and Warwick Chase near Budbrooke.

WDC has not upgraded the roads infrastructure to match the increased numbers of cars and Warwick Parkway traffic.

Budbrooke has special problems with sewerage so badly built Severn Trent would not adopt it and electricity infrastructure inherited from the old Barracks.

Although the document states that the objective includes a commitment to providing for the accommodation needs of Gypsies and Travellers, there is no such provision or acknowledgement of this need in the subsequent policies.

Social - Providing for Growth and Changes within Population

To reflect the National Planning Policy Framework 2012 (NPPF), the WDC needs to involve Self Builders as part of the Development Plan to encourage more energy efficient and innovative design to reduce the carbon footprint of residents


Emphasis on Infrastructure

The number of proposed homes will place an intolerable strain on traffic flows in and out of Budbroooke Road due to the restricted traffic flow at the Warwick Parkway railway bridge. This uses a one lane direction traffic lights filter and will not cope with such additional traffic volume.

Stagecoach Midlands therefore wishes to generally support Warwick District Council's Strategic Vision, which is essential in setting the basis on which sustainable development can be realised, but has strong reservations about certain of the measures proposed, which we do not believe will deliver the vision. As this Vision is taken forward through robust policy-led prioritisation of actions, Stagecoach Midlands will be much better able to support the LPAs objectives while achieving our strategic goal to provide further high-quality greener smarter travel choices to the District's residents and visitors.
The National Planning Policy Framework (NPPF) makes clear in paragraph 7 that the "golden thread" of Sustainable Development that runs through it, includes economic, social and environmental goals. Stagecoach Midlands recognises not just its general responsibilities as a good corporate citizen, but the particular key role our business plays in securing these objectives at a local level.
Every day, Stagecoach buses:
* connect customers to markets and employees to businesses. Stagecoach Midlands itself is a locally-significant employer and customer of UK businesses
* connect people of all socio-economic groups to school, college, further and higher education; and of course to leisure and recreation opportunities
Our operations achieve all of this in a way that reduces congestion, and emissions. DECC statistics demonstrate that in the UK, personal transport use generates as many greenhouse gas emissions as the entire residential dwelling stock.
Not only do we reduce personal travel carbon footprints radically, but we are making strenuous efforts to reduce the carbon intensity of our own operations. Stagecoach Group announced in January 2013 that it has cut the carbon impact of its businesses in the UK and North America by more than 20% in the past four years. The transport group's absolute annual carbon footprint is now nearly 56,400 tonnes of CO2e lower than in 2007-08. The annual carbon saving is equivalent to the CO2e produced by powering nearly 11,000 homes for a year. Measured by carbon intensity (kg CO2 per £ of turnover), Stagecoach's carbon impact now is 22% less than four years ago.
As a result, Stagecoach Group is the first Transport Company to reach the Carbon Trust standard for emissions reductions.
Where land-use planning, and local transport policies align to facilitate high quality efficient commercial bus operation, then a full range of highways management, economic development, environmental sustainability and socio-economic inclusion objectives are all simultaneously met.
Where bus services are not effectively and positively planned for, and bus operators and their customers are marginalised, then unsustainable car-dependent development is the unavoidable result, contrary to the overarching intent of National Policy, and the explicit principles set out in paragraph 17 of the National Planning Policy Framework.
Stagecoach therefore regrets that connectivity is not given much priority in Warwick District Council's Strategic Vision, although we understand the preoccupation with meeting housing need.
Transport, to the extent that as it is addressed at all in the Strategic Vision, is largely considered in terms of lists of hard infrastructure projects, designed in response to the modelled impacts of the Revised Development Strategy. Transport measures therefore seem entirely to flow out of the Development Strategy, rather than the Strategy firstly taking account of "the opportunities for sustainable transport modes (to be) taken up, depending on the nature and location of the site, to reduce the need for major transport infrastructure" as required by NPPF paragraph 32.
This risks a strong misdirection of attention into physical highway works without looking at more creative and holistic approaches which better address the wider needs of communities, now and in the future. This is explicitly required by paragraph 17 of NPPF. Specifically, it states that plan-making and decision- taking should:
"actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable."

Stagecoach also submits that the approach being taken, with its emphasis on hard engineering, is likely to prove more costly than one which identifies and takes up the existing opportunities presented by more sustainable modes of transport, in deciding the location for new development. This approach risks the delivery of that development, by imposing additional burdens on development viability than might strictly be necessary. We note that, just before this consultation closed, the promoters of the greater part of the Myton Garden Village site west of Europa Way, have tabled an application for up to 800 dwellings, of which only 20% are affordable, rather than the 40% sought in Warwick DC's emerging Local Plan policies. The applicants submit a full viability appraisal, by professional development economic specialists, that demonstrates that the cumulative burden on viability of planning requirements, including transport, does not permit the Council's target to be met.
NPPF is clear that planning should also ensure that:
"improvements can be undertaken within the transport network that cost-effectively limit the significant impacts of the development."

NPPF paragraph 31 also explicitly requires that plan-making bodies should
"...work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development."

We therefore are disappointed that the Revised Development Strategy and supporting Warwick Strategic Transport Assessment (WSTA) makes little or no provision for infrastructure to support delivery of high quality bus services, and in particular, bus priority at key points and on key corridors to the South and North of Leamington where congestion is already becoming a significant difficulty for us, and where future development proposals will greatly increase pressure on the highway network.
Stagecoach Midlands is very concerned that, based on the Warwick Strategic Transport Assessment Phase 3 modelling, undertaken in support of this strategy, the following effects arise, even with all the prioritised mitigation in place:
* A deterioration in traffic conditions in both Leamington and Warwick Town Centres
* A general decline in traffic speeds during peak hours, especially in the network south of the Avon
* That with all model runs, the biggest residual deterioration in road network performance occurs on the south and eastern flanks of Leamington Town Centre, on the one hand, where scope for engineering-driven mitigation is most limited; and on the Europa Way and Tachbrook Road corridors.
* A general increase in peak delays and queuing, in both town centres and on key arterial routes. The modelled increase in queues even at full mitigation at the Victoria Terrace/Spencer Street lights, and the Old Warwick Road/Princes Drive junction, through which a large number of our services must pass to serve the proposed southern focus of planned development, is especially worrying; and barely less so at the Tachbrook Road/Heathcote Lane junction. We are equally concerned, on the opposite side of the urban area, that a similar deterioration in traffic conditions is anticipated at the A46 Thickthorn Interchange.
The result is that each bus within our Leamington and Warwick network will cover less mileage in a given period of time, at the end of the Plan Period. Therefore, just to "stand still" in terms of journey frequency, Stagecoach Midlands will have to find additional resources: buses, drivers and overhead; to maintain the current timetable offer within the urban area and environs. Actual journey times will be slower, which ordinarily would be expected to produce a decline in overall patronage.
There is a real risk that, far from improving the conditions to deliver improved modal choice, in conformity with the requirements of NPPF, the Revised Development Strategy undermines it, because of the absence of specific targeted and comprehensive measures to deliver bus priority.
With regard to the developments themselves, while we do note WCC's preferred strategy on bus service specification to serve specific major development south of the towns in particular, the sense from the consultation document is these and all other bus services, will also have to fight for space on the existing network, alongside all other traffic, with negligible rebalancing of the highway network in favour of the bus as a more sustainable travel mode, as required by NPPF Paragraph 29.
WSTA Phases 2 and 3 modelling do assume certain very limited bus priority measures, though these are largely focused at the northern end of Europa Way. These mainly take the form of priority bus gates to allow buses to enjoy priority release from signals, but do not allocate dedicated lanes for bus services over any distance.
We also note that there is a considerable discrepancy between the Virtual Park and Ride frequency for which WCC are seeking developer funding, and that modelled in WSTA. The Revised Development Strategy sets out a 30-minute frequency service to Warwick, and a 20-minute frequency service to Leamington. WSTA Phase 3 assumes a 9-minute service frequency to Leamington, and 12-minute to Warwick throughout the day (WSTA Phase 3 section 9.2, p.95).
There is also some lack of clarity about the P&R routing and operating mode assumed by the WSTA models. It appears the WSTA Phase 3 modelled a dedicated direct Park and Ride bus service as it is not clear that any allowance is made in the journey time for the service to stop en-route to pick up and set down between the facilities and the town centres, as the "virtual P&R" concept envisaged in the Revised Development Strategy anticipates.
We are also very concerned at the journey time penalty suffered by Park and Ride users, compared with car users, that the model produced. We are therefore extremely sceptical that the mode shift assignment of travel demands to the bus service will occur at the level anticipated by the Plan. We do not see that motorists will see any advantage in parking, waiting up to 20 minutes for a bus to Leamington, and then suffer a slower journey than cars taking a parallel route into town (WSTA Phase 3 figure 30, page 101).
To re-iterate, the Park and Ride bus services are anticipated to operate as a conventional bus routes, and will therefore also act as the main bus links from the proposed development allocations to the Town centre. We do not believe that this service should make an initial journey first to the park and ride facility, before making its way into town, without enjoying any bus priority at any stage. In the absence of bus priority measures, the 15% mode shift target required by the Strategy would be much better achieved by those services serving the developments taking the most direct route into town.
The time disadvantage that WSTA assumes for bus passengers at peak times seriously undermines the credibility of the mode shift targets for bus use required by the Strategy. This time penalty can only be addressed by the introduction of comprehensive bus priority measures on the main affected corridors, and in the town centres of Warwick and Leamington.
We also note that the Leamington Park and Ride Route has been modelled to operate through the Myton Garden Suburb area, a parallel but not comparable route with Europa Way in terms of speed. In fact, depending on urban design approach, this route, with the potential for multiple accesses, side roads and on-street parking, is likely to be, and perceived to be, slower and more circuitous than a service running directly along Europa Way, if conventional urban and highways design approaches are used.
We are aware that a formal outline planning application for the bulk of this area was submitted just before this consultation closed (W13/1016/OUT). It is clear that the Master Plan and Movement Strategy is quite conventional.
We will be making our own submissions in response to the application. For now, in response to this Policy consultation, we would say that there are a number of ways to address this journey time disadvantage by Master Planning and highway design within the Myton Garden Suburb site, which we cover later in this submission. For the avoidance of doubt, we can see the considerable merits of combining a service through the Myton Garden Suburb with the "virtual" Park and Ride operation, BUT for this to work effectively and be attractive to potential passengers, great care needs to be taken in the overall design approach to the actual bus corridor within and adjoining the scheme, and the urban design of the proposals as a whole.
The approach taken within the modelling to the assignment of patronage to P&R is high-level and is therefore relatively inaccurate. Experience over many years demonstrates that park and ride delivers significant mode shift, and commercially-sustainable levels of patronage, only when parking at the destination is highly constrained, very frequent bus services are offered, and significant on-line bus priority exists, to allow motorists to see buses passing them while they sit in queuing traffic.
Looking both at the national experience of successful Park and Ride schemes, and then at a growing list of failed Park and Ride operations in some other towns, we consider that the virtual Park and Ride proposals need far more robust and nuanced operational and commercial modelling, based on a service design that offers very much clearer and more credible advantages for potential customers, if this part of the Revised Development Strategy is to achieve the necessary impacts.
To conclude and summarise, no bus operator can provide high quality mode choices when its costs are increased by operating in heavy congestion, while its customers face delays and unpredictable journey times. Real mode choice requires that the relative attractiveness of more sustainable travel modes needs to be enhanced. The Revised Development Strategy makes almost no explicit provision for such rebalancing, at least as far as bus services are concerned.
Indeed, the relative silence of the Development Strategy on the role of bus services in securing a sustainable form of development is quite notable, despite the weight attached to the effectiveness of certain bus-based elements in the WSTA.
The Councils' own retained specialist transport consultants conclude at the end of the WSTA Phase 3 Report that "further detailed assessment of the potential benefits of the P&R should be undertaken although it is imagined that such testing would be intended to compliment an over-arching feasibility study of the P&R site meaning allowances for mode share and interception could be included within the modelling to allow a better understanding of both the benefits and impacts of delivery." We strongly agree. In fact, we do not understand how the Revised Development Strategy can be considered robust without this work having informed the Strategy.
WDC/WCC's own highways technical consultant explicitly states that "it is critical that sustainable transport improvements form part of the mitigation package to support the housing and employment growth proposals within the District." (WSTA Phase 3 Appendix H Technical Note 21/5/13, page 1).
Stagecoach Midlands considers, having carefully reviewed the revised Plan proposals and the supporting evidence base, that a considerable amount of further work needs to be undertaken, in partnership with promoters, WCC and bus operators, as required by NPPF paragraph 31, to arrive at a deliverable, robust package of sustainable transport measures in support of a much more sustainable local Statutory Development Plan for Warwick.

I am writing about the issues that are involved with the Local Plan. I am 13 years old, and go to King's High School in Warwick, and I live in Bridge End. I have heard about the plan from the worries of many local residents and after a little research, feel the need to express my anxiety over the proposals.
Firstly comes the environmental aspect. The colossal amount of proposed development land in Warwick alone is unbearable. With so much natural land destroyed, not only will there be ever less land for the already rapidly declining hedgehog populations (of which may I point out you are readily encouraging) as well as other plants and animals' natural habitats, but even the basic need for a clear horizon will not exist. I've even heard that the Ribbon Development Act doesn't allow this much destruction of natural land. All over the world natural habitats are being destroyed, to my disgust, at an ever increasing rate. But when this comes to home, I begin to feel horrified of how real this all is. The natural habitats of the area are already being strained out, and although you may "express concerns", I believe you do not. I feel ashamed that my home country is turning as industrious as the rest of the world - it is becoming less and less special. You will prize it more, in your eyes, but not us. For you this is simply a business matter but for us this is our lives, and through all this paperwork, all you're really doing is thwarting the beauty out of them. It really comes to a point of the tolerable and the intolerable.
Secondly, and very potently, the health aspect. As a local along with at least 25 people in Bridge End walk to Myton, King's High, and Warwick Boy's School. After a trip to Cornwall, I remember saying "Dad, can't you smell something really... you know, like dust, like stale air.." and Dad said "the car fumes. I love Cornwall, it's so clean from the sea, it's a shame I guess...". And I do notice it even now. When I walk up to school through the town centre, the fumes are really noticable, and horrible. England, like the rest of the world, is shrouding itself in it's own filth. Also, all of the girls and boys from Warwick Prep, King's High and Warwick Boy's have PE lessons in the playing fields. Many of my friends have asthma, and all of us can actually taste the pollution in the air. The huge amount of housing means extra roads, extra roads mean extra cars, which mean thousands more inputs on air pollution. I've heard the air pollution in Warwick is at or even over the legal limit. Is this true? It doesn't surprise me. You may claim otherwise, but it's a fact. The increase in air pollution will be significant. It will go over the legal limit, very much to your knowledge, yet you readily accept and move on thinking "we are not liable. This is not through our cause, but of the new local residents." This has serious health effects, or else the limit wouldn't have been made! Buildings as well as people will be affected, including the Castle and other historic sites. As a cross-country runner who loves to train on the school track, I know as much as everyone that it's not only horrible, it's damaging me as I run even though I'm meant to be getting healthier from excerise! Isn't that what you encourage, because it can't be for long. It's illegal, and we shouldn't put up with it.
And finally, the actual effect of the quality of life on the residents, visitors and tourists. The Bridge. Shown in countless postcards of Warwick, it's an enormous cultural significance. I walk across it twice a day to get to school. I used to throw snowballs over the edge when I was little with my Mum. People row their boats down the timeless stonework. Photographers use it to catch that beautiful sunset view of the castle, where, on a plaque that countless feet have walked across, reads "one of the finest views in England." So many new cars may, over calculations, seek an end to this masterpiece. You simply cannot wish to achieve this! One of the finest views in England, replaced by a cold, budget replica, because all of this is really about money. You are rejecting one of the best treasures of the River Avon, the most famous river in your country.
I already know all too well that every morning, every afternoon at rush hour the traffic queues are some of the largest in the area. Even when the traffic lights turn red to let me cross the road, the queue will often grow 500m. For large events, like concerts, and the folk festival, the traffic can extend as far as you can see over the bridge in all directions. Add to this thousands more cars, and I don't think many can cope. Some people may want to drive because of the illegal air fumes, so these extra cars (that would have been healthier walkers, may I add) create even more unwanted fumes. Others may want to walk because of the unbearable traffic, but they hate to because of the horrible fumes! You have to drive either way. Many of my friends' parents drive them to school, as well as their siblings. With so much extra traffic in the area, the journey between sibling's schools will be extended, to the point that (already being tight) one may have to miss some school in the morning. The money you pay for many schools wasted, as pupils cannot attend the first ten minutes - no, not an exaggeration, a real concern amongst everyone! This may seem little, but over the course of a childhood will have a noticeable effect on their education - often the start of a lesson is the most important! You may say the extra roads will spread the traffic out more, but we don't need more roads, we have plenty to get around. What these new roads really are doing is turning half the town into a parking lot!
Tourists and visitors will likely be put off too. Even from entering Warwick, "the heart and soul of England", actually an industrial skyline of fields of grim, identical looking houses just like these people have back at home, huge employment buildings, like at home. Traffic that reduces their day spent in Warwick, also simply off-putting. Who wants to know that the beautiful, idyllic town of Warwick has decided to replace it's history and wonder with industry, money and power? The history lost from the bridge, the nature lost from development and replaced with the things these people already have and are trying to escape from in order to experience new places to their fullest - will surely put tourists and visitors off. Meant to be a quiet place, not just for tourists, but for families and the retired, Warwick will have a terrible increase in noise pollution. I love the great outdoors and it's quiet serenity, that makes it so at peace. The noise of traffic and people in town are already starting to drown out my thoughts. Why go further? Not only will all this have an effect on your reputation from outsiders (and insiders) from within and without England alike, it will eventually decrease the steady flow of tourists that many people's livelihoods remain on. They get poorer, you get less tax, until many become unemployed and seek your help - which you are trying to solve by building an employment building!
My letter may seem somewhat defensive, but I feel it has to be. So many people feel these things but their voices are blatantly being ignored, which makes me feel even more passionate about having the voice that our country is meant to give us. Of course I realise that this isn't simply a matter of acting on the plan or not, as there are a lot of issues that you are trying to solve, and a lot of things tying you down. But I am concerned that far more issues will be made taking action in the plan - the ones above are simply a sampler of the concerns that I and indeed all the locals harbour. These cons will affect you too - they threaten all of us. The new residents coming to live here will also experience them, and word of mouth will leak to them of the side effects of this development, which they shall not be proud of. This is a long term commitment - 18 years altogether - that not many can take. Residents will leave, so this plan to get more people to stay will surely not balance as planned? This is my entire childhood, and all my friends, which will stay with us for the rest of our lives. Warwick will be a less green place, a noisier, more claustrophobic, and grimier, less interesting or beautiful place. Many people decided to retire here for what it truly is. You are about to deny them that and force them to live the most precious part of their lives in misery - they don't deserve this!
Please make the most out of our country. It upsets me that if the people who contributed to the history of Warwick, who helped make it such a beautiful place, were able to see the disrespect and ingratitude that some people nowadays have on them and their country - they would feel ashamed and disappointed. I feel grateful for what fortune has given me and my family - all of my childhood memories come back to here. Please show a love to other people's lives, like you promised you would, and help Warwick continue to be the prosperous, green, homely community it already is. Please let me know I am in good hands.

I have serious concern over many of the proposals made in this plan.
The stated aim of this New Local Plan is "to make Warwick District a Greater Place to Live, Work and Visit." I was born in Leamington and have lived all my life here. However over the years I have seen many lost opportunities, and mistakes, to make the area more environmentally acceptable.
While I have to accept that areas regarded as Urban Brownfield Sites should be developed for Housing and some of the smaller Greenfield Land, ie Kenilworth (Thickthorn) and East Whitnash provide natural extension of existing housing areas. However the overdevelopment of the area South of Leamington could eventually become a planning disaster.
Taking the Plans objectives in a slightly different order:-
Work
The outlook for British Industry will not be as it was in the past. Large Industrial Plants, like Automotive Products will not be sited in this area of comparative affluence. The Government, no matter who is in power, will provide incentives for any such major plants in area of high unemployment. The future for Industry in this area will be in small to medium units supplying other major manufactures. One only has to see the units on the old AP site are Distribution Warehouses and the many empty units on the Heathcoat, Sydenham and Queensway sites. In fact the Queensway site is being cleared of existing Industrial units to build retail units (Aldi) and Housing Association Units. If there is a demand for Industrial Units why have the planned units on the Ford Foundry site been abandoned?
One has to question why we want all the new Housing Developments. Even with the large number of available factory units the Unemployment Rate for the area is 1.7%, some 1,340 people. It could be assumed that even a modest improvement in the Economy would absorb most of the people.
"A Grater Place to Live"( Traffic)
The Projected 12,300 new homes are much too high. Particularly when one considers that the majority of this building will be on the south of both Leamington and Warwick. This in itself will cause traffic problems but when combined with Stratford District Councils plans to expand LIghthorne Heath, KIneton, Southam and Wellesbourne by a total of 4,800 dwellings which will all used Leam/Warwick for many of their shopping, recreational and school journeys, the increase in traffic will be considerable.
The ability of all this traffic moving about is seriously restricted by the number of bridges that cross the Avon and the Leam. There are 4 in Leamington, Willes Road, Victoria Terrace, Adelaide Road and Princees Drive. Of these Bridges the first 3 have reasonably free flowing traffic as they are not directly connected to the north/south route through the Town. However the Princes Drive Bridge is another matter, being directly link to the M40 by Europa Way. It is further complicated by the restricted height involved in the 2 Railway Bridges that are in the vicinity of the Bridge. This junction with its "unique" road makings which are open to various interpretations, within days extra mini cones had to be installed to prevent illegal turns. In addition the misleading lane markings that results in Europa Way traffic having to get back into the correct lane has resulted, so far, in only minor collisions. The congestion coming into the area therefore funnels a large amount of traffic onto the Banbury Road Bridge over the Avon at Warwick. How long this Bridge will withstand this traffic is a matter of conjecture but it must be a matter of concern to the Highways Department. (To appreciate the possible volumes of congestion you only have to witness the problems in Warwick when there is a road accident in the vicinity of Warwick on the M40 or the A46.)
While Air Pollution in Leamington is at a Low Level at the present during a holiday period with the Schools closed, a spike in the level of Nitric Oxide have occurred in the last week, Nitrogen Dioxide has been recorded at 30 m/metre cubed and Particular Matter 40m/metre cubed. (Ricardo AEA). If the full number of projected house were to be built it could conservatively be consider that an extra 20,000 private vehicles would be added to the daily movement which at peak times of the day would escalate the volumes of pollution.
Studies across the World have linked short term exposure to Air Pollutants to the increased admissions to hospital and increased cases of Heart Failure. (The Lancet)
A Great Place To Visit
While in the process of composing this letter I had to travel through Warwick from the Stratford Road to the Banbury Road, at midday on a Summer Friday. It was chaos, Jury St was packed from end to end with one must assume on a summers day were visitors to the Town. It would have been quicker to walk from West Gate to East gate. There were 3 delivery vans parked half on the pavement, and as I approached East Gate an Ambulance had to force its way through the traffic taking the opposite carriageway.
It is indicated that Traffic Improvements are to be made to the Jury St, Butts, Smith St, road junction. Well practically what can be done, nearly all the Building are Grade 1, or 11 Listed, and whichever way the traffic is going it passes into a further restricted highway.
The remaining life blood of Warwick is its Tourism. Over my lifetime I have watched it disintegrate from a thriving Market Town of great charm with many interesting streets and shops. It is now has County Hall and the Castle with limited parking, which on any reasonably busy day most tourists have to park in Myton Fields and walk into the Town.
Surely Warwick is a place that many Tourists only visit once, and do not recommend to their friends. The building of more Factory Units and Residential areas south of the Town can only make the situation worse.
Location of Traveller and Gipsy Site south of Warwick and Leamington
Anybody who has a plot of unfenced land lives in dread of this problem. I have had personally experience of the disruption, filth and sheer antisocial result of a Travellers site. I presume that the situation at Meriden in the last few of years has resulted in the pressure to accommodate a site in this area of the County. If the County Council is forced by Law to make provision for such a site why is it necessary to have 3 sites in this area and so many of the potential sites in the area south of Warwick and Leamington?
Conclusion
It is the nature of our society that the building of dwelling places is cheaper on open land. The fact that the land to the South of Warwick and Leamington, while being good agricultural land is not designated as Green Belt, and therefore can be developed with minimal legal restrictions. This is unfortunate because the expansion of our small conurbation over the Harbury Lane towards the M40 I feel is a mistake. The Government has applied pressure for reason that I will not explore to make more sites available for building and this wrongly has been taken as a the easiest option without the infrastructure to support the addition buildings successive Administrations have always taken the easier, and above all cheapest option. Hospitals, Schools and Main Services can be adapted and enlarged after the expansion of our Towns. If the Heathcote area produces flooding of the Myton Road after a thunderstorm the drainage can be modified.
However once the Application is approved, the increased traffic starts moving there is no going back. The health and quality of life of Warwick and Leamington will be forever irreparably damaged.

I am a resident of Bishops Tachbrook, where I live with my wife and family.
We have lived in the village for 9 years and chose the location because we wanted to live in a quiet village location away from the town centre.

I have read the WDC Revised Development Strategy (2013) and I have attended a public meeting where I viewed the WDC RDS PowerPoint presentation. What follows is my considered response to the proposed housing developments and Gypsy Traveller sites.

The RDS completely contradicts WDC's strategic vision "to make Warwick District a great place to live, work and visit" (RDS 3.1).
An increase of 12300 homes will not achieve this vision and will in fact have the opposite effect for a number of reasons:
The actual number of homes required to meet the projected population growth in the district is 5400. This is based on factual information derived from the national census statistics, and allows for migration. Where is the evidence to support WDC claim that 12300 homes are required?
The WDC presentation states that, in order to provide for growth of the local population (RDS 3.5), sites for 550 new homes per annum would need to be identified. Over an 18 year period this totals 9900 homes. Where does this number fit in with the 12300 WDC claim are needed to meet growth?

Why has the WDC empty home strategy not been included in the 5 year plan? WDC has developed 250 homes back to use under this strategy and further homes have been identified. http://www.emptyhomes.com/ identified approximately 1350 empty homes in the Warwick district in 2012, why isn't more work being done around this type of development of existing homes rather than proposing large scale new developments. There does not appear to be any mention of empty homes into RDS.

Warwick District currently has a very low unemployment rate, with only 1.6% unemployment (claiming JSA). If some of the proposed development is about economic growth where is the evidence to show that people moving into the area will be able to find work?
Much of the employment land in the district has not been fulfilled and may subsequently become land for housing but where are the jobs for the people moving into the area?
I have heard the growth of Jaguar Land rover cited as a employment opportunity which would require homes for employees moving to the area. However, the WDC RDS does not take account for the fact that Stratford District Council are in the process of consulting on a proposed development of 4800 homes in the Gaydon and Lighthorne area. This would be closer to the JLR than any of the Warwick District developments in terms of homes for JLR employees.
Why have WDC and SDC not communicated about their development plans when they are so close? As a Bishops Tachbrook resident we will also be affected by the SDC plans as any commuters and/or visitors to Warwick and Leamington from the new developments will increase the traffic and associated problems, noise/ air pollination etc.

The visual impact on the view from Bishops Tachbrook, Harbury Lane, Tachbrook Valley, Gallows Hill will be hugely significant for existing residents but also visitors to the area. No amount of 'country park' can make up for the loss of beautiful countryside and open fields which would be lost to thousands of homes and the associated environmental impacts such as noise and light (from houses, cars and street lighting). The planning inspector who reviewed the current plan in 2006 said that Woodside Farm should not be built on then or in the future. The WDC's own landscape consultant, Richard Morrish, said in the Landscape Area Statement (2009) referring to the land south of Gallows Hill "this study area should not be considered for urban extension and the rural character should be safeguarded from development". The RDS goes against this recommendation, why?


The local infrastructure cannot support such a significant number of houses in one area. The Southern Site already has significant issues in terms of volume and flow of traffic. The RDS does not contain any evidence to show that the proposed infrastructure improvements would alleviate any of the problems that would come with such a large development. No number of dual carriage ways will improve the flow of traffic through the 'pinch points' such as crossings of canals, rivers and railways and the RDS does not provide any realistically deliverable to solutions to these problems. There are major problems for traffic trying to get into Leamington on weekday mornings when the traffic backs up all the way onto the main carriage way on the M40. Appendix E of the Warwick Strategic Transport Phase 3 Assessment shows traffic speeds of only 0-10 mph in large parts of Warwick. Any increase in traffic, never mind the exceptionally large numbers proposed in the RDS, will make this situation worse. Rather than increasing trade in the town centre it is likely that people would be put off visiting the shops because of the volume of traffic. This view was supported by the Chairperson of the Warwick Chamber of Trade, who echoed this point at the public meeting I attended.

A lot can be learnt from previous developments in terms of the volume of traffics. The Warwick Gates and Chase Meadow developments prove that the people who move onto these developments will use their car to commute to/from work and to/from shops and town centres. The bus services serving these developments are not self funding and rely on subsidies to run. It would be naive and idealistic to think that this would be any different on new developments. Most houses have more than one car and most people will drive to work. The location of the Southern Site development would require most residents to commute to work.
A lot can also be learnt about sites identified on plans for facilities such as schools and play areas which are not followed through. The Warwick Gates plans contained a site for a school which was never built. This subsequently but huge pressure on surrounding schools and thee is still and annual scrabble for places amongst the Warwick Gates residents who have a nervous wait to see if their child will get their preferred option. Therefore I have no faith that if the proposed plans go ahead the schools will come to fruition. Similarly, the Chase Meadow development had a playground site on the plans and again this was not built. Also many of the properties on both of these developments are rented out and therefore not lived in by the people who bought them.

One of my main concerns is the health implications. I have read the Local Air Quality Progress Report (2011) and the areas already identified in this report as 'Air Quality Management Areas' will be affected by an increase in traffic volume as a result of the proposed developments. As the Air Quality is covered by the Air Quality Regulations 2000 (amended 2002) and the Environment Act 1995 as well as various other legislation I cannot understand why a full Health Impact Survey has not been commissioned. How does WDC know that the proposed developments will not take air pollution levels above the legal limits. It is not acceptable to just go ahead and worry retrospectively when we are talking about serious health implications. Many schools, nurseries and parks are in the vicinity of the Southern Site and the Heath of the children who use these facilities could be at risk if this goes ahead without a full assembly of the potential impact of such a large development. I seriously worry about the effect on my children's health and other children in the area. In my opinion this should take priority over everything else and I am extremely disappointed that WDC are not giving due consideration to this aspect of the impact on local residents.
In terms of Bishops Tachbrook, the village is already a cut through for many vehicles on their way to/ from the M40. When I walk my dog in the morning there is a disproportionate amount of traffic travelling through the main roads in the village, in comparison to the number of residents. Speeding along these roads has always been an issue and the speed reduction measures are ineffective. Mallory road leading to the Banbury road is also prone to flooding and has sometimes been impassable. There have been no improvements made to the road systems or pavements since the development of Warwick Gates and I see no acknowledgement of this need in the RDS. This is yet another example of WDC failing to recognise and consider the wide reaching impact of large scale housing developments on existing infrastructures. If the proposed develop goes ahead it will increase the volume of traffic through Bishops Tachbrook and that will increase the risk to residents of Bishops Tachbrook as there are no proposed improvements.

The housing proposed for village settlements has categorised Bishops Tachbrook as the largest type (100-150 homes). The Bishops Tachbrook housing needs survey identified a need for only 14 homes. Again, where is the evidence to support the need for 100-150 homes? Why would this many houses be needed in the village when 3400 homes are proposed for the Southern Site development? With regards to the visual, environmental and infrastructure issues I echo what I have said in the above paragraphs.

Why are we insistently building on prime agricultural land? Surely this land is needed to feed the ever growing population of the country or we will become more reliant on importing food and pushing prices up even further. Obviously the developers prefer this option as it's easier and means more profit for them.

I have read the criteria for the sites for Gypsy and Travellers from the consultation document. I do not think that the proposed sites are distributed evenly around the district and again the south contains a disproportionate number. All of the above points I have raised would also apply to the development of a Gypsy and Traveller site in this area.
In terms of the relevant criteria I do not consider the following sites to be suitable:
Site 3: this site is very remote and does not have easy access to facilities, access, pedestrian access and is prone to flooding.
Site 4: as above.
Site 5: The access is onto a very busy road and there is no pedestrian access. There would be a visual impact on the approach to Warwick and there is a listed building on the site. There would be undue pressure on the local infrastructure and services of such a small village.
Site 6: has no pedestrian access and is very remote in relation to distance from main centres and services.
Site 9: there would be a visual impact on the approach into Warwick and there are listed buildings on the site. The access is onto a busy road and there is no pedestrian access.
Site 10: Too close to the Guide Dogs for the Blind National Breeding Centre.
Site 15: This site is located on the banks of the Tachbrook. As the proposed site may be used as a place of work there could be a risk of contamination.

The school in Bishops Tachbrook has one class of approximately 30 children per intake. A GT site of 5,10 or 15 could be home to 10, 20 or 30 children. As Bishops Tachbrook is a small school already at capacity is could not support the needs of the site. There are other schools in the district that are not at capacity that could support the need.

The sites around Bishops Tachbrook are too remote to support the development and the village and its facilities are not big enough to support such an increase in population, in terms of infrastructure and facilities.

I am also concerned about the negative impact these sites will have on local house prices and increases in house and car insurance. Statistics show a rise in crime rates.

I understand the requirement for WDC to provide 31 pitches but I strongly feel that a larger number of smaller sites evenly distributed across the district in areas where the existing facilities can accommodate the need is the most appropriate way to meet the requirements.

OBJECTION TO THE LOCAL PLAN FOR THE REVISED DEVELOPMENT STATEGY

This is not a plan or a Consultation Document it is a mish-mash of isolated ideas and unconnected thoughts without any joined up thinking. I am repeating what I said at the meeting held at Hill Close Gardens a year ago. Fundamentally my views have not changed.

My major objections are as follows:

1. There cannot be any development in this area without the building of

* A new hospital which is fit for purpose as Warwick Hospital cannot cope with potentially 20,000 - 30,000 new patients
* Two new secondary schools need to be built and I can only see a site for "possible Secondary School". This has other implications on both schools in the area and on traffic flows at peak times.
* Where are these people going to work? Is it Sir Peter Rigby's new Gateway scheme that the WDC planners are so keen on?

2. No traffic assessment can have been done because if that is the case then the overwhelming case cannot be in favour of bringing traffic over a Grade II listed bridge that is already crumbling as the 7.5 tonne weight limit is regularly ignored. You only have to stand at the end of Myton Road between 8.00am and 9.00am or between 5.00pm or 6.00pm and you can see the effect. Warwickshire County Council's record in traffic management schemes is not one to have confidence in considering the mess they made of the recent "improvements" to the High Street and Jury Street. Indeed if these plans come to fruition then many of the streets in Warwick and surrounding environs will be just be arteries and I think here of Smith Street, St Nicholas Church Street, Bridge End, Myton Road, High Street, Jury Street, Castle Hill, Europa Way etc. The list is almost endless.

It has been suggested that the junctions become traffic light signal controlled. If they are anything like the new scheme that has been put in place at Princess Drive and the Recycling Centre then they will be an accident waiting to happen. It also adds nothing to the traffic flow and is far too complicated.

If the Gateway scheme is to be the major employer then again it is naïve on the part of the traffic planners to say there will be little impact on traffic flows. Most people will therefore be making their way to the A46 Trunk Road and either Avon Bridge or Europa Way will become very congested indeed. It is already indicated that traffic at the morning peak will be moving at less than 5mph. This means maximum pollution for very little reward.

3. At a previous meeting at Hill Close it was indicated that traffic issues at peak times would be a real problem issue due, in part, to school starting and finishing times. It was suggested that schools could be spoken to stagger their start and finish times. This I felt was naïve in the extreme as many parents drop their children off on the way to their place of work and this will not change. Thus that will not improve.

4. Developers will only build houses if they can sell them. Do people want to buy them and are they affordable. However once planning permission is in place then it is very difficult to stop it. This will be like having the 'Sword of Damocles' hanging over us.

5. Surely 12,000 houses are excessive. I would have thought a maximum number of half that amount is what is actually required which would have a dramatic effect on the plan. Why is the vast majority of the development on Greenfield sites and not Brownfield ones. I understand that only 9% of Britain is developed but when cuts out most of Scotland, Wales some areas of Derbyshire, Yorkshire, Northumberland, Cumberland and others then the picture looks vastly different. We are already overcrowded as an island. Why must the residents of Warwick (mainly) and Leamington be made to suffer?

I am not a 'serial' objector but a very concerned resident of what is a jewel in the crown of Warwickshire that is likely to be desecrated by this plan.

Thank you for the opportunity of commenting on the Warwick Local Plan Revised Development Strategy.
Midland Red (South) Ltd trading as Stagecoach Midlands, is the leading commercial bus operator in Warwickshire. The company operates the vast majority of bus services in Warwick District, including Leamington Spa and Whitnash, where we operate a comprehensive network designed to offer both convenient local trips, but at least as important, services offering residents effective choices for longer journeys. The great majority of these routes are commercial, fully funded by our passengers
We also operate services supported by Warwickshire County Council, won following tenders for best value. We always strive through disciplined reliable operation, quality customer service and on-board experience, and effective marketing, to build revenue on such services as far as possible with a view to taking them on without public funding at a future date, where possible. These services to a great extent follow timetables and routes specified by WCC, as socially necessary services, where patronage today could not support a commercial operation by us or another bus company.
Stagecoach in particular has a national, independently assessed reputation for delivering among the highest levels of customer satisfaction. As well as offering reliable convenient services we are constantly investing both in existing services and our operational bus fleet, and developing new products and services aimed explicitly at providing greener smarter travel choices to the public, and especially those who do not yet regularly travel by bus.
Stagecoach proactively seeks to identify and pursue business development opportunities, and the company recognises the role it plays in delivering sustainable development. We welcome the opportunity to comment on, and help shape development proposals to the advantage of the community and the wider travelling public.
High-quality bus services are one of the most credible means of preventing car dependency, mitigating local highways impacts as far as possible, and achieving sustainable development. This includes not only environmental but also socio-economic goals.
We submit that there is a clear alignment of interests between stakeholders in the planning system, and ourselves and other commercial bus operators.
Strategic Vision
Stagecoach Midlands therefore wishes to generally support Warwick District Council's Strategic Vision, which is essential in setting the basis on which sustainable development can be realised, but has strong reservations about certain of the measures proposed, which we do not believe will deliver the vision. As this Vision is taken forward through robust policy-led prioritisation of actions, Stagecoach Midlands will be much better able to support the LPAs objectives while achieving our strategic goal to provide further high-quality greener smarter travel choices to the District's residents and visitors.
The National Planning Policy Framework (NPPF) makes clear in paragraph 7 that the "golden thread" of Sustainable Development that runs through it, includes economic, social and environmental goals. Stagecoach Midlands recognises not just its general responsibilities as a good corporate citizen, but the particular key role our business plays in securing these objectives at a local level.
Every day, Stagecoach buses:
* connect customers to markets and employees to businesses. Stagecoach Midlands itself is a locally-significant employer and customer of UK businesses
* connect people of all socio-economic groups to school, college, further and higher education; and of course to leisure and recreation opportunities
Our operations achieve all of this in a way that reduces congestion, and emissions. DECC statistics demonstrate that in the UK, personal transport use generates as many greenhouse gas emissions as the entire residential dwelling stock.
Not only do we reduce personal travel carbon footprints radically, but we are making strenuous efforts to reduce the carbon intensity of our own operations. Stagecoach Group announced in January 2013 that it has cut the carbon impact of its businesses in the UK and North America by more than 20% in the past four years. The transport group's absolute annual carbon footprint is now nearly 56,400 tonnes of CO2e lower than in 2007-08. The annual carbon saving is equivalent to the CO2e produced by powering nearly 11,000 homes for a year. Measured by carbon intensity (kg CO2 per £ of turnover), Stagecoach's carbon impact now is 22% less than four years ago.
As a result, Stagecoach Group is the first Transport Company to reach the Carbon Trust standard for emissions reductions.
Where land-use planning, and local transport policies align to facilitate high quality efficient commercial bus operation, then a full range of highways management, economic development, environmental sustainability and socio-economic inclusion objectives are all simultaneously met.
Where bus services are not effectively and positively planned for, and bus operators and their customers are marginalised, then unsustainable car-dependent development is the unavoidable result, contrary to the overarching intent of National Policy, and the explicit principles set out in paragraph 17 of the National Planning Policy Framework.
Stagecoach therefore regrets that connectivity is not given much priority in Warwick District Council's Strategic Vision, although we understand the preoccupation with meeting housing need.
Transport, to the extent that as it is addressed at all in the Strategic Vision, is largely considered in terms of lists of hard infrastructure projects, designed in response to the modelled impacts of the Revised Development Strategy. Transport measures therefore seem entirely to flow out of the Development Strategy, rather than the Strategy firstly taking account of "the opportunities for sustainable transport modes (to be) taken up, depending on the nature and location of the site, to reduce the need for major transport infrastructure" as required by NPPF paragraph 32.
This risks a strong misdirection of attention into physical highway works without looking at more creative and holistic approaches which better address the wider needs of communities, now and in the future. This is explicitly required by paragraph 17 of NPPF. Specifically, it states that plan-making and decision- taking should:
"actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable."

Stagecoach also submits that the approach being taken, with its emphasis on hard engineering, is likely to prove more costly than one which identifies and takes up the existing opportunities presented by more sustainable modes of transport, in deciding the location for new development. This approach risks the delivery of that development, by imposing additional burdens on development viability than might strictly be necessary. We note that, just before this consultation closed, the promoters of the greater part of the Myton Garden Village site west of Europa Way, have tabled an application for up to 800 dwellings, of which only 20% are affordable, rather than the 40% sought in Warwick DC's emerging Local Plan policies. The applicants submit a full viability appraisal, by professional development economic specialists, that demonstrates that the cumulative burden on viability of planning requirements, including transport, does not permit the Council's target to be met.
NPPF is clear that planning should also ensure that:
"improvements can be undertaken within the transport network that cost-effectively limit the significant impacts of the development."

NPPF paragraph 31 also explicitly requires that plan-making bodies should
"...work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development."

We therefore are disappointed that the Revised Development Strategy and supporting Warwick Strategic Transport Assessment (WSTA) makes little or no provision for infrastructure to support delivery of high quality bus services, and in particular, bus priority at key points and on key corridors to the South and North of Leamington where congestion is already becoming a significant difficulty for us, and where future development proposals will greatly increase pressure on the highway network.
Stagecoach Midlands is very concerned that, based on the Warwick Strategic Transport Assessment Phase 3 modelling, undertaken in support of this strategy, the following effects arise, even with all the prioritised mitigation in place:
* A deterioration in traffic conditions in both Leamington and Warwick Town Centres
* A general decline in traffic speeds during peak hours, especially in the network south of the Avon
* That with all model runs, the biggest residual deterioration in road network performance occurs on the south and eastern flanks of Leamington Town Centre, on the one hand, where scope for engineering-driven mitigation is most limited; and on the Europa Way and Tachbrook Road corridors.
* A general increase in peak delays and queuing, in both town centres and on key arterial routes. The modelled increase in queues even at full mitigation at the Victoria Terrace/Spencer Street lights, and the Old Warwick Road/Princes Drive junction, through which a large number of our services must pass to serve the proposed southern focus of planned development, is especially worrying; and barely less so at the Tachbrook Road/Heathcote Lane junction. We are equally concerned, on the opposite side of the urban area, that a similar deterioration in traffic conditions is anticipated at the A46 Thickthorn Interchange.
The result is that each bus within our Leamington and Warwick network will cover less mileage in a given period of time, at the end of the Plan Period. Therefore, just to "stand still" in terms of journey frequency, Stagecoach Midlands will have to find additional resources: buses, drivers and overhead; to maintain the current timetable offer within the urban area and environs. Actual journey times will be slower, which ordinarily would be expected to produce a decline in overall patronage.
There is a real risk that, far from improving the conditions to deliver improved modal choice, in conformity with the requirements of NPPF, the Revised Development Strategy undermines it, because of the absence of specific targeted and comprehensive measures to deliver bus priority.
With regard to the developments themselves, while we do note WCC's preferred strategy on bus service specification to serve specific major development south of the towns in particular, the sense from the consultation document is these and all other bus services, will also have to fight for space on the existing network, alongside all other traffic, with negligible rebalancing of the highway network in favour of the bus as a more sustainable travel mode, as required by NPPF Paragraph 29.
WSTA Phases 2 and 3 modelling do assume certain very limited bus priority measures, though these are largely focused at the northern end of Europa Way. These mainly take the form of priority bus gates to allow buses to enjoy priority release from signals, but do not allocate dedicated lanes for bus services over any distance.
We also note that there is a considerable discrepancy between the Virtual Park and Ride frequency for which WCC are seeking developer funding, and that modelled in WSTA. The Revised Development Strategy sets out a 30-minute frequency service to Warwick, and a 20-minute frequency service to Leamington. WSTA Phase 3 assumes a 9-minute service frequency to Leamington, and 12-minute to Warwick throughout the day (WSTA Phase 3 section 9.2, p.95).
There is also some lack of clarity about the P&R routing and operating mode assumed by the WSTA models. It appears the WSTA Phase 3 modelled a dedicated direct Park and Ride bus service as it is not clear that any allowance is made in the journey time for the service to stop en-route to pick up and set down between the facilities and the town centres, as the "virtual P&R" concept envisaged in the Revised Development Strategy anticipates.
We are also very concerned at the journey time penalty suffered by Park and Ride users, compared with car users, that the model produced. We are therefore extremely sceptical that the mode shift assignment of travel demands to the bus service will occur at the level anticipated by the Plan. We do not see that motorists will see any advantage in parking, waiting up to 20 minutes for a bus to Leamington, and then suffer a slower journey than cars taking a parallel route into town (WSTA Phase 3 figure 30, page 101).
To re-iterate, the Park and Ride bus services are anticipated to operate as a conventional bus routes, and will therefore also act as the main bus links from the proposed development allocations to the Town centre. We do not believe that this service should make an initial journey first to the park and ride facility, before making its way into town, without enjoying any bus priority at any stage. In the absence of bus priority measures, the 15% mode shift target required by the Strategy would be much better achieved by those services serving the developments taking the most direct route into town.
The time disadvantage that WSTA assumes for bus passengers at peak times seriously undermines the credibility of the mode shift targets for bus use required by the Strategy. This time penalty can only be addressed by the introduction of comprehensive bus priority measures on the main affected corridors, and in the town centres of Warwick and Leamington.
We also note that the Leamington Park and Ride Route has been modelled to operate through the Myton Garden Suburb area, a parallel but not comparable route with Europa Way in terms of speed. In fact, depending on urban design approach, this route, with the potential for multiple accesses, side roads and on-street parking, is likely to be, and perceived to be, slower and more circuitous than a service running directly along Europa Way, if conventional urban and highways design approaches are used.
We are aware that a formal outline planning application for the bulk of this area was submitted just before this consultation closed (W13/1016/OUT). It is clear that the Master Plan and Movement Strategy is quite conventional.
We will be making our own submissions in response to the application. For now, in response to this Policy consultation, we would say that there are a number of ways to address this journey time disadvantage by Master Planning and highway design within the Myton Garden Suburb site, which we cover later in this submission. For the avoidance of doubt, we can see the considerable merits of combining a service through the Myton Garden Suburb with the "virtual" Park and Ride operation, BUT for this to work effectively and be attractive to potential passengers, great care needs to be taken in the overall design approach to the actual bus corridor within and adjoining the scheme, and the urban design of the proposals as a whole.
The approach taken within the modelling to the assignment of patronage to P&R is high-level and is therefore relatively inaccurate. Experience over many years demonstrates that park and ride delivers significant mode shift, and commercially-sustainable levels of patronage, only when parking at the destination is highly constrained, very frequent bus services are offered, and significant on-line bus priority exists, to allow motorists to see buses passing them while they sit in queuing traffic.
Looking both at the national experience of successful Park and Ride schemes, and then at a growing list of failed Park and Ride operations in some other towns, we consider that the virtual Park and Ride proposals need far more robust and nuanced operational and commercial modelling, based on a service design that offers very much clearer and more credible advantages for potential customers, if this part of the Revised Development Strategy is to achieve the necessary impacts.
To conclude and summarise, no bus operator can provide high quality mode choices when its costs are increased by operating in heavy congestion, while its customers face delays and unpredictable journey times. Real mode choice requires that the relative attractiveness of more sustainable travel modes needs to be enhanced. The Revised Development Strategy makes almost no explicit provision for such rebalancing, at least as far as bus services are concerned.
Indeed, the relative silence of the Development Strategy on the role of bus services in securing a sustainable form of development is quite notable, despite the weight attached to the effectiveness of certain bus-based elements in the WSTA.
The Councils' own retained specialist transport consultants conclude at the end of the WSTA Phase 3 Report that "further detailed assessment of the potential benefits of the P&R should be undertaken although it is imagined that such testing would be intended to compliment an over-arching feasibility study of the P&R site meaning allowances for mode share and interception could be included within the modelling to allow a better understanding of both the benefits and impacts of delivery." We strongly agree. In fact, we do not understand how the Revised Development Strategy can be considered robust without this work having informed the Strategy.
WDC/WCC's own highways technical consultant explicitly states that "it is critical that sustainable transport improvements form part of the mitigation package to support the housing and employment growth proposals within the District." (WSTA Phase 3 Appendix H Technical Note 21/5/13, page 1).
Stagecoach Midlands considers, having carefully reviewed the revised Plan proposals and the supporting evidence base, that a considerable amount of further work needs to be undertaken, in partnership with promoters, WCC and bus operators, as required by NPPF paragraph 31, to arrive at a deliverable, robust package of sustainable transport measures in support of a much more sustainable local Statutory Development Plan for Warwick.
RDS1 Stagecoach Midlands has no comment to make.
RDS2 Stagecoach Midlands has no comment to make.
RDS3 Stagecoach Midlands wishes to object to the proposed preferred option for the broad location of development, because of the difficulty in serving the sites on a sustainable commercially viable basis.
We strongly agree that a strategy of urban concentration makes best use of existing public transport infrastructure, and allows existing bus services to perform significantly better in terms of load factor. Such an approach also gives scope for a virtuous cycle of service enhancements to be delivered based on an overall larger quantum of demand from which to draw, by developing the network.
This supports travel mode shift not just from within the new developments, but across the improved network as a whole. It is likely, for example, that new or augmented routes serving development to the south of Warwick would continue, as today, across the town centres providing new direct links as well as enhanced frequency. This would improve the overall attractiveness of the service offer, subject to operating conditions being at least as supportive as today.
There is currently virtually no bus priority within the Warwick and Leamington urban area. Were measures to achieve bus priority to be introduced, then the positive effects outlined above would be greatly magnified.
We also concur with WDC and WCC that there is scope through a concentration of development south of the towns, to kick-start a radically improved level of service in an area in which historically it has proved very hard to offer frequent, direct bus services, not least because of car-dependent urban design, and a lack of critical mass of demand. In addition, the major local highway corridors, in particular Tachbrook Road and Europa Way, are already affected by peak-time congestion, even before any new development is constructed.
This opportunity to improve the public transport offer will only be realised, however, by positively planning for the bus to play a much enhanced role. While some of this is implicit in the intent of measures set out in the Revised Development Strategy, we are concerned that overall there is no clear agenda, nor specified measures, to ensure that the opportunities provided by the Strategy to deliver a much higher quality of public transport offer have been taken up, in the form of sufficiently well-developed actions required by Policy. We will address the opportunities we identify in more depth later in our responses.
As such we submit that the Strategy is not in conformity with NPPF.
Stagecoach Midlands OBJECTS to the location and distribution of the quantum around the south of Leamington and Whitnash.
In general, we consider that insufficient consideration has been given to achieving higher density development across the sites, or parts of them, sufficient to make best use of existing and credible future quality public transport provision. While we recognise the attractiveness and desirability of the Garden Suburb vision, the provision of effective high quality bus services is undermined by the relatively low housing densities involved, and the consequent likely impact on the dwelling stock mix.
The current Strategy, in proposing a relatively large development footprint also effectively gives rise to a much greater expanse of development south of Harbury Lane, than is easy to serve by a single high frequency bus route. Diverting existing service 68 through these areas will pull it away from existing development at Warwick Gates OR risk creating a circuitous service design that will be very unattractive to existing bus passengers, while being even less attractive to car owners.
Large parts of the development footprint in Myton Garden Suburb in particular, are much closer to existing local employment and amenities, and are also most closely related to the existing urban area. This development proposal is expected be within easy reach of the proposed high frequency bus corridor incorporating the "virtual Park and Ride". Depending on the master planning approach, higher densities might be justified in Myton Garden Suburb adjoining this bus corridor, either on the eastern flank if the service uses Europa Way, or, if a bus priority corridor were delivered within the scheme, within 250-300m of that. Higher densities, of up to 45 dwellings/Ha, would support much better patronage levels for the proposed bus service.
If it were possible to accommodate a larger development quantum at Myton Garden Suburb overall, which is the location best able to take advantage of sustainable transport measures, it might be possible to avoid the need for land releases elsewhere, which are currently very much less easy to access by sustainable transport modes.
In particular Stagecoach Midlands considers that several small-scale proposed land allocations east of Whitnash/South of Sydenham look to be difficult to serve on a sustainable basis, by attractive public transport services, without significant infrastructure measures being put in place, that are not anticipated by the Revised Development Strategy.
As stated above, the Strategy proposes that the development footprint extends much more than 300m south of Harbury Lane. The development quantum on land allocated beyond this threshold would be equally hard to serve with a bus service sufficiently frequent and direct to be attractive. In addition the wider public concerns expressed about incipient coalescence with Bishops Tachbrook could also be mitigated by a revised approach that reduced the development quantum that needs to be accommodated here by achieving a higher-density more compact urban form on development sites better related to existing and future sustainable transport opportunities.
We particularly object to the smaller scale releases of land south of Sydenham/east of Whitnash. These areas are well beyond 400m of existing bus services. Extending services into this area will require an additional vehicle resource, even at a modest half-hourly frequency. We do not consider that the potential patronage that would be generated by the proposals would sustain a credible commercial service in the long term. In fact, the need to split access to land south of Sydenham with a second access across the current Campion School site, makes this problem much worse, with only an additional 300 dwellings available to support the operating additional operating costs involved, which are likely to be between £130-140,000 per year at current prices.
However, were direct bus-only vehicular access provided across the railway between Whitnash and the land South of Sydenham, we see much greater potential to incorporate these areas into a high-quality commercial bus network, subject to appropriate pump-priming funding being available during the build out period to deliver this service appropriately early. This would require a bus gate incorporating a pedestrian and cycle link; and a high-quality bus circulation facilitated through the site, also picking up the proposals at Fieldgate Lane west of the railway.
Such an approach would lead to Sydenham potentially being directly connected to employment both existing and proposed south of Leamington. We consider that this would significantly enhance its connectivity to these opportunities and greatly improving the socio-economic sustainability of the Strategy. A dedicated transport crossing would also give public transport and other sustainable modes a major advantage over private car use from all the development east of the railway, and as a result these additional measures would offer a much more sustainable location compared with further development south of Harbury Lane.
We support the proposals at Redhouse Farm Lillington where the whole proposal falls within easy reach of an existing commercial high frequency service. It is the one proposed allocation that best makes use of existing public transport services and infrastructure in a location that is already sustainable.
We note the current proposed approach at Kenilworth. We recognise the need to meet the housing requirements of the town, and can see the landscape and other factors that favour Thickthorn. However we object to the current proposals because:
* We see that with the main access being proposed on to the A46 interchange, it will prove to be an exceptionally attractive location for car-based commuting, causing additional peak time congestion and undermining the effectiveness of the Strategic Highway Network, and potentially delaying our existing services, not least those offering fast links to Coventry and Warwick University via A46.
* When evaluating how we might serve the development, it is unclear that the quantum of development proposed there, and that existing adjacent, is sufficient to support a dedicated high-quality bus service longer term. Were we to divert existing routes it would in effect lead to other large parts of Kenilworth which currently enjoy frequent services, being either unserved or much more poorly served.
We also strongly support the additional development envisaged outside the main towns, particularly in larger villages. Bus services to these villages already typically offer hourly services, or better, but the longer-term sustainability of the current level of service does depend in most cases on higher levels of demand. We submit that, at a time when Warwickshire County Council is faced with ever increasing pressure on its budget for socially necessary but uneconomic bus services in rural areas, the approach taken by the Revised Development Strategy outside the main urban areas, is a prudent one to maintain and indeed possible allow some enhancement of bus services to outlying settlements. Walking and cycling do not present as credible a sustainable travel choice in these locations.
We would suggest there is likely to be scope for the kick-start of improved service patterns in certain rural corridors, facilitated by limited developer funding sought across multiple developments served by a rural bus route corridor. This may not only involve added frequency, but also more direct services, making elapsed journey times much more competitive with other modes such as car or scooter.
RDS 5 Proposed Allocations
Station Approach: Stagecoach Midlands would point out that a substantial portion of this site is our existing operational depot for the area. The depot provides the bus services for Leamington, Warwick and most of the surrounding area. No suitable or cost-effective alternative location for a replacement facility has yet been identified. Therefore the site is not available and is thus not currently deliverable or achievable.
Hampton Magna: If it were possible to create a greater allocation here, this would offer a larger population and a wider socio-economic mix that would be much better able to support the ongoing commercial operation of a bus service in this location, and one that is less circuitous than the present route, which given existing levels of patronage, requires Local Authority financial support.
Hatton Park: If it were possible to create a greater allocation in this area, this would offer a larger population and a wider socio-economic mix that would be much better able to support the ongoing commercial operation of a bus service in this location, and one that is less circuitous than the present route, which given existing levels of patronage, requires Local Authority financial support.
The current design of internal roads also makes the existing development exceptionally difficult for bus services to penetrate, owing to the detailed design of traffic calming features. Any traffic calming measures introduced must be low floor bus friendly and very minor works within the highway could address this as part of future development proposals, and should be required to do so.
RDS 6 Employment Land requirement: Stagecoach Midlands has no comment to make.
RDS7 Location of new employment land.
Stagecoach Midlands supports the provision of employment land at the western end of Thickthorn, which could be served by our existing services; and also and allocation adjoining Warwick Technology Park (WTP).
The augmentation of employment at WTP could help create greater critical mass of demand for existing and future augmented services here, as well as reducing the average distances residents in the locality will need to travel to work from the new development overall. Shorter travel to work distances give scope for more sustainable modes, including bus services, to offer attractive options compared with personal car use.
It should be possible to address the current very unsatisfactory bus circulation and stopping arrangements within the existing Technology Park site, and the problems associated with on-carriageway and other inappropriate parking. Rigorous Travel Planning formulation and delivery should accompany proposals for this location to avoid exacerbating existing car-dependency and congestion. If a direct bus-only link could be provided from the north or north-east of WTP, through a Technology Park extension sited north of Harbury Lane, and into the wider Myton Garden Village beyond, this would make the resulting bus journey quicker than the car for many trips at peak times.
Chapter 5, Strategic Development proposals
Stagecoach Midlands has concerns that the strategic development proposals set out in the Strategy are coming forward through the development control system in an uncoordinated manner, in advance of the strategic Policy framework to guide this development being in place. These proposals now account for the majority of the strategic quantum. Having reviewed all of them, we find that in most cases, little consideration has been given to providing a sustainable high quality bus service within convenient walking distances of homes. We will make our separate representations on individual proposals in due course.
In general, Stagecoach Midlands believes that the density proposals do not support high-quality public transport provision. Within an average density of 30-35 dwg/Ha Master Plans should make provision for higher density along proposed bus corridors, even if this is offset by lower densities in the more remote areas.
Myton Garden Suburb: We are aware that a formal application has been submitted by the promoters ref W13/1016/OUT, for the bulk of the proposed allocation west of Europa Way, and was registered less than a week before this consultation closes.
This proposed allocation offers by far the most compact urban form of the sites identified in the Revised Development Strategy. In the view of Stagecoach Midlands, this site is the most critical to the success of the proposed Strategy. This is because it sits between the existing urban area, including Leamington Town Centre, and most of the proposed new strategic development. The main new strategic bus corridor is proposed to run either alongside or within the site. En-route, this corridor serves key destinations such as the Station, Morrisons, Leamington Shopping Park, existing employment at Europa Way, and the existing and expanded Technology Park, before continuing to serve the greater portion of residential development proposed in the Strategy.
Creative and imaginative urban design and master planning could deliver bus priority through or alongside the development, thus unlocking the viability of:
* The proposed virtual Park and Ride
* The new bus route
and by extension all the other public transport initiatives supporting the strategy
By linking together the Technology Park, its extension, the Park and Ride, and the residential area using a dedicated bus-only link through or alongside the development to create a bus priority route to Europa Way; the opportunity will have been taken to protect and exploit sustainable transport modes in line with NPPF paragraph 35.
A number of alternative approaches within the control of the promoters of Myton Garden Village could secure this outcome, including:
* peak bus priority along the dualled Europa Way, with the nearside carriageway being a bus lane at peak times.
* An additional bus lane or dedicated bus road provided over and above the dualling of Europa Way for general traffic
* A purpose designed bus corridor within the Garden Suburb, which may be used by vehicular traffic for portions of its length, but with a bus gate or gates to prevent rat-running.
Without such measures, we believe that the Strategy as a whole will only perpetuate and exacerbate the existing car-dependence in this area, in direct contravention of NPPF. Such an approach would be unsound, as it would be inconsistent with national policy.
South of Gallows Hill: Stagecoach Midlands supports this allocation in principle. The initial proposals made in a formal outline application by the developers for the eastern portion of this area did not anticipate bus services entering the site. The road layout would involve excessive circuity and only allow buses to serve the far edge of the development, which would mitigate strongly against effective and attractive bus service provision.
Those proposals have recently been withdrawn. We submit that any future master planning approach for this site and the land to the west, should be comprehensive, and assume the retention and enhancement of the existing bus routing, with good, well-surveilled pedestrian links to quality bus stops provided on Harbury Lane, spaced between 280-330m apart. This justifies higher densities on the northern edge of future proposals.
Proposals here should help support high-quality links from the area towards Warwick and thus can be considered to support the consolidation of demand on an existing public transport corridor.
We agree this area is less suitable for employment-led development, from a public transport perspective, not least because we believe it is more operationally expedient to provide the P&R and the Technology Park extension to the north of Harbury Lane, immediately adjoining the Technology Park and its extension.
West of Warwick Gates: Stagecoach supports this allocation in principle. Stagecoach Midlands reiterates that this site needs to make provision for high-quality roadside infrastructure and associated pedestrian links to them if the site is to be sustainable, and the overall Transport Strategy is not to be undermined.
Lower Heathcote Farm: We note a formal planning application was made for the northern portion of this site. Stagecoach Midlands notes that the promoter has made no provision for a bus service to penetrate the site directly or indirectly in those proposals. These have now been withdrawn. We found this omission most concerning. We submit that any future proposals for this land should assume the retention and enhancement of the existing service along the existing route/s, with attractive pedestrian links to quality bus stops provided on Harbury Lane. This approach justifies higher densities on the northern edge of future proposals that come forward. As a corollary it may be appropriate to reduce densities at the southern edge especially if these plots end up being outside a reasonable 400m walking distance of stops on Harbury Lane.
This would also support wider urban design and planning objectives.
We object to the development footprint extending further south onto land beyond the initial application site, as this land is well over 400m away from Harbury Lane and will not be within reasonable walking distance of a good bus service.
Former Sewage Treatment Works: Stagecoach Midlands objects to the proposed allocation. The Company does not see that a viable bus service could be provided, as this area could foreseeably be within 400m of a quality public transport corridor. Planning applications made on adjoining land to the east (Grove Farm) and west (Lower Heathcote Farm) make no apparent provision for an efficient bus route linking through this land. In any case, as discussed above, even if a comprehensive approach is taken to deliver a bus corridor south of Harbury Lane, this would draw any service away from the existing development north of Harbury Lane, or lead to the splitting of the provision such that the frequency of service offered would not be sufficiently high to be attractive. We therefore submit that, with the possible exception of some limited development on the northern edges of the site, this option is not sustainable.
Grove Farm: This site is not currently within easy reach of existing bus routes operating at regular high frequency. It is possible that a new service might be provided along Harbury Lane to the north of the site. Alternatively the existing hourly X18 running to the east of the site offers a much more direct route to the town centre, and might be augmented. We note an application for an initial 220 dwellings, all within 400m of Harbury Lane, is already submitted (W/13/0036/OUT). We can see that the layout affords a potential link to land to the south. The full quantum proposed, alongside proposals to the NE at Woodside Farm, might support the provision of a new local bus service, or a wider network recast to improve local bus frequencies serving the site.
However while in landscape terms this site functions as a unity with proposals to the west in particular, and equally adjoins the urban area, it will be much harder in this area to take advantage of the bus service improvements serving the wider area proposed by WCC. We consider this site less sustainable in terms of making best use of existing bus services, or logical improvements to the local network. We believe developer contributions from this site, and Woodside Farm, would be justified to kick-start a much better frequency of service on the Tachbrook Road corridor serving both this site and Woodside Farm, over and above those already being sought by WCC.
Woodside Farm: We note the site is the subject of an undetermined application W/13/0776/OUT. This site is relatively hard to serve directly by public transport. Providing a bus turning circle within the site, in line with the current proposals submitted earlier this year, or a bus-only gate giving through access to Harbury Lane, might achieve a 30-minute commercial service at final build-out when combined with the full quantum at Grove Farm, and a suitable means of running buses within the wider Grove Farm development. We recognise an existing PRoW offers direct access to our existing G1 Goldline service, but its width and quality is very poor, and many dwellings will be beyond the limits of a 400m walk to the stops on Coppice Road.
In our view, as stated for Grove Farm, additional proportionate developer contributions might be secured towards kick starting a new or augmented bus service via Tachbrook Road running at least every 30 minutes, and preferably every 20 minutes, serving these sites, and the poorly-served eastern end of Warwick Gates.
Employment Site Option 2: As noted above we support this option over a site south of Gallows Hill, subject to effective linkage both between the existing Technology Park and the site; and also the proposed residential development further north at Myton Garden Suburb. As discussed above we see a number of means whereby a creative and effective solution might be achievable.

Chapter 5.1: South of Leamington Infrastructure requirements
Stagecoach Midlands objects to the infrastructure strategy as the measures would not deliver a high quality public transport service and is thus inconsistent with the objectives of the strategy.
We have been previously notified by WCC of its intentions and approach to securing bus service improvements in support of the Strategy. We broadly concur with the overall shape of the strategy.
However it is clear to us that the 15% mode shift sought demands much higher bus frequencies, in particular on the virtual Park and Ride services. This would demand the pump priming of additional vehicles, above the four for which WCC is seeking funding.
Not least, the additional development quantum south of the towns that that RDS now proposes, demands significant additional capacity to achieve the required mitigation. Today the bulk of our town services operate with 38-seat midibuses. A 20-minute frequency would offer only 112 one-way seats per hour to Leamington. Full sized single decks would offer up to 46 seats per journey. If the Park and Ride is to be successful, and secure a significantly higher bus mode share from new residential development, which accounts for up to 3195 new dwellings and a new population of about 7,200, this capacity will not be sufficient
In particular we believe that a second new direct service needs to be offered via Europa Way and there must be sufficient bus priority to ensure that the speed of the service is attractive enough to encourage its use by the residents of this area.
We also strongly endorse WCC's view that a Park and Ride needs to be an integral part of the wider bus network to be viable.
We consider that a 20-minute direct and 30-minute indirect service to Leamington town will be not sufficiently attractive to persuade motorists passing the P&R site to use the service, or encourage local residents to make use of the facility. The time penalty associated with waiting for a bus is likely to be, or perceived to be, too high. Experience across Stagecoach operations shows that urban services ideally require a "turn up and go" frequency of between 10-12 minutes to provide an attractive choice for casual bus use by customers who have a car available. A 15 minute frequency is the absolute minimum service that might achieve this goal.
In addition to be financially sustainable the proposed Park and Ride site must be of sufficient capacity to cope with the existing pressure on parking at WTP, the proposed new employment park and shopping, casual leisure or tourism visits. We believe that a greater provision is warranted than the 500 spaces proposed due to the above demands. We look forward to working with the Council's consultants in further exploring how Park and Ride could be made to work successfully, through a robust and comprehensive design and operational approach.
Developers south of Warwick are also currently being asked to fund an additional bus resource on service 68. This service is now partly supported by WCC between Warwick Gates, Warwick town centre, and points further west. It is a 30-minute frequency service designed principally to meet essential socio-economic needs. Both in terms of frequency and routing, the service is not attractive to existing car users.
We now understand from the RDS and supporting WSTA phase 2 and 3 that the additional bus for which WCC is seeking funding, is merely to maintain the existing frequency as journey speeds slow down along what is a very long route. This is not what we, and some developers' consultants, have been previously led to believe. This no doubt arises from an assessment of the congestion produced by the proposed development; to allow further diversions into the Park and Ride; and provide possible extensions to serve some development roads. Stagecoach Midlands questions how this is either financially sustainable after a subsidy period ends, of how far such a service will perform much meaningful mitigation. This measure cannot be considered a service enhancement.
A 30-minute service 68 would not be able to perform a meaningful Park and Ride function between the proposed virtual P&R and Warwick, given that if a bus has just left, it would be as quick for a reasonably able person to walk the 1900m to Warwick Town Centre.
There is a large inconsistency between the Park and Ride service specification set out in the Revised Development Strategy, and that actually modelled by WSTA to develop and test a credible highways impact mitigation package. The WSTA Phase 3 model assumes a 9-minute bus frequency to Leamington and 12 minute to Warwick. From what we can ascertain in the Consultation Document, the Strategy and associated infrastructure schedule is seeking funding to maintain a 30-minute frequency on service 68 to Warwick and a new 20-minute frequency service to Leamington. The discrepancy between the RDS proposal and the supporting evidence base offered by WSTA is considerable, and we would appreciate clarification.
The Councils' own evidence makes clear within the results of the WSTA Phase 3 model runs, that should the P&R-based mitigation strategy fail, the implications for the wider network are very serious. This is demonstrated by the queue length outputs, and the average traffic speed outputs, presented at section 9 of WSTA phase 3, and attached appendices D-G. There appears to remain a significant risk that if congestion rises further this will create a vicious spiral of lower bus use, higher costs, and ultimately service reductions, aggravating the problem.
Stagecoach Midlands also wants to highlight the significance of the tradeoffs between the costs of on-site and off-site highways and engineering measures, other necessary infrastructure, and the delivery of other policy objectives.
We realise that the proportion of affordable housing provided is particularly liable to reduce to redress the difficulties of overall development viability.
This is very relevant to the robustness of the Plan, in terms of the opportunity to make best use of sustainable transport. We recognise that the 40% affordable housing target aspired to by WDC is relatively high. Experience nationally is starting to make clear that this does support generation of much higher bus service patronage on new developments.
In order for the package of additional bus services to the area to be sustainable long term, it is very important that the maximum affordable housing quantum is delivered. However, we can already see publicly available detailed evidence, in the form of the viability assessment provided by the applicants at Myton Garden Suburb attached to application W/13/1016,that a level only half that aspired to, may actually be deliverable based on the emerging infrastructure strategy.
On the basis of the above issues we object to the Infrastructure strategy, as it makes little or no explicit provision to rebalance modal dependence in favour of public transport. There is little provided in the way of bus priority and there is a risk that the impacts of the Strategy may undermine current bus operations.
Achieving mode shift and a parallel reduction in operating costs through higher vehicle productivity is of the essence in delivering the optimised transport strategy for the area. We are thus very concerned, that no mention is made of comprehensive measures to assist public transport and redress the current conditions in the area today that all favour personal car use over more sustainable modes.
It should be noted that today a disproportionate level of bus operating mileage within the area earmarked for strategic growth needs to financially supported, compared with the rest of Leamington and Warwick, where services are generally fully commercial. Thus the Strategy needs not only to deliver augmented service that can credibly be sustained through revenue alone at the full build out period, but to recover a modest deficit situation.
The current difficulties operating bus services in the proposed growth quadrant arise to a great extent from historic approaches to land use and urban design. Previously, planning did not make any provision for the creation of effective bus routings. In fact, master planning and detailed design of streets have led to a situation where bus services have had to be retrofitted on some roads within the Warwick Gates development that are barely able to accommodate the vehicles. There is virtually no provision of high-quality roadside infrastructure in the wider area. Any perpetuation of this approach would be inconsistent with NPPF.
We therefore welcome that the Plan Strategy makes explicit reference to high-quality bus stop infrastructure, at least incorporating high profile flags and timetable displays, a suitable boarding area to offer level access to the disabled and infirm, and additionally, high quality shelters where appropriate. We would urge that this takes a more prominent place within the final Plan. Given the difficulties encountered retrofitting bus stops after initial consent we strongly urge that sites are agreed as part of initial master planning at Outline submission stage, where urban design and effective pedestrian accessibility can be considered with bus stop location in the round, and not at the determination of Reserved Matters.
We also support WCC's design standards for residential streets (2002) which requires 6.5m widths to accommodate bus routes, or 6.2m where on-street parking bays are provided. We recommend tracking for 12.2m Scania K230UB or Optare Versa V1200 single deck buses should be assessed to test all proposed bus routes within submitted layouts for fitness. Effective and efficient bus operation means that routes for buses should avoid multiple changes in priority, and sharp bends. Equally, tight radius corners, however subtle the turn, cause buses disproportionate difficulty, and we recommend they are avoided.
Chapter 5.2 Sites at Whitnash/South of Sydenham
We object to the proposed infrastructure requirements as we believe that they will be insufficient to facilitate the provision for sustainable bus service.
The now-consented appeal site south of St Fremunds Way cannot be served by a further extension of service 67, as a further vehicle resource would be needed. Much less will be possible to serve an additional 300 units to the south, for which separate access is envisaged, and therefore an entirely separate bus route would be required. As outlined above, merely extending services into this area at existing limited frequencies will require substantial additional resource, the costs of which, if developer-funded, would neither meet CIL Tests of reasonableness across such a limited housing quantum, nor would it likely to be commercially sustainable at full build out.
As we have said elsewhere, without a bus link across the railway offering scope to tie this area into the wider network to the west we do not see how this proposal can be considered sustainable.
Final Comments
Stagecoach Midlands is very aware that land-use planning must resolve a very large number of conflicting objectives and interests, to the ultimate benefit of the community.
The Company also recognises the particular challenges involved in today's economic climate, and equally respects the plan-making efforts sustained by both Councils and other stakeholders over a very considerable period to date, that have led to the current proposals.
We trust that Warwick District Council and Warwickshire County Council recognise that we are very willing to play an active and constructive role in further shaping the Development Strategy, as key stakeholders in securing sustainable development now and into the future.
Stagecoach Midlands would be happy to meet with representatives from the two Councils, developers and their respective specialist consultant teams as required, to assist in achieving the optimum development strategy for Warwick District over the next 20 years, and to help ensure that the objectives of sustainable development are met in the detailed design of the development proposals.

Whilst we are pleased to see the reference under the 'Environment' heading of the Strategic Vision (section 3) to the general principle of 'Protecting biodiversity, high quality landscapes, heritage assets and other areas of significance', we would like to see this aim specified in more detail in this Strategy. We appreciate that it may be intended to cover this elsewhere in the Local Plan process, but we contend that it is important to set this out in the actual development strategy itself.

Specifically, we would like to see -


1. Absolute protection for ancient woodland and ancient trees in accordance with national policy. Every ancient wood is a unique habitat that has evolved over centuries, with a complex interdependency of geology, soils, hydrology, flora and fauna. This requires absolute protection in accordance with national policy as set out below.

Ancient woodland, together with ancient/veteran trees, represents an irreplaceable semi natural habitat that still does not benefit from full statutory protection: for instance 84% of ancient woodland in the West Midlands has no statutory protection.

With Warwick DC showing a slightly above average ancient woodland resource at 2.64% of land area compared to a Great Britain average of 2.40%, it is vital that this valuable natural resource is absolutely protected.

It is also important that there is no further avoidable loss of ancient trees through development pressure, mismanagement or poor practice. The Ancient Tree Forum (ATF) and the Woodland Trust would like to see all such trees recognised as historical, cultural and wildlife monuments scheduled under TPOs and highlighted in plans so they are properly valued in planning decision-making. There is also a need for policies ensuring good management of ancient trees, the development of a succession of future ancient trees through new street tree planting and new wood pasture creation, and to raise awareness and understanding of the value and importance of ancient trees. The Ancient Tree Hunt (http://www.ancient-tree-hunt.org.uk/) is designed specifically for this purpose and has already identified ancient trees across the District, such as the ancient oak beside the railway line at Old Milverton (grid ref: SP 302 674).

Government policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The new National Policy Planning Framework clearly states: "...planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland..." (DCLG, March 2012, para 118).

However this NPPF wording should be considered in conjunction with other stronger national policies on ancient woodland -
- The Government's policy document 'Keepers of Time - A statement of Policy for England's Ancient & Native Woodland' (Defra/Forestry Commission, 2005, p.10) states: 'The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland'.

- The Government's Independent Panel on Forestry states: 'Government should reconfirm the policy approach set out in the Open Habitats Policy and Ancient Woodland Policy (Keepers of Time - A statement of policy for England's ancient and native woodland).....Reflect the value of ancient woodlands, trees of special interest, for example veteran trees, and other priority habitats in Local Plans, and refuse planning permission for developments that would have an adverse impact on them.' (Defra, Final Report, July 2012). This has been endorsed by the response in the recent Government Forestry Policy Statement (Defra Jan 2013): 'We recognise the value of our native and ancient woodland and the importance of restoring open habitats as well as the need to restore plantations on ancient woodland sites. We, therefore, confirm our commitment to the policies set out in both the Open Habitats Policy and Keepers of Time, our statement of policy for England's ancient and native woodland'.

- The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, para 2.56) states that: 'The Government is committed to providing appropriate protection to ancient woodlands....'.

- The new Biodiversity Strategy for England (Biodiversity 2020: A Strategy for England's Wildlife & Ecosystem Services, Defra 2011, see 'Forestry' para 2.16) states that - 'We are committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland site'.

- The West Midlands Forestry Framework (Growing our future, May 2010, Forestry Commission) Objective EB2 seeks: 'To prevent any further loss of ancient woodland and to enhance ancient semi-natural woodland and trees with new native woodland planting...'


An example of good Local Authority policy on ancient woodland is provided by North Somerset Council Core Strategy Adopted April 2012 -
'Policy CS4: Nature conservation
North Somerset contains outstanding wildlife habitats and species. These include limestone grasslands, traditional orchards, wetlands, rhynes, commons, hedgerows, ancient woodlands and the Severn Estuary. Key species include rare horseshoe bats, otters, wildfowl and wading birds, slow-worms and water voles.
The biodiversity of North Somerset will be maintained and enhanced by:...
3) seeking to protect, connect and enhance important habitats, particularly designated
sites, ancient woodlands and veteran trees'.

The Plan for Stafford Borough - Pre-submission publication: Jan 2013 states in Policy N5 that: 'New developments will be required to include appropriate tree planting, to retain and integrate healthy, mature trees and hedgerows, and replace any trees that need to be removed. Development will not be permitted that would directly or indirectly damage existing mature or ancient woodland, veteran trees or ancient or species-rich hedgerows'.

We would therefore like to see this Development Strategy contain a policy to read: 'Planning permission will be refused for developments resulting in the loss of or adverse effects upon ancient woodland or ancient trees' in accordance with the latest national policy.



2. As well as 'protecting' biodiversity, it is also critically important to EXPAND priority habitats like native woodland in order to deliver the wider aspirations of the Government's Natural Environment White Paper to achieve the 'landscape scale' habitat outcomes set out in the biodiversity review by Sir John Lawton (Making Space for Nature, DEFRA, September 2010).

The National Planning Policy Framework (NPPF) supports the need for more habitat creation by stating that: 'Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', (DCLG, March 2012, para 114). Also para 117 states that: 'To minimise impacts on biodiversity and geodiversity, planning policies should:....promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan'.

The new England Biodiversity Strategy which makes it clear that expansion of priority habitats like native woodland remains a key aim - 'Priority action: Bring a greater proportion of our existing woodlands into sustainable management and expand the area of woodland in England', (Biodiversity 2020: A strategy for England's wildlife and ecosystems services, DEFRA 2011, p.26).

A reading of these new policies in the National Planning Policy Framework together with the England Biodiversity Strategy indicates that habitat expansion, like native woodland creation, should form a high priority for this Strategic Policies document.

Woodland creation also forms a significant element in the conclusions of the Government's Independent Panel on Forestry, which states: 'Ensure woodland creation, tree planting and maintenance is part of the green space plan for new commercial and housing development' (Defra, Final Report, July 2012). This has now been endorsed by the response in the recent Government Forestry Policy Statement (Defra Jan 2013): 'We believe that there is scope for increasing England's woodland cover significantly to deliver economic, social and environmental benefits. We want to see significantly more woodland in England. We believe that in many, although not all, landscapes more trees will deliver increased environmental, social and economic benefits. We particularly want to see more trees and woodlands in and around our towns and cities and where they can safeguard clean water, help manage flood risk or improve biodiversity'.

The refreshed West Midlands Forestry Framework (Growing our future, May 2010, Forestry Commission) calls for: '...a significant increase in the West Midlands tree and woodland cover where strategic target areas continue to be identified' (Objective TWC2).

There are already good examples emerging of suitable wording on habitat expansion emerging in other Local Plan documents -

Solihull Draft Local Plan - Pre-Submission draft January 2012
Policy P10 Natural Environment
The Council will seek to protect, enhance and restore the diverse landscape features of the Borough and to create new woodlands and other characteristic habitats, so as to halt and where possible reverse the degrading of the Arden landscape and promote local
distinctiveness.
The Council will seek to conserve, enhance and restore biodiversity and geodiversity, to create new woodlands and other habitats and to protect and enhance semi-natural ancient woodland and green infrastructure assets across the Borough.

Draft Core Strategy for Chesterfield Borough Council - Feb 2012
5.25 Both the Chesterfield and North East Derbyshire Sustainable Community
Strategy and the Chesterfield Greenprint aim to increase the tree cover in the
borough for the benefit of both people and wildlife as well as improve
landscape quality. Tree and woodland planting will help the borough to
respond to climate change and flood alleviation, as well as improve
biodiversity and levels of amenity.


We would therefore like to see this Development Strategy contain a policy to read - 'development proposals should conserve, protect, enhance and expand features of biological or geological interest, including Biodiversity Action Plan habitats and species, and native woodland.

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