RDS7: The location of new employment land is as follows:

In my opinion as a property adviser the allocation should be increased to at least 10 ha and should not be exclusively office led and should included other uses within Class B subject to their compatibility with adjoining development and conditional upon high quality buildings being developed appropriate for their use and purpose.

Too much concentration south of Warwick/Leamington - 1/3 of the total provision or over half of the non-strategic allocation will be forced into the southern area - so will produce even more commuting and traffic problems

The land to the east of the Warwick Technology Park should not be considered. It is designated an Area of Restraint specifically to prevent what is being proposed. When the Technology Park was created it was on the condition that it would not spread east.

As I believe there is no need for the development of homes in the area south of Warwick and Whitnash I think there is no need for new employment land in this area especially as Warwick District has low unemployment at only 1.7%.

the area of Honiley Airfield amounting to some 200 acres has been identified by council officers as a potential site for employment development but not referred to in the proposed local plan.
There is already some 59 businesses located in a small part of the eastern area. Location and access is good for substantial expansion.
Recently a planning application was passed to benefit for the storage of vehicles for Jaguar Landrover for a period of four years only on a small area.
Despite hat was said at a meeting of Councillors and officers of the Council, the present occupiers of the site, Prodrive, as lessees and owners of the airfield, it was formally stated in the planning application that Prodrive are downsiing its operations at Honiley with the view of moving out of the area.
Although realizing the influence of the LEP is towards the Gateway project, it is believed that Honiley Airfield substantially offers itself as a far superior site for employment by location, existing infrastructure, access, etc., including it not suffering the gross toxic contamination of the Gateway site. housing for employees can be found within a small area including hatton green which is only some 3 miles away on the less busy stretches of the a4177. The development of the site will impose a far lesser burden on the public purse than Gateway and increase the sustainability of Warwick District noticeably.
the whole of the airfield is within wdc.
it is understood that wdc has made no approach to the owners of honiley airfield in its search for employment land and argument cannot be made against 'why not'.

I object to any land at thickthorn being designated employment land . It has been demonstrated that there is over 20 years supply of sites already designated for this purpose in the area. WDC has granted permission for development at abbey park and stoneleigh park and both sites are struggling to find any occupants. Thickthorn is green belt and a need for employment land here cannot be demonstrated.

Over estimated requirement.

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.

As new residents of Baginton, my wife and I would like to take a moment to raise a few objections in regard to proposed development plans for the village. We realise you will have heard these comments already from the Baginton Parish Council, but we just wish to confirm that we share these opinions and that we are concerned for the future of our community.
Local Plan - Revised Development Strategy
The Gateway is unsustainable and inappropriate development of the Green Belt with no very special circumstances. We agree with the BPC's request to remove references to the Gateway and associated projections from the Local Plan.
70-90 additional houses is far too big an increase for a village this size. The Localism Act should be considered and the outcomes on the Parish Plan and Housing Needs Survey should be used to gauge additional housing requirements.
Gypsy and Traveller Site Options (G101 and G107)
The proposed sites are (like the Gateway) inappropriate use of Green Belt land and we agree with the negative effects cited in the consultation documents. Amenities are not within easy reach and public transport links are inadequate. Three sites already exist within a few miles of the proposal, which therefore in its objective to distribute development across the district. The Stoneleigh Road site is privately owned and Smith's nursery is a well-regarded and popular local business, which would be unfairly impacted by this development. The other proposed sites to the south of Warwick are preferable because the issues outlined here do not apply.

I wholeheartedly agree with the ambition of making WD "a great place to live, work and visit" but I am not convinced that this Local Plan addresses the issues in such a way as to achieve that vision.
I therefore wish to raise my concerns regarding the new local plan. I am extremely conscious of the position WDC finds itself in but am very worried that this solution is driven by an urgent need for a strategy in the face of developer pressure against the backdrop of the NPPF.

1. Assumptions

I am not convinced by the ONS's forecasts for population. There should be a forecast for 2030 and another for 2050. Most economists agree that UK population will start to fall away mid-century.
There are only 4 options presented and each is exclusive of the other; there are no options presented which are simple or complex hybrids. This is narrowing the choice unnecessarily when a hybrid plan may present the best compromise / optimum mix for all.
The options do not fully consider the needs across district or borough boundaries. The RSS Core strategy in 2007-10 looked at the wider picture and sought to find regional, more balanced solutions. By looking at numbers individually by District or Borough, our choice of options is dramatically reduced and does not consider the impacts on surrounding areas. These artificial political and authority boundaries are not considered by business or residents. As a parallel, in the past Fire Services looked only at the provision of service within a County boundary...clearly this is inappropriate when best planning a reactive service, particularly in rural areas, to avoid duplication eg N Warks / Sth Leics.

I see that there is now a Joint SHMA following the intervention of the Planning Inspectorate. Surely a Local Plan cannot be fully considered through consultation until this has met and made broader, more fully fledged proposals that meet the needs of the wider area and so avoiding duplication and ensuring more joined-up thinking? And what is the "new information" that has come to light?

Finally, when the Plan refers to 'Sustainable Communities', what is is meant by this? Very seriously, a definition is required to know what is being spoken of. Does it mean a community feeding itself, travelling within its own confines, providing its own energy and water needs? Please provide.

2 Housing

The primary determinant for the preferred option seems to be to avoid building on the Green Belt even though elsewhere WDC and Coventry CC will allow industrial development on the Green Belt. This is surely not a principle. Whatever guides the decision-making should be consistent and coherent. If one is permissible, then so should the other.

The notion of the primary employment site being planned at Baginton / Coventry Airport whilst 70% of new housing is proposed south of Warwick and Leamington doesn't seem to make sense

And "The apportionment of housing was guided by the principle of....avoidance of coalescence of settlements". The option proposed for suburban peripheral development to Warwick and Leamington would guarantee that the two in fact would become symbiotic twins with no green buffer separating them.

I would like to have seen a 'HYBRID 5' option being proposed that included elements of options 2, 3 and 4.
I believe in particular that the development of a new town, in the mould of the Eco-Town once proposed near Ettington a few years ago, in South-central Warwickshire would be the best solution to our collective needs. Sites such as the former Royal Engineers depot at Long Marston would have been perfect. I also believe that further expansion of Southam would make sense regionally.
Other villages such as Leek Wootton and Hatton should be expanded more than proposed given a) their size, b) their available land c) their current lack of village services and d) their proximity to the A46 corridor and Warwick and Warwick Parkway train stations. Hatton currently has next to no services and amenities: how was it allowed to be so?

Despite the huge impact on the area, the matter of HMOs and students seems to get little coverage or perhaps I have missed something in the documents. Given the sale of the issue, the Local Plan should address how in future it expects to balance the town between long-term residents and students etc. I would advocate more block development and place a moratorium on the conversion of existing housing stock: there has been a great surge in the number of terraced houses converting to student occupancy which has reduced the availability for young home-makers and families. Surely this is placing an additional burden on the housing shortage being faced in Warwick District. I would urge that WDC considers the conversion of Riverside House and the Fire Station to student blocks with the Council retaining 51% ownership of the sites for future revenue generation.

3. Economic considerations and Employment

I cannot see where in the document it speaks of the additional employment lands other than at the Gateway site.

In fact, worse still, the mention of a Reduction in employment land on industrial estates in Sydenham, Cape Road, Montague and Common Lane would be to the detriment of low skilled work forces throughout the area. Currently such workers are able to walk / cycle to work. this will not be the case in the future as these sites are sold off for housing. By insisting on maintaining the land as industrial, the land value will fall and then become viable for future industrial use; if the land value rises then this will be impossible in future.

The document speaks of " a need to provide new employment land in and around the District's main towns to meet local needs and encourage the creation of new jobs". Completely agree with this but have serious reservations about the viability and robustness of the Gateway project to deliver the number and quality of employment it is promising. In fact, the notion of a business park by the airport would suggest that this is really a giant logistics park by stealth when the former Ryton car plant site is a ready made brownfield location for such business. If I recall, such an application was made some years ago but turned down by Rugby BC. Using Green Field and Greenbelt land to provide such business seems wrong on all counts therefore.

I do not see how the expansion of the Warwick Technology Park is going to help low-skilled workers find jobs. It does not make sense.

Further, the document details the need to "support the rural economy"; this is really important but only touched on. The entire viability of villages is threatened in future with the withdrawal of services from them (the closure of post offices / pubs, small village stores, even primary schools etc..)

4. Infrastructure

The document speaks of an emphasis on infrastructure - "the development of sustainable communities with strong local centres / and or community hubs". As above, the rural economy is very fragile and villages need greater support if they are to remain viable. Rural bus services will become more and more threatened unless the villages served have sufficient mass.

I don't understand how having the major employment site to the north of the district and the housing tithe south will not lead to massive congestion in the town centres of Warwick and Leamington. This does not make sense.

5. Sustainable

See point 1) above. To re-iterate, what is really meant by sustainable communities. It is important to be clear on this point to avoid accusations of 'Greenwash', but it is similarly important to ensure the best, most durable and sustainable communities are created, it just for 2029 but for 50-100 years from now.

The coalescence of Warwick and Leamington does not seem to support a better environment.
The document states that "..ensuring new development is based on principles of sustainable Garden Towns, suburbs and villages" is key however it is not fully explained how this may be achieved. Urban centres have an optimum mass but this is not explored. Likewise, their interdependence is not explained; creating an hierarchy of primary and secondary villages is welcome but this needs to be examined in depth as to implications for the main settlements.

Section 3.4 para 17 talks of contributing to conserving the environment by "....reducing pollution" yet this is not supported with any evidence or data. The development of south Warwick and Leamington would surely have quite the opposite effect.

The document speaks of "caring for our built, cultural and national heritage" which is laudable and right. But the strain on Warwick and Leamington town centres by the addict all 'peripheral residential development would be at odds with this aim.

There is no reference to Building Regulations or the greatest ambition of all, namely, to build 'Passivhaus' dwellings for all new developments between now and 2029. It is possible and should be our goal.
Cycle routes are mentioned only on passing. They should be a key factor in new transport planning to / from town centres and stations / transport hubs.

In summary I have major reservations about this Plan. It appears fundamentally flawed in its assumptions, its siting of housing and its assumptions for employment in the north of the District and not in the south. Foremost, I have grave concerns about the lack of infrastructure, in particular for roads and transport in general to support such number sof homes around the periphery of Warwick and Leamington.
These two towns are very unusual in that they have three barrier to the passage of people and traffic. From north to south and vice versa: a railway, a river and a canal. As such, in Leamington, there are just three narrow single carriageway routes joining the two halves. They will not be able to support any increase in traffic. And in Warwick their is the medieval town and castle to navigate around. What is already a nightmare for pollution will only become worse.

This is not a plan to deliver "Sustainable Communities and Development".

I urge you to reconsider urgently before these towns are forever destroyed by the short-termism forced on WD by developers and the NPPF and the Localism Bill.

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.

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I am a Bagington resident and object to the proposals in your consultation document as follows:

1 Gateway Proposals The erosion of Green Belt that would be occasioned by this development does not seem to be justified by exceptional circumstances. The case has not been made for the necessity of a distribution centre of the size proposed. It is important that Green Belt be preserved, especially round a village so close to Coventry city.

2 The number of new houses proposed is completely disproportionate to the size of Baginton village. A smaller number (e.g. no more than 20) would be acceptable and contribute to the sustainable viability of the local services without adversely affecting the character of the village community.

3 The proposal for gypsy and traveller sites within Baginton parish boundary would seriously affect the Green Belt and again needs justification given the close vicinity of three other sites within a few miles. The proposal to create a site on private land adjacent to Smith's nursery and requiring part of their land is unfair and unacceptable.

4 I believe the options of traveller and gypsy sites south of Warwick district would help to spread the load and minimise the affect on local businesses.

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I object strongly to The Gateway and the totally unsuitable development of Green Belt land. In no respect should this project be given credence in the light of unfounded promises of boosting employment numbers and eroding such large areas and blighting the land. Please take on board the BPC concerns and see less commerce £ signs and a more balanced view of the benefit of such a scheme. In light of so many industrial units being empty in and around Coventry and businesses crumbling daily, it seems preposterous for more green belt land to be taken forever and lives and homes ruined.
Where extra housing is also concerned, please take into account the lack of transport, amenities, schools, doctors are a-lacking in this area and a small village can only take so much. 70-90 properties is extreme. A small number as was built in Andrews Close would be acceptable, but no more. Farmland and people's properties would have to be purloined to accommodate to high numbers. If there is a good infrastructure to support such changes then they should be considered but not until.

I object to the Gateway and Housing Strategies for Baginton Village.

Inappropriate development for Green Belt Land and its environmental and community impacts.
The Gateway scheme does not enhance or improve the area and would have far-reaching negative impacts on local communities and the environment. The proposal is deeply flawed in content and sustainability. THis proprosal should be withdrawn.

The proposed extra houses could number 70-90 is too high a figure for such a small village. There is an acute lack of land and amenities for such a development. More Green Belt Land? Where's the services, transport, shops, schools, doctors etc? An acceptable small number could be accommodated but a limit to around ten.

Both schemes unsustainable and the Green Belt should be protected. Last year there were approx 72,000 empty homes in the W MIdlands and 64,000 in the E Mids. Why aren't they being renovated and re-used...why more erosion of green belt and small communities?

Employment Land Allocation in WDC's Draft Local Plan
RDS6
I suspect that that you will have lost most commentators on this one. Patently, there is already a gross over-supply of employment land available, so how is it that WDC can possibly have come up with any credible logic in an attempt to bolster the unsupportable assertion that there is a lack of employment land available ?
The only reason that there is any question at all regarding the amount of employment land available is brought about solely by WDC's unjustifiable, idiosyncratic, and frankly bizarre, assessment of their Employment Land Requirements. This inflated guesstimate of "requirements" miraculously manages to turn a proven and substantial over-provision of employment land into an unjustified deficit. As a result, your policy RDS6 tries to claim that an additional 22.5 hectares of new employment land needs to be set aside between 2011 and 2029. What is particularly annoying (and under the circumstances, ludicrous), is that most of this "requirement" will of course be provided by our ever-dwindling reserves of green-belt. In the latest Sunday Times, there was a long article about a current government backbench revolt concerning this very matter - of needlessly, thoughtlessly and unjustifiably squandering valuable & irreplaceable green-belt.
Your Table 4, in section 4.5.7, is entitled "Calculating the employment land requirement" and this apparently attempts to justify the fantastical and fatuous deficit claim :-
The Supply Demand Balance Hectares
Demand
A. Net Employment land requirement 2011 - 2030 36
B. Margin to provide flexibility of supply 16.5
C. Potential re-development of existing employment areas 13.5
D. Total gross employment requirement (demand) 66
Supply
E. Completed employment land since 2011 0.47
F. Current available land supply 48
G. Total gross employment land supply 48.5
H. Balance to be allocated 17.5 (15 - 25)
Subsequently, in section 4.5.8, you take the 17.5ha of the last item H. ("Balance to be allocated") and arbitrarily and randomly inflate it by a completely unjustified 5ha (a 29% increase !) to 22.5ha in order "To allow for flexibility and the assumptions used in modelling and forecasting".
What on earth is the 16.5ha of item B. ("Margin to provide flexibility of supply") designed for IF NOT "To allow for flexibility and the assumptions used in modelling and forecasting" ?
The stated reason for adding in this unjustifiable 5ha has already been taken into account within the definition of item B. It is ridiculous for WDC to double-bubble this figure by re-including the same thing again. Presumably this is a try-on designed to artificially inflate these numbers to suit WDC's aims over those of its ratepayers and parish councils ? The whole rationale behind "a margin of error" is that it is a plus or minus figure - it can go up or down (and should be thus marked) - but in WDC's case, it only ever works in the one direction - and that is always to the detriment of our environment and green-belt.
What is even harder to take is that you then add to this nonsense by attempting to claim that "it is reasonable to provide an additional 22.5 hectares of employment land" ! Certainly, in this particular case, under no circumstances whatsoever is this a "reasonable" or a justifiable thing to do. This claim is an entirely false construct, based on an entirely false premise, and it is entirely and demonstrably unreasonable.
This becomes an even more blatant attempt at distorting the truth when you consider that the 16.5ha of item B. ("Margin to provide flexibility of supply") is already an enormous 46% margin over and above requirements - being the 36ha of item A. ("Net employment land requirement"). Adding in WDC's newly dreamt-up double-accounting 5ha (thus effectively taking item B. up to 21.5ha) instantly inflates this already huge "margin of flexibility" up to 60% ! If WDC cannot operate without allowing margins of this order of magnitude, then something is dreadfully wrong with the forecasting at Riverside House.
We cannot afford for Warwickshire's ever-diminishing green-belt to be squandered in such a wasteful, unaccountable and profligate fashion. Rather than the 16.5ha to 21.5ha that WDC currently propose, a much more reasonable, justifiable and acceptable item B. ("Margin to provide flexibility of supply") would be around 1.8ha to 3.6ha (5% to 10%), but certainly no more,.
There is a further item which is of major concern within the current plan, and that involves taking areas previously identified as "Employment Land" out of that use, and instead allocating them to WDC's vastly excessive and wasteful house building plans. I am aware that this attempt at a gross over-provision of housing within the current plan is being dealt with - as a matter of some urgency - by a large number of local and parish councils, and I would just like to comment that I completely agree with their criticisms and arguments.
This is also a matter which is deeply implicated in the arguments within your Table 4 (above). There, on the "Demand" side of Table 4. we find 13.5ha of land is identified as item C. ("Potential re-development of existing employment areas"). Yet again, this figure has been brought about solely because of WDC's convoluted but erroneous logic. It is only necessary to include it now because of the unjustified and arbitrary "change of use" of existing employment land to housing use. Subsequent sections spell out in detail how WDC are in fact planning to remove a total of 19.5ha of existing employment land, in order to replace it with 13.5ha of new employment land elsewhere.
However in section 4.3.9, and despite the use (twice) of the word "some", and the specific inclusion of "and employment use", nowhere in this section does it mention WDC's actual intention, which is to take all of this land out of employment use. Employment land should be redeveloped as employment land - as was intended and envisaged originally. We are left to conclude that WDC are themselves not convinced that the demand for employment land is there. Certainly your previous attempts at justification for this topic (Gateway) are terminally weak (as we hope a planning inquiry may soon demonstrate).
It is completely unacceptable to take brownfield land out of employment use and then immediately replace it with employment greenfield land, especially when much of this will be green-belt land.
RDS7
It is completely unacceptable to then use this counterfeit deficit (detailed above) in an effort to go on to attempt to justify developments in RDS7 (section 4.6) of 14.5ha of new employment land in the green-belt, being Thickthorn (8ha) and a chunk of "the employment site of sub-regional significance" (6.5ha). The "employment site of sub-regional significance" being part of the "coalescence" that is the Gateway of course (itself being a part of the abolished RSS RIS).
RDS8
The RSS provisions continue to march forward within WDC, much like zombies - despite it being abolished by the government quite some while ago now. The so-called "Sub-Regional Employment Site" in this section is clearly still the RIS of RSS "Coventry & Warwickshire Regeneration Zone" fame, but merely with a change of name. As part of the "smoke and mirrors" that pervades this document, the vague, business-speak appellation of "Sub-Regional" is never actually explained, defined, or proven to be necessary - why not ?
Surely, any valid definition of a "sub-region" would include at least Coventry, Nuneaton and Bedworth, being the area with the worst employment problems, which MIRA is ideally set up to help to solve due to its geographical proximity to the problem.
In contrast, RDS8 appears designed to work counter to any hope of employment expansion since it will take jobs away from these areas of greatest need and increase still further the excess of employment land in WDC's area. Additionally, it will also increase travel by car from towns to the rural area to be blighted by this development, thus scuppering any chance of the urban regeneration which the area is crying out for.
All the previous economic/employment forces in this area have clearly been usurped by the undemocratic CWLEP with its still outstanding and unanswered questions about corporate governance - including the role of the Chairman of the LEP. It was noticeable that at the Scrutiny Committee meeting on 9th July, Cllr. Caborn (apparently acting as the CWLEP's cheer-leader) flatly refused to answer Cllr. Dhillon's perfectly logical questions about this matter. What an affront to democracy WDC and the CWLEP is turning out to be, with what appear to be cosy cabals apparently operating with impunity and able to dodge important issues raised by elected representatives.
It is also notable that within the "Revised Development Strategy", dated May this year, section 3.5 covers WDC's sustainable development principles, which includes "avoiding coalescence". However, the current plan directly contradicts this supposedly "sustainable" aim, as the (abolished) RSS based RIS - the "Sub-Regional Employment Site" (Gateway) - will be directly responsible for the coalescence of Baginton merging into Coventry, and to a degree Bubbenhall as well. Furthermore, the Thickthorn housing development (and its employment allocation) will of course dramatically reduce the already vanishing separation between Kenilworth and Leamington.
By leaving existing identified areas of employment land alone, and employing reasonable and common-sense assessments of the levels of flexibility and error-margins required, there is already more than enough employment land available to WDC, without having to undertake further development in the green-belt.
The NPPF requires planning to "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the green-belts around them". Policy RDS8 fails this test on every level, and it should be removed.
The employment land proposals within the New Local Plan (RDS6, RDS7 & RDS8) are not coherent, necessary, or sustainable. They should all be removed.

see-attached

Dear Sir or Madam

I wish to make the following comments on the Local Plan bearing in mind the significant development that has already taken place in Warwick over the last two decades, namely Hatton Park, Chase Meadows, Benfords site, Warwick Gates and Myton Road (old school site).

The local plan is suggesting significant further development of the town, which would potentially increase the size of Warwick by approximately 40% and yet little attention seems to have been taken into consideration the already poor air quality experienced in the town centre, which would be further adversely affected by the additional traffic generated by such development, which seems to suggest that traffic would be concentrated on the Castle Hill area of the town. The proposed changes to the infrastructure of the town seems to be based solely on providing additional traffic lights and by reducing access to a thoroughfare at the St John's end of Smith Street. The traffic congestion which already exists in the town, particularly at peak times is an issue now, let alone having potentially more traffic directed through the town in future years. I understand that a report is due shortly on the air quality of Warwick town centre, and so I think it regrettable that the District Council would put forward such development without having first knowledge of the outcome of that report.

Development on the scale proposed would have significant impact on services such as schools and hospitals. It was suggested at the public meeting held at Aylesford School that the District Council were in discussion with Warwick Hospital and the County Education Department about the provision of additional services. We have all read in the press about problems at Warwick Hospital A & E Department being able to cope with current demand, and as the hospital site has already been developed to its maximum potential, I fail to understand how it can be suggested that the hospital could cope with the impact of providing care for potentially a 40% increase in the size of the town and surrounding district. It was suggested at the Aylesford meeting that to cope with the additional demand for school places, that Myton could expand, and yet you only have to attempt to travel along the Myton Road now between the hours of 8.15 am and 9.00 am and 3.15 pm and 4.30 pm to see that the current road is frequently blocked with long tailbacks of traffic caused by school traffic both from Myton and Warwick Schools. Any such expansion of Myton School would have an impact on the infrastructure and yet this does not seem to have been taken into account.

With regard to the plan for the proposed traveler sites, it strikes me that all the proposed sites are predominantly around Warwick, and this seems an unfair distribution, bearing in mind that there is a long tradition of using the Thickthorn site in Kenilworth for the annual traveler horse fair. That site is close to transport links (A46), close to schools, doctors, shops etc and would appear to meet more of the criteria that a lot of the sites suggested for Warwick. I fail to understand why that area of land at Thickthorn would be designated for employment use, when there is no history of employment use in that part of Kenilworth, and there would not appear to be a demand for employment land in Kenilworth when you take into consideration the change of use around Common Lane, Priory Road, Kenilworth from employment to residential.

All in all I think the proposed local plan reflects badly on the Council as an ill-conceived document, and officers and Councillors need to go back to the drawing board and start again, and come back with proposals which residents of the area would find acceptable. It is clear from the local press that there is strong opposition to the plan, and as a democratic country, Officers and Councillors should respond in line with local wishes.