5.6 District Wide Transport Mitigation Proposals

1) I am not aware of the STIRR campaign flows for 1971. However we do monitor flows at WCC and have reliable records using Automatic Traffic Count equipment. I have attached a plan showing site locations and the flow data which shows the peak period has remained fairly static but the shoulder peaks(0700-0800,0900-100,1600-1700 and 1800-1900) have grown, in some cases significantly. As the road network continues to become more congested this growth in the shoulder peaks will continue to occur at an increasing rate. I would also expect that the growth in housing provision during the period presented in this peak spreading evidence to be less than that proposed in the new Local Plan, WDC would have to confirm this. There may not have been material change in the traditional peak, due to the finite capacity of the road network in central Warwick. However this does not mean that there is the same level of congestion and impact on journey times. There is an increased demand for road space and this is spilling over into the shoulder peak periods, the requirement to cater for other road users through provision of crossing facilities at signals compounds this issue.

2) The areas identified as suffering from delay are the same areas that suffer today. I have not seen the document produced by the Warwick Society. However I do know that the WCC/ARUP Strategic Transport Assessment compared Local Plan growth against 2028 Reference Conditions (i.e. DfT Growth levels are applied proportionally across the network rather that allocated to certain areas, as is recognised practice in this type of assessment) and therefore a comparison is not made against today's conditions. It should be noted that the delay does increase in the peak as a result of the growth but maybe not to the extent that the public fear due to the finite capacity of the road network and the public's propensity to re-time there journey, avoid journeys and use alternative modes. It is the shoulder peak periods which we experience the most significant growth. MS002 plot included in the latest Strategic Transport Assessment on the WDC website which shows predictions for the 2028 Ref Case this will help in a comparison, in the town centre there doesn't appear to be a substantial worsening of conditions. I have also attached modelled and observed congestion data taken form 2011 (Observed based on DfT NI 167 data derived from satellite navigation devices) which highlight the existing congestion hotspots.

3) This is correct in terms of flow for the traditional 0800-0900 and 1700-1800 peak periods but not congestion for the aforementioned reasons. i.e. peak spreading resulting in growth at other times, meaning a higher total delay over a longer period which has a knock on impact on the overall levels of congestion - delay and journey times, compounded by the provision for pedestrian movements at signals and crossing. Furthermore, the propensity for some trips to travel within the peak hour is inevitable and, as such there will undoubtedly be an impact within the traditional peak hours. This growth is almost inevitable regardless of the approach to the allocation of development across the district. The delivery of the mitigation schemes in the area of the town centre is intended to alleviate some of the impacts of these trips which, if not successfully mitigated, could have the potential to cause severe impacts within the town centre. The purpose of the proposed schemes is to minimise the potential for these impacts to occur.

4) I do not have figures on how air pollution has changed over the years in Warwick, this is not my area of expertise. Air pollution is attributable to both traffic levels and the speed at which the traffic moves. During the peak period traffic is moving slower but levels may not have increased significantly, this trend continues through the local plan period. Additionally the growth in traffic flows and levels of delay in the shoulder peak periods does grow significantly and this will also add to the pollution issues within the AQMA. Again, public perception may well be that the impacts will be greater than the evidence suggests. One point worth noting is that without the improvements in Warwick Town Centre outlined within the STA, the impacts on delay are significantly worse, as such the air pollution will be considerably more. The potential for congestion levels to get much worse is limited during the peak period since the congestion itself is an indicator of a section of network reaching capacity. Growth in traffic will worsen conditions in the AQMA to a point and then the network will be saturated and air quality will decline substantially. The introduction of schemes reduces the rate at which the decline in air quality is occurring. Furthermore, as cars improve and become more environmentally friendly it could be argued that the quality of the environment within the AQMA is likely to be as much a function of the vehicle fleet therein as it is the levels of growth.

Although not resident in the centre of Warwick which I understand has pollution from vehicle exhausts already worse than legally permitted levels I live in an area close to the existing roundabout with Myton Road. I understand that it is planned to install traffic lights with additional lanes in place of the roundabout due to the anticipated increase in traffic if the Council's proposals as to development are implemented. As I understand it the air pollution not only in Warwick itself but at the proposed new traffic lights and along the nearby roads will be worsened.

Furthermore I walk into Warwick on a regular basis as do a number of other residents in Bridge End and am concerned at the anticipated
increase in air pollution for pedestrians and householders generally. What steps are to be taken by the Council, advised by yourself, as to safety measures in relation to air pollution in Warwick itself and on the roads leading into the town and in other residential areas?

I object to the Council's proposals as to possible and substantial development to the south of Warwick and Leamington Spa in any event for well documented reasons put forward by many others but particularly on the grounds of health as indicated above. I await your reply to the second paragraph of this letter.

As a business owner, resident and current spokesperson for the Smith Street Traders Association I would like to express my and my fellow traders of Smith St our dismay at the current proposals.

Do you realise the impact to Smith St by placing a no right turn into St Nicholas Church Street? Obviously not, so I'll enlighten you.

Smith St traders depend on traffic flowing down the street as there is very little footfall.
We depend on cars coming through so that they can park on the street or to discover us on route to their destination. If vehicles and it's passengers have come from the West side or even the South west side (Banbury Road) how can they possibly get back from Smith St if they can't turn right into St Nicholas Church St to get back to the Castle Hill roundabout and then turn left or right to get back home or wherever else they have come from?

This change would absolutely discourage potential customers coming to Smith Street as their will be no way back. Potential customers will have to proceed down into St Johns and Emscote Road, do you then expect them to turn around in the Sainsbury's Local car park so that they can get onto St Nicholas Church Street and get home? Cars and the customers will either not come to Smith St or even Warwick if this scheme goes ahead. You will turn the street into an island of empty units as cars that carry the customers find an alternative way back to the West & south side of Warwick by clogging up The Butts as they proceed onto Priory Rd, straight across into St Nicholas Church St missing out Smith St altogether. This will be a disaster for traders and the town. Warwick's oldest shopping street, 100% occupied by independents decimated by flawed decisions by Warwickshire County Council.

The really bizarre thing about this is WCC recently invested £400,000.00 in Operation Footfall. A scheme which I successfully applied for funds to put in place a program to encourage people to come and shop in Warwick. Here you are with this proposal actively encouraging people not to come into Smith St with it's 60 odd business's. Just think of the rates that you will lose plus the investment in which Operation Footfall has made?

Within your plan document, page 64 you appear to be actively wishing to promote home shopping under the heading of "Smarter Choices" One word for this, 'Hypocrisy" when you have invested £440k in Operation Footfall.

I and the rest of Smith St Traders Association urge you to reconsider this flawed proposal in this area of Warwick.

See attached submission and:

I have very late in the day, been advised that the lower end of Smith Street is to have traffic control such that vehicles coming down Smith Street or Priory Road will no longer be able to turn into St Nicholas church Street and so back into Warwick and south on to Banbury Road.
If this is correct may I urge to think again about this as it would cause endless frustration, and extra traffic in the Emscote and Coventry Roads as vehicles seek somewhere to turn aroun to access St Nicholas Ch St.
I have been unable to locate this proposal on the plan,however may I urge to think again.

Just wanted to confirm my complete agreement to your concerns raised,

Having spoken to most retailers in Smith Street all confirm without parking bringing people to the street their business would be at risk, period.

I wish to ask the question where is the common sense in making St Nicholas St. a two lane route taking traffic up to the roundabout and pushing through the high st. and the obvious chaos within the town centre.
A different approach is required, Priory road would make far more sense to reverse the one way and divert traffic away from the town centre, this would also allow a left turn at the base of Smith St.
and allow visitors to park at the NCP car park, and making best use of an unpopulated street thus leaving St. Nicholas as it is.

The above mentioned plan would perhaps require a mini roundabout at the base of Smith St. and St. Johns. but remove the reason to route via Jury St. & the High St. unless visiting the actual town centre,
and dare I say support visitors in parking and therefore local business.

As an independent business owner in Smith Street Warwick, I feel compelled to express my horror and dismay at the traffic proposals I have seen put forward for Smith Street.

In this tough economic climate and constant uncertainty about the long term future of the 'High Street' I can only imagine that these plans will be the final nail in the coffin for the future of Smith Street and many of it's businesses, all of which are owned independently. If the proposed prevention of a right turn from Smith Street into St Nicholas Church Street is implemented, cars will simply avoid Smith Street, if they are unable to go back the way they have come ie. back to the Castle Hill roundabout. It is difficult to imagine where the traffic will go - Emscote Road, Coventry Road or maybe the intention is to prevent traffic using Smith Street altogether, but not only will this have a negative impact on businesses there, it will also create significant traffic congestion in other areas of the town. At peak times, Warwick already gets extremely congested. The traders of Smith Street rely on traffic flowing down the street as this enables existing customers to visit and for new ones to discover what is on offer as they pass through. Without this constant flow of traffic, customers will go elsewhere and go to places that are easier to get to. This will be a total disaster, not only for Smith Street, but the town as a whole. Many people visiting my shop tell me they love to visit Warwick to have a look around all the lovely quirky little shops - Warwick, they say, is different from so many of the other 'High Streets' - it has a unique feel because it doesn't have all the leading high street names making it feel that you could be on any high street, in any town. Smith Street, the oldest shopping street in Warwick will be deserted if these plans are introduced.

It seems odd that only recently, WCC were supposedly supporting an increase in footfall for local businesses, with significant funding for 'Operation Footfall', an initiative aimed at encouraging people to shop in Warwick and now a few months later the same people are proposing to implement something which will completely discourage people from visiting Smith Street and it's many and varied businesses. Why?

I would please urge serious reconsideration of this proposal which will have a catastrophic effect on Smith Street businesses if it goes ahead.

As a business owner of 14 years, and a member of Smith Street Traders Association, may I say how distressed I am with some of the proposals that have been put forward as part of the new Local Plan.

The one that is of primary concern is the right turn at the bottom of Smith Street into St Nicholas Church Street being prohibited. If customers come to us from the other side of Warwick, the Banbury Road or Stratford, how are they supposed to get back? There is no other option without a massive diversion through housing estates, or going as far back as Leamington and returning along the Myton Road. If this plan goes ahead, Smith Street will become a vacant island as the difficulties in exiting it outweigh the benefits of shopping there. Considering that this is the only street in Warwick that is solely occupied with independent traders, it should be nurtured, not neglected. Too often towns are clones of one another, and finding an area that is unique and flourishing is becoming increasingly difficult. Please do not enforce proposals that will make trading harder in already uncertain times.

Ironically, I believe £400k was recently invested into Operation Footfall. It seems odd that a scheme to attract people to shop in Warwick should then be negated by a plan that will essentially prohibit customers from one of the busiest shopping areas in Warwick.

I would ask you to please reconsider these proposals, and respect the local knowledge and consideration of the traders in Smith Street.

I live in Bridge End, Warwick and I am very concerned that your new local plan is going to make life very much more difficult for me and my neighbours. Some examples of the sort of thing that is worrying me are

1 I am told you are going to remove the pedestrian crossings on the
Myton and Banbury roads to make things easier for motorcars. But what about me - I cannot walk very quickly these days. And what about the children going to school: will the lollipop ladies have to go too?

2 I am also told that you are going to convert the Banbury and Myton
Roads into dual carriageways. Can you assure me that the footpaths will be retained and that there will be more, not less, cycle tracks.

3 At my age you worry about access for Ambulances and fire-engines.
Is it not going to be much more difficult for them to reach us? And what happens when traffic is diverted through Warwick when there is an accident on the M40. We have had grid-lock in the past and I am told it will be much worse in future.

Please give some consideration to my concerns. We don't all drive cars.

Having recently moved to Warwick (living near the town centre), I was surprised that the Local Plan fails to address the problem of traffic congestion in the town, and the consequent air and noise pollution and danger to pedestrians, be they locals or tourists. A long-term, strategic view needs to be taken and it seems to me that this is an opportunity missed. How about a 'Park and Walk' scheme for those coming to visit and measures to encourage others to drive around rather than through town?

Since there is a proposal for 'a major sub-regional employment site in the North East of the district' it appears very odd to site 3,195 houses South of Warwick, which almost inevitably will create huge volumes of traffic - the plan for which appears to be to direct it along the Banbury Road over the Avon Bridge through the town and out along the Coventry Road, presumably heading to the 'sub-regional employment site in the North East'.
It appears that the proposals regarding roads are to the benefit of traffic - easing as much through the town centre as possible...the document refers to 'a more attractive route to vehicles'.
An audit of current pavement usage? What about the current users of the pavements? Has the Local Plan taken into consideration the current numbers of pedestrians, cyclists, dog walkers, joggers, parents with prams and toddlers in tow, tourists photographing the castle, school children walking in groups to and from all three Warwick Foundation Schools and Myton School at key points during the day.
St Nick's park is really well used. Rowers and various boat users on the river Avon, walkers, joggers and children. Sea Scouts is based in the park. One of Warwick's most beautiful spots is the iconic view from Avon Bridge across to the castle. It's simply stunning. Lots of tourists congregate on the bridge to take photos; it is not a road that could/should take large volumes of traffic.
The Banbury Road needs to keep the pedestrian crossings. Numerous children cross there daily to get to school. There also seems to be a trend for office workers from Heathcote Industrial Estate to take a healthy walk around Bridge End at lunchtimes. People currently enjoy living and working in Warwick.
Traffic Noise/Pollution Warwick Prep School Playground for the youngest pupils is next to the Banbury Road (pollution levels? Noise in classrooms?) The Avon Bridge, St Nick's Park (which is extremely well used and visited), the Myton Road with its 3 schools, are not areas to try to increase the volume/speed of traffic. A Left filter turn into Myton Rd seems particularly worrying- a school girl broke her leg being hit by a car there around Easter time. To have a filter lane - which encourages continual movement - by a very large school seems absurd. A left lane filter would remove an area that is currently pavement and landscape and a buffer between school children and the numerous coaches and cars that turn there during school hours.
Green Belt Vs Historic Buildings? It appears that some previous plans did not progress due to concern for the Green Belt north of Leamington. The traffic will be increased in parts of historic Warwick, especially over the grade II listed Avon Bridge. Bridge End is a conservation area, the route along the Banbury Road is landscaped which is meant to reflect the tradition of Warwick Castle Park. The impact of additional signage and traffic lights on the historic vistas through the town centre would be detrimental.
If there is to be some increased housing in Warwick, such as that of the Myton Road, surely the priority is to ensure that children living in those houses can cycle to Myton/Warwick school and allow their parents to walk or cycle to work in Warwick/Leamington town centres. Therefore increased cycle lanes would be paramount to any green plan for the area.
There's nothing in the plan to benefit those people with shops and businesses in Warwick. The town centre needs a better parking plan. There is nothing to encourage the volumes of traffic to be directed through the town to stop and enjoy the things that Warwick has to offer.
Misguided traffic proposals. The idea to block one entrance of Bridge End is unworkable. Cars are invariably parked on both sides of the length of Bridge End and there are already occasional problems with deliveries. This conservation area needs to keep access for emergency vehicles, refuse collection and deliveries.
All traffic should be directed out of the centre of Warwick - not through the middle of it! It is imperative that any new houses based south of Warwick should have major road access to the by-pass/motorway or other links to major employment areas. The roads and buildings in Warwick are such that there will always be a maximum capacity however much tinkering goes on to 'improve traffic flow'. The town environment and historic nature of the area deserves much better than to make its roads the main priority.

I congratulate your officers if they survived the heat, in all senses, in Aylesford School Hall last night

Living on Emscote Road overlooking Coten End, I see daily traffic congestion.

I once drove to Scotland and the worst traffic jam on the whole route was in Coten End.

More houses are bound to lead to more congestion.

I understand the need for more houses but think the numbers in the Draft Local Plan are excessive.

I am writing to voice my objection and concerns about the revised development strategy.

Having attended several of the public meetings and discussed the proposals with representatives I feel that I must object to the current plan on a number of points.

TRAFFIC
It is widely known and accepted that there are issues with the traffic in the area around Europa way and the plan to develop up to 1200 homes within this area will generate a significant increase in the current traffic volumes.
I am concerned with the calculations and models being used to predict the expected increase in traffic as the numbers are significantly less than 1 car per household.
It is my understanding that a national model has been used to predict the number of cars yet t he average number of cars per household in the area is significantly more than this.
Much of the traffic mitigations are aimed at not making the current situation worse, and little has been done, or made public to validate the models being proposed. The recent junction changes for the new supermarket have not in my experience improved the traffic situation as the traffic lights mean traffic is forced to back up.

POLLUTION
There is currently a major health issue with pollution levels ABOVE the legal limit and and errors in the predicted numbers of cars adding to the traffic and the effectiveness of the traffic flow and bottleneck works will mean an INCREASE in this pollution health risk

FLOODING
During the recent periods of heavy rain, the cycle path and some houses newly built on the site of the old school have flooded.
This is with all the land off Europa way being farmland and hence available to soak away rainfall. The amount of water that runs off into the culvert is significant and building on the land will dramatically reduce the amount of soakaway and I am concerned that the current plans will not address this significant flood risk.
Should any existing homes flood after any development I would expect the council and or developers to be liable for any subsequent flooding and premium increases that may result.

There has been much discussion about improving traffic flow from the south of the leamington/warwick, indeed directing it around the towns. Surely it makes sense to actually build the homes to the North where all the traffic is heading.
It has been stated that land to the north cannot be built on unless there is no other places to build, yet the King Henry VIII land was protected from development, a condition of the building of the technology park and the council already has a legal obligation to resucr eht pollution - this surely will not be possible with the addition of all the extra traffic.

This plan proposes changes to the local area that have health and flooding risks that affect existing residents that have not been addressed or any mitigations adequately published.
I would need to see

1. A full independent health study on the pollution levels and the effects of increased traffic.
2. A review on the expected levels of traffic based on the currently demographic of the area and not a model that the council are allowing developers to use ( as quoted to me by a representative)
3. a full review of the flooding risk.

I do not know of a single home in the area that is not opposed to the proposed local development plan and I find it hard to accept that it will be pushed through given the clear issues that have not been addressed.

Hello,
I would like to register my objection to the New Local Plan.
I objected to the previous plan on the grounds it would do nothing but great harm to our historic town, and this latest plan appears to be far worse.

The traffic in the town at peak times and when there are issues on the local main roads is abysmal. The attempts previously have made it worse I am sure, and the latest plans look to lock down Warwick altogether. The town should NOT be for people to pass through and it should be made easier for the people of Warwick to move around more freely. Since the developments in the Technology Park came about, the traffic going through the town is much worse even when the plan was to deter people driving through. This has not worked and these new plans for the roads, together with the proposed nearby excessive housing plans will not only make it worse, I fear it could make to a non-reversible catastrophe.
Having not yet done anything about the pollution and air quality in the town, which is a considerable health issue now, these plans again will make things much worse.

I have no confidence in WDC or WCC in making improvements to the town based on the previous plans, recent attempts to change things and current situation in Warwick.

I recently attended a Community Forum event and am interested to learn
more about changes to one area in Warwick near to where I live.

At the recent community forum meeting I learnt that the council plan to
"widen the approaches" to Spinney hill roundabout. After talking to the
Council traffic planning officers no one was aware of what this would
entail and that recommendations are based on a traffic modelling
software.
When will plans be ready to view about the exact changes?

several issues seem to be missing from the plans and I would like to
draw these to your attention and request information and clarification.

Evidence - what increased traffic have you accounted for and where will
it be coming from and be going to?
What effect will widening have on the traffic and the surrounding
housing?
Is it possible to widen the approaches, have you surveyed already?

Cycle route- it is suggested in the revised plan that this would run
from the roundabout to the town centre, but no route was given. What
route do you intend to take?

As I understand the situation no pedestrian/bike crossings have been built into the widening plans.
Why not? Especially as a feasibility study for a crossing has been agreed for the bottom of Primrose Hill. Can I please request the revised plans are drawn up with the need for a crossing on the lower section of Primrose Hill to allow the safe passage of pedestrians and cyclists.

I am writing this e-mail to give my reaction to the New Local Plan as a major employer situated on the South side of the area.

One of the main needs of the business community is to be able to attract & retain quality staff. There is a lot of competition for qualified people who, whilst seeking a rewarding career, are also highly motivated by the quality of life. There is no question that Leamington & Warwick provide the potential for a very high quality of life, but the shortage of housing means that house prices are relatively high and unaffordable for many new employees. It is vital that the Council moves to implement a local plan with a sense of urgency to ensure the economy in the area can continue to flourish.

Business is also very conscious of the impact on the local infrastructure. Both Leamington & Warwick are very congested towns in rush hour due to the limited river crossings & the historic nature of the area. This is why all the business parks are located to the south of the area close to the M40 & A46 junctions. The location close to the centre of the motorway networks is attractive to business. It is vital, therefore, that the local plan ensures that the infrastructure supports the proposed developments & does not create unintended consequences elsewhere. I am writing to provide my support as a business leader for your latest plan for the following reasons:

1. The new housing developments will help attract the quality of the workforce required to maintain & grow our business in the future.

2. The developments are located close to where the employment opportunities are (to the South of Leamington & Warwick) thus providing an opportunity for people to live close to their work thereby reducing or eliminating the commute for many people with a consequential positive impact on the environment & their quality of life.

3. The prospect of access to a good local workforce will help to encourage more business to set up & relocate to this area, helping to generate more jobs & prosperity for the local community.

4. The proposals to improve the main access road, Europa Way, by making it a dual carriageway is vital to the success of the plan, and I would like to encourage the council to ensure that this is actioned at the beginning of developments in order to minimise the potential for long term disruption. This will also assist those will have to commute to access the major arterial routes more easily. In respect of this proposal, I would suggest that the council also considers improvements to the roundabout at the end of Europa way leading to the access road for the M40. This is already heavily congested in the morning and the evenings.

I would like to comment on the local plan,i do realise that more housing is needed the number being suggested however is unbelievable,as a bishops tachbrook resident i attended a meeting recently and when a representative was asked how the roads can possibly cope with such a huge influx of traffic we were assured a study had been done and indeed the roads could cope if improvements are made.Making the the Greys Mallory island larger and making Europa Way into a dual carriage way will help trafic along but it is still all going to finish up at the Ford island where it will back up for miles [has anyone seen the traffic backing up down the slip road to the motor way?]I suspect this is of little interest as the housing cannot possibly be just for "locals"[money for greedy developers]so it wil be for commuters going in the opposite direction ie.towards the motorway.I doubt whther this area would be anywhere near as attractive for development if it was not for the motorway,add to all this the already poor air quality being polluted even more our only hospital bursting at the seams ditto doctors surgeries where are the sick going to go?People live in villages because they want to live in smaller community and avery fine one we have here,we therefore do not want to be joined up to some sprawling suburb.there is something else that seems puzzling why is that it was origionally thought we needed 15 more houses in tachbrook and now it is
100 when there will be hundrds built little more than a mile down the road.to add insult to injury we also learn we are to take the lions share of the traveller sights around here[people are already worring about losing thousands on the value of their homes]it is a shame we cannot decamp to the north end of the town!it appears to be the favoured end.People here are very annoyed that they have been ignored when their way of life could be changed forever.


i am sorry that i ommited my name on my previous e mail however after attending the recent meeting i can only say that my concerns are jutified.There is no possible way that the local roads will cope with the huge influx of traffic,widening and improving will not stop the bottle neck at the fords island,this is not housing for local people we were told 50%is for migration 40% is for afordable housing isuspect few of the people allocated social will be from any where near leamington or warwick they will be people from coventry or birmingham and their councils either cannot or do not wish to house them,the bulk of the rest will probably go to immigrants.tachbrook has always had a wonderful community feel many people have lived here all their lives and enjoy a "village" life this will all end when we are all joined together in the suburban sprawl that is about to come thanks to the parks that will join us all up.I cannot understand the need for 100 new houses in the village when there are thousands being built a mile down the road!even people with family in the village cannot mind travelling that short distance.one of the proposed sites is behind holt ave the field next to it is one of those suggested for travellers!
do the council really believe people wil buy a house next to a travellers sight?
local people feel absolutely impotent-we all know that no matter how much we complain our way of life and peace of mind is about to be destroyed forever; surrounded by housing and land bought up by travellers who pay nothing whatsoever into the system and get everything out for free,the local school will have to keep several places free for their children (the ones they say do not exist)keeping local children out.All in all it is a very depressing future for people who have worked hard all their lives to see the fruit of their toil lose thousands off its worth and live in a very less pleasant and safe place.

Last week, Cycleways submitted its response to the transport mitigation proposals contained in the Local Plan.
In its response it referred to the government's White Paper on transport, and attached is a copy of the relevant pages, for your reference.
Later on in the White Paper, p38, it refers to the Sustainable Travel Towns project.
Even though this project has only been running for a few years it is already demonstrating a modal shift in travel behaviour, as follows:
reduction in number of car driver trips - 8%
cycle trips increase per resident by 26%
walking trips per resident increase by 13%
PSV usage increase by 14%
If one looks to London where a sustainable travel strategy has been in place much longer, the shift is quite dramatic when it comes to cycling.
The head of TfL surface transport planning, Michelle Dix, was recently quoted as saying that they plan to have as many commuters cycling to work by 2030 as those who use the underground.
In a recent survey conducted by City Hall in the City of London it showed that 49% of all vehicles passing along Old Street at the morning peak, were bicycles.
Turning to more local matters, Cycleways has prepared a draft cycle plan of the Warwick District embracing all three of its towns to show how the objectives set out in 5.6.3 of the Local Plan could be delivered. Here once again, the large scale plan of Leamington and Warwick that you supplied to us, was particularly useful.
With thanks

We have read the revised Development Strategy for the Local Plan.

We appreciate that it is difficult to plan for so much development and that not everyone will be happy with the plans.

Our objection has always been that green belt should be protected if possible. It appears the new plans recognise this is possible and we are pleased to hear this.

Since the majority of development is nearer the motorway, train station and now a large number of supermarkets - it seems far more sensible from an infrastructure point of view.

Also the main entry point to the north of Leamington is heavily congested most days and could not cope with a large increase of traffic.

We note the idea of changing the roundabouts on the Kenilworth Road to lights appears strange. Whilst not traffic experts, it would appear this would be very expensive to change, more expensive to maintain, incredibly disruptive to make the alterations and we don't think this would increase or improve the traffic flow. Whilst not perfect, roundabouts rarely cause fatal accidents since everyone knows to slow down whereas traffic lights on main roads tend to lead to occasional severe accidents when a driver accidentally fails to obey the lights.

Therefore we are very pleased to latgely support the new plans but urge you to reconsider replacing existing roundabouts with taffic lights.

I object to the Local Plan - Revised Development Strategy & wish this to be recorded formally & my further comments passed to the ultimate decision making authority

In summary,I believe the proposal is not sustainable on environmental, economic and social grounds

1. Housing needs - the assumption of business growth & housing needs are unrealistic given that there are already over 5,000 empty homes in Warwickshire, 5 business units on Smith Street in Warwick unlet, land next to Morrisons supermarket unsaleable to business & many business units in both Leamington & Warwick that have become unlet or charity shops because businesses are not viable, given the economic conditions. Furthermore, there are already a number of residential developments that have recently been built or started within close proximity of the proposed developments & they are still not sold or occupied. With the proposal for housing to be built near Lighthorne Heath, any possible increase in jobs for Jaguar Land Rover is already covered. As a result, the likelihood is that the number of commuters would increase as a result of more houses South of Warwick - putting more pressure on roads in & around both Warwick & Leamington train stations which is already high at peak times.

2. Car parking - there is already a shortage of adequate car parking space in & around Warwick. Despite the building of the Warwick Technology Park & the plan for adequate car parking spaces, currently over 40 cars are parking on the verge of Gallows Hill. Increasing numbers of cars because of extra housing will result in an even bigger car parking problem unless attractive alternative means of transport are provided. The current provision of a cycle path on both Myton Road & the Banbury Roads are not fit for purpose as they are not continuous & likely to lead to more accidents.

3. Environment - one of the main generators of income to the local economy is the success of Warwick castle. The views from Warwick castle would be significantly disturbed if the Local Plan were to be approved. The proposal to build houses on the land South of Warwick on Gallows Hill off Banbury Road would mean the green views from Warwick Castle would be destroyed - any proposal needs to be environmentally sensitive.

4. Gas emissions - the air quality is already over the guidelines in both Smith Street & Jury Street, Warwick. The Local Plan would result in a significant increase in car journeys & traffic congestion in & around Warwick (particularly on St Nicholas Street, Mill Street, Banbury Road, Myton Road & Bridge End) - what action is being taken to ensure the resolution of known & forecast air quality problems ? The significant detrimental effects on health & buildings as a result of the increase in gas emissions is unsustainable.

5. Traffic mitigation schemes - the proposed mitigation schemes will only result in complete chaos given that the Avon bridge can only have 2 lanes & so this will result in a bottleneck, particularly at peak periods & when there is a major incident such as a crash on the M40, roadworks, need for Emergency vehicles to pass. The accuracy of the the assumptions used to predict traffic flows need to be checked.

6. Safety of pedestrians (particularly the young, old & disabled) & cyclists are not properly considered in the revised local plan when taking into account their needs to cross roads & access shops, services such as doctors, schools & businesses. This applies particularly to Myton Road, Banbury Road, St Nicholas & Smith Streets - especially, given the significant number of residents & visitors & road users requiring access to Warwick Castle, St Nicholas Park, Warwick School, Myton School & Coten End School.

7. The importance of the Conservation Area south of Warwick, including Bridge End. What special measures are being taken to mitigate the impact of traffic & consequence noise & pollution on the conservation area in the light of its architectural, historic, tourist & environmental importance.

8. Infrastructure - the pressure on local services such as the hospital, education, social services & education is too great. They are already suffering. Furthermore, the drainage systems of South Warwick near & around the river already appear to be inadequate for current users.

Overall, the main practical problem seems to be the likely bottleneck of traffic on the bridge over the River Avon on the Banbury Road, Warwick. What is needed is a plan in which traffic is actively managed away from the bridge on Banbury Road - why is this not included in the revised plan when it is clearly needed ? and all traffic needs to be diverted away from the centre of Warwick. A super highway bypass is needed which would enable the plan to be sustainable & a major re- think of if & where new houses are really needed then perhaps land closer to Coventry or even North of Leamington would be a better balanced fit for a plan to be more sustainable on environmental, economic & social grounds.

Please will you acknowledge safe receipt of these comments & confirm they will be passed on to the appropriate decision making authority.

COMMENTS ON THE REVISED DEVELOPMENT STRATEGY OF THE WARWICK DISTRICT LOCAL PLAN - 2013
INTRODUCTION:
Because of having to be away from Warwick for the latter part of June and into early July it was only at the presentation at Aylesford School on 15/07/2013 that I was able to find out more about the "Revised" proposals. Unfortunately the presentation by WDC personnel on that night was less than impressive, the acoustics were bad resulting in part of the presentation not being fully audible and the attitude seemed to be, "this is what you are going to get so you will have to put up with it". It was certainly not a "consultation" process. However, having now been able to read the documents issued I will at least comment on the "revised" plan and the potential problems it will create if implemented. Also, as the forms provided for comment do not seem to give enough space to fully comment I am using this format to cover a range of points.
HOUSING PROJECTION AND LOCATION:
The projected figure of an additional 6.600 new houses seems excessively high and with a very large concentration of the same in the area immediately south of Warwick. That, in turn will produce problems with congestion and transport. Also, there does not seem to be any mention in the "Revised Plan" of those sites which have previously had planning permission but have not been developed. (There are a number in Warwick still not started). Nor is there any mention of the number of empty houses available for sale or for rent. Until all those numbers are included in the figures the true need for "new Build" cannot be fully assessed.
Also, it has been reported that Stratford District Council have approved a "draft" strategy to build a new 4000 home "town" in the Lighthorne area just south of Warwick. If that goes ahead it would also have some effect on the infrastructure requirements, (as mentioned below), within the Warwick Local Plan; yet no mention is made of that scheme has been taken into account when preparing the Warwick Local Plan.
ROAD INFRASTRUCTURE:
Much is made in the plan of the proposed improvements to road junctions, new traffic lights, etc. to enable traffic to move faster into Warwick & Leamington, but no solution is given to the problems caused when the cars reach the towns. Warwick has natural "bottlenecks" in The Butts, Jury St., High St., Smith St., Nicholas Church St. Friars St., Hampton St., and Theatre St. etc. etc. Unless those roads are widened, (by demolishing listed buildings!), or a new road around the town is built, there will be a massive congestion problem, (there already is). No solution to this is offered in the "Plan" and needs to be prior to any approval for new houses.
AIR POLLUTION:
Where we live at present, (on Friars St. and by Hampton St.), is already at, or above, the recommended levels, as is parts of the Warwick Town Centre. The revised Plan does not address this problem.
HEALTH:
Apart from the additional health problems that can be caused by any increased traffic congestion there is no mention of the capacity of Warwick Hospital to cope with a massive increase in population. The present hospital is surrounded by housing and cannot expand, can it cope with such an increase as is projected by the "Plan"?
SITES FOR GYPSIES & TRAVELLERS:
The need for such sites is recognised and the concept supported. Indeed it is needed to stop the current problems that occur when car parks and public parks are used unofficially and left in a mess. However, even a casual glance at the Plan shows a marked imbalance of the distribution of the possible sites over the whole of the District. Of the 20 possible sites listed only four are in the northern part of the District with the remaining 16 in the southern part, with the biggest cluster just south of Warwick. This should be re-examined to ensure a more equitable spread of the burden on the residents of the District.
CLOSING OBSERVATIONS:
The above points are general rather that specific but clearly indicate a need for a more "in-depth" approach to what the District as a whole needs. From the information provided the people who have drawn up the Plan do not seem to have considered all the facts nor how to overcome, or at least alleviate, the problems that will be created by placing the bulk of the predicted new dwellings into one main location. To gain the support and the trust of the residents of Warwick District more openness and consultation than in the past is now required. In addition, serious consideration should be given to giving equal protection to open land to the south of Warwick and Leamington as that given to the "green belt" area located to the north of the towns so that all the open "greenfield" sites can be considered equally and the load spread more equitably throughout the District.

Consultation Response to New WDC Local Plan Preferred Options Paper

I am writing to object to the proposal for 12,300 houses in Warwick District and nearly 4,000 new houses in Warwick. In objecting I refer to the National Planning Policy Framework which "aims to strengthen local decision making and reinforce the importance of up-to-date plans".

Population Growth

The NPPF states that there should be a clear strategy "taking account of the needs of the residential and business communities".

Why has the number of 12,300 been proposed which is higher than the 10,800 proposed in the Core Strategy and was strongly resisted by Warwick District Council at that time? The West Midlands Regional Office was vehemently criticised by WDC for producing these flawed and untenable figures. Your figures do not comply with WCC population figures and are therefore unreliable. A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause immense damage to the character of the County Town. Migration from other areas into Warwick's more attractive green environment has produced most of the population growth. The provision of more houses will encourage more migration and Warwick will no longer be an attractive area. The new Plan should cater for LOCAL needs not migration into the area. You have included figures to cover an increase in students but they should be housed near the Universities not in the District, especially in south Leamington. Increasingly high concentrations of students in certain areas is an issue of concern.

Regarding your assumptions on the demand for housing, given that more than 50% of national population growth has been from immigration over the last two decades, and the government has publicly stated it wishes to greatly reduce this future net immigration, why is Warwick District planning for an even greater level of growth over the next 15 years, than has been experienced in the recent past? Warwick District population has increased by 12% since 2000, which is approximately twice the rate of increase for Warwickshire, twice the national average increase, and over three times the increase for West Midlands. Warwick Councillors asked that the proposed development should be equitably distributed over the District but half of the homes proposed in the new Local Plan are south of Warwick.
Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and history has shown that the necessary infrastructure has never been put in place.

The NPPF (48) states that Local planning authorities may make an allowance for windfall sites in the five-year supply". 1,224 properties have planning permission or a planning brief at the moment and yet you do not appear to have taken these into consideration. This would equate to a two-year supply of houses. I do not believe our authority has identified and brought back into residential use the 300-400 empty houses and buildings (NPPF 51) to the extent they should have done. Not all empty homes have been identified. New planning laws now allow unused office space to be converted to housing and his should be taken into account in the housing projections.

We have not been given information on where the 'missing' 6,000 homes are proposed to be built. Why not? You have stated at Aylesford School that this has not been decided yet. How can we make informed representations without the full facts being presented in the proposed new Local Plan?

The validity of your forecast projections of housing need has been seriously questioned. Evidence submitted by Cllr. Ray Bullen demonstrates that there is a 5 year housing land supply. The last 5 year housing land supply document is dated November 2012. It is out of date. The NPPF 153 says the " Local Plan .......can be reviewed in whole or in part to respond flexibly to changing circumstances". Therefore the out of date 5 year plan should be updated immediately to take account of those changing circumstances.

Research by Cllr. Ray Bullen shows that only 5,400 homes are necessary for local need which allows for moving in and out of the area based on what happened in last 10 years (births/deaths/migration). 12,300 includes economic growth but if jobs don't materialise unemployment will rise. Unemployment is low 1.6% currently. We need a homes/jobs balance. If we are looking to build housing you then have to match employment to housing. There appears to be no current evidence of a demand for employment development schemes. Employment land currently available cannot attract employers so cannot justify building 12,300 houses, e.g. the lack of interest in office space at Morrisons. Where will we find employment to match housing? The large office block plan at IBM is now being used for housing (windfall site).

The NPPF requires 'sustainable development'. The three criteria of sustainability are environmentally, economically and socially sustainable. The development south of Warwick is not sustainable.

I believe that the only motivation for WDC producing such figures for demand is the income that will benefit WDC in New Homes Bonus, rent, rates, council tax monies etc.

Stratford-on-Avon is currently consulting on the possible provision of some 4,500 houses in Gaydon and Lighthorne and this would impact on the need for houses in Warwick District. Local authorities have a duty to co-operate but WDC have not had discussions as yet with SoA.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Green Belt

The NPPF (79) states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence."

An incredible 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

NPPF (88) states "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and I am objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. I would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

Stratford-on-Avon have said there are exceptional circumstances to develop on certain areas of Green Belt. Why doesn't WDC take same point of view? There is land available north of Leamington and in Kenilworth which is nearer to employment in Coventry and the Gateway.

Coalescence

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The current Local Plan states in para 9.11, "It is important to protect the areas of restraint from development proposals that could alter their predominantly open character. Their value and importance lies in their contribution to the structure and character of the urban area, providing open areas in and around towns and preserving open wedges that separate one urban area from the next." The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including owls, uncommon woodpeckers, roe deer and badgers. This green space also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on! The NPPF 109 states "the planning system should contribute to and enhance the natural and local environment by:
* protecting and enhancing valued landscapes, geological conservation interests and soils;
* recognising the wider benefits of ecosystem services;
* minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological netwoerks that are more resilient to current and future pressures."

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Yet your reason for allocating development on Green Belt, against the National Planning Policy Framework is that "there is nowhere else to build". This argument is totally flawed and I would expect the Inspector to find this Plan unsound on this issue.

The NPPF (17) states that planning should be "empowering local people to shape their surroundings."

Why has this amount of housing been proposed for South Warwick when the previous consultation on the Core Strategy produced a 97% response in overwhelming opposition to housing here (700 objecting to the Europa Way, Gallows Hill and Banbury Road area.. Why were those results not heeded when you devised the new Plan? These plans do not reflect the aspirations of the community as the Government intended in the Localisation Act.

Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk but you are proposing to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102)

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. You have received photographic evidence of flooding from properties in Myton Crescent and the Malins. When the Warwick Technology Park was created, there were severe flooding problems in the adjacent Myton Gardens. The field donated to Myton school as a restricted covenant playing field has proved to be unusable because of water-logging, demonstrating on-going water-management problems. Even more relevant to the Malins and Myton Crescent was the severe flooding in 2007 caused by the re-orientation of the water run-off flows and the disturbance and removal of top soil from the Round Oak School playing fields behind Myton Crescent. It was only after threats to sue the County Council that remedial action was taken. This consisted of a bund to capture excess run-off and a pump situated in the north-west corner to return water uphill into the drain near the Round Oak School. This action has proved ineffective and inadequate as run-off water has periodically flowed into the gardens most recently in October 2012 when the water level reached was only a few inches below the level of the electricity sub-station situated between 26 Myton Crescent and 1 The Malins.

The field at the end of The Malins slopes upwards from The Malins and run-off water from adjacent fields above and to the right and behind also flows towards The Malins and Myton Crescent. When there is a downpour on saturated ground, water flows quickly down, fills up the lower parts of the field and collects in the gardens of nos. 26, 28 and 30 Myton Crescent, and overflows into the gardens of nos. 3 and 12 The Maslins and towards no. 1 The Malins and the electricity sub-station. There is little indication that the seriousness of this flooding is being taken into account.

Ignoring flood risk is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere." The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

 
Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. They were then allowed to build more houses on the area allocated for sport/play area at CM. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Coventry Council should also provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

Infrastructure

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:

* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and

* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries, evening clinics and Saturdays to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost. The public sewer discharges to Longbridge Water Treatment Works. Severn Trent currently transport sewage from Longbridge to Coventry by tanker several times a day. They do not have the capacity now to deal with sewage at the Longbridge site and it is inconceivable how they will cope with sewage from another 4,000 houses in Warwick. How many more tankers will be required and at what extra cost?

Buses have not proved to be sustainable. The only service for Myton Road is one per hour and no-one uses it.

CIL

The NPPF (175) states "Where practical, Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan. The Community Infrastructure Levy should support and incentivise new development, particularly by placing control over a meaningful proportion of the funds raised with the neighbourhoods where development takes place."

You have not provided information on these charges at all. I do not believe that there will be anywhere near the amount of funding available from CIL to cover the above extra infrastructure needs, especially new roads, bridges, schools and hospital. The hospital currently is in crisis and there is no room to extend. Funding for a new hospital is in doubt.

Air Quality/Traffic

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

The Traffic Assessment commissioned states, "Schemes proposed within the modelling at this stage have not been tested to a sufficient level of detail to determine that they are the optimum solution" and "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"!

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 12,300 new homes, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?

The 2008 Air Quality Action plan for Warwick shows the very worst area being Warwick town centre and states on page 17:-

Policy ER.2: Environmental Impact of Development
"The environmental impact of all proposed development on human beings, soil, fauna, flora, water, air, climate, the landscape geology, cultural heritage and material assets must be thoroughly assesse, and measures secured to mitigate adverse environmental effects to acceptable levels. Local plans should include policies to ensure this takes place. The impact of existing sources of environmental pollution on the occupants of any proposed new development should also be taken into account. Ass assessment of environmental impact should take account of, and where possible seek to reduce, uncertainty over the implications of the proposed development. If adverse impacts cannot be mitigated to acceptable levels, development will not be permitted."

NPPF 124 states, "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

I request that a Health Impact Assessment will be carried out including air quality testing well before any Local Plan in its current form is approved.

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road, Europa Way, Castle Bridge, Emscote Road and Prince's Drive are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen. One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area. The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then put it in for development - why? Traffic would increase at the Butts, the narrowest road in the town and the no right turn plan for St. Nicholas Church Street would impact severely on the economy of Smith Street. Vibrancy of the town centre is important. Think about what the effect will be on people sitting outside cafés in danger of being knocked over and pollution from all the traffic being funnelled through Warwick. People won't want to shop in Warwick because they won't be able to get into the town. It will be the destruction of Warwick and the people who want to shop here. There will be an adverse affect on Tourism.

Parks

In the new Local Plan our parks will not be sufficiently protected from development by the old area of restraint policy we once had.

Historic Environment

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. We need an impact assessment to ensure its conservation. English Heritage have offered to help with this.

The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional." The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre. Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe" (NPPF 32).

Gypsies and Travellers Sites

Why are 15 of the proposed sites south of Warwick and only 3 north of Warwick?

Conclusion

You state that in 2026 Warwick District will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands that have developed and grown in a way which has protected their individual characteristics and identities....." In my opinion this could not be farther from the truth.

The above comments demonstrate that this Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable. I believe the Planning Inspector will declare it unsound, especially on the air quality issue. It cannot be justified as "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence" and it is not "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework." (NPPF 182)

This Plan should be completely revised taking account of the above, specifically reducing the numbers of housing proposed for Warwick.

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.

Conservation Advisory Forum
Comments on Local Plan Consultation Housing Sites

CAF Meeting 18 July 2013


* Scale of development. Concerns expressed about impact on Warwick . There will be a 40% increase in the population of Warwick which will have a dramatic effect on the existing settlement and on traffic passing through both Warwick and also Leamington along Europa Way.

* Sustainability. It is not considered to be a sustainable development rather suburban sprawl.

* Traffic impact . Significant concern expressed about the impact of traffic on the Conservation Areas in particular the increased use of Banbury Road and the need for upgrading of the road system and the impact on Castle Hill roundabout and the bridge over the River Avon which is a Listed Building.

* Increase in car usage .This type of development reverses the trend over the past 20 years a small scale infill and the reduction of car usage. These proposals will increase car usage which will impact upon the historic Town Centres, as all the sites are only accessible by car. This will have a roll on effect in terms of the transport infrastructure and will make everyone else use cars.

* Impact on cycling . It was felt there was no scope for cycling because of the intensity of traffic.

* Release mechanism for sites .The release mechanism of sites was questioned. It was felt that the present system will lead to sites being built on regardless of whether there is any infrastructure to support them. A staged approach is needed for any sites within the district.

* Impact on historic buildings .The impact of traffic entering the Town Centre will impact upon all the major junctions and will impact upon the Historic Buildings themselves and the setting of them.

* Thickthorn , Kenilworth .It was pointed out that Kenilworth did their own consultation and have come up with the Thickthorn site as the best of the options if we have to meet the five year housing supply.

* Infrastructure for Kenilworth . Kenilworth needs to have adequate infrastructure of eco houses and appropriately relocation of the various clubs that use the Thickthorn site before development commences.

* Integrated transport system. Kenilworth needs an integrated transport system with a proposed new station, each house being provided with two parking spaces.

* New Hospital .It was felt that to support the level of development a new hospital would be needed in Warwick.

* Transport mitigation measures .The impact of transport mitigation measures on Warwick would include a 3-4 lane Banbury Road development, traffic signals at Bridge End roundabout, effects on Listed Castle Bridge, gyratory system at the Castle Hill roundabout and traffic lights. All roads will have a greater amount of traffic; there will be significant effects on air pollution and the quality of air in the Town Centre. Congestion charges were suggested. It was felt that if traffic was removed completely the High Street shops would suffer.

* Station Approach site - it was felt that it should follow the SBD for that site.

* Student accommodation . It was felt that if more students were to be housed on Warwick and Coventry University sites this would release more houses in Leamington Spa for use by families and would reduce the housing need overall.

From reading the Revised Development Strategy leaflet and attending The Guy Nelson Hall, Warwick School on Monday 22nd July, I was made aware of the full extent of this plan and the negative impact it would bring to Warwick and Leamington Spa.

I live in Warwick, on Camel Close, off the Myton Road and have lived in Leamington & Warwick over the last 20 years and consider this the most beautiful region in the Midlands.

During my time here, I have seen many changes in the region and with some of the recent developments around the new Morrison's and ALDI stores, I can see that the nature of the surrounding town areas are becoming overly congested and normal day to day commuting becoming more arduous.

When looking at the website for Warwick District Council, I have read the comments from Les Caborn and struggle to understand the points being made, as there is several areas of contradiction:
"Councillor Les Caborn, the lead councillor for the Local Plan said "I believe these proposals set out an approach which will enable the district to continue to grow and thrive, at the same time as protecting and enhancing many of the things that make Warwick district a great place"
Interesting... By exponentially expanding the requirements for new homes, the infrastructure required to support this and socio-economic factors it brings will not protect or enhance our region. On the contrary, it can only been seen that these changes will threat the things that make this a great place to live.

He also says:
"I'm really pleased to be putting forward proposals that provide for some real improvements in housing needs, a new country park, opportunities for employment, as well as transport schemes, schools and community facilities. I look forward to hearing what people think of these proposals."
But what about improving the stock of potential homes we already have available? Would this not remove the issues of additional transport schemes required (which would only worsen the situation), burden on schools, hospitals etc?

When looking at the proposed plans, I have major concerns and therefore need to make an official objection on many levels upon why these plans should be rejected.

1. New Homes and Projected Volumes?
District Council proposal for more than 12,000 new homes to be built by 2030?
This is a staggering amount of new homes to be built. A detailed explanation is required to understand how this calculation has been made?
When looking at the overall census from 2001 - 2011, there has been a steady increase in numbers over that period. When projecting this into 2030, an expansion of 12,000 new homes is an exponential growth. How can this be? With the increase of jobs in the automotive sector, this still does not cater for this growth.
Therefore, it is requested that the calculation of new homes is made available to be verified and cross checked with other external bodies.
See section 158 - NPPF: "Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

2. Empty homes currently within Leamington & Warwick and existing brown field sites
Has the existing stock of empty homes and properties available for renovation within the Leamington & Warwick been considered? Would it not make sense to address the issues in the town to rebuild and improve these properties, which are currently abandoned and derelict? Would it not be advisable on a planning perspective to make good these properties and bring them back into a good condition and build up and improve existing areas given the infrastructure we currently have? Is this not more sustainable?
(See point 17 of the NPPF: "encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high
environmental value"
See point 51- NPPF: "Local planning authorities should identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and, where appropriate, acquire properties under compulsory purchase powers. They should normally approve planning applications for change to residential use and any associated development from commercial buildings (currently in the B use classes) where there is an identified need for
additional housing in that area, provided that there are not strong economic reasons why such development would be inappropriate " - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf


3. Empty Office buildings.
In addition to empty residential homes, is it possible to convert existing business / office buildings into a residential properties. Looking around Leamington and Warwick, there are many areas identified that have been unoccupied for several years. Given the economic climate, it is likely that these properties will remain empty and potentially fall derelict.

As per point (2) and (3), it would only be in the council's favour to allow these properties to be converted into homes, such that they can start gaining revenues for council tax!

In addition to this, I see that additional offices are also being suggested within the plan.. Why are the planners doing this? If we can't fill the existing office spaces around Leamington & Warwick, why are we building new offices?
If there is new offices being built, exactly how many people would it support, if all units were occupied..? Would it cover the additional people moving into the area?
Given the current economic state, it is likely for more offices to remain empty. Given this, if the economy took a further downward spiral in the next 10 years, it is likely that the ratio of unemployed to working people would also rise. How does that help the district to grow and thrive?
See point 51- NPPF: - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

4) Green spaces in Warwickshire
One of the many positive aspects of living in this area is the consideration given to green spaces, that makes this region so special.
When looking at the plans of south Warwick, a large area of green fields could potentially be lost due to the unnecessary expansion between Warwick and Leamington.
In addition to this, it is important to consider proper planning and restraint when converting green field sites to urban sprawl. The conservation of wildlife is becoming even more important, but no references has been made to this within the plans for the protection thereof.
Yes, yes.. I see that there is plans for a country park in Whitnash and Sydenham, but lets not forget, this area is already a green field site. How does overstating this on the plan actually improve the wildlife conservation in South Warwick?

In addition to this, one of the biggest assets in our region is Warwick Castle. Why is it that this is the biggest area of expansion.. This can only be described as wilfully irresponsible, which will ruin one of the things that really makes this a great place.
See section 12. Conserving and enhancing the historic environment of NPPF.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

5) Transport
Currently, the road networks around Leamington and Warwick are barely adequate to deal with traffic today. Most homes will typically contain at least 1 if not 2 cars.
If we draw an average of 1.5 cars per household, that will be an addition 18,000 cars on the road. If only half of vehicles travel through Leamington / Warwick during peak times, that will be 9,000 cars...
Expanding the region to deal with this extra volume will only create havoc during peak periods.
The plans show several 'Grade 1 Junction' improvements. However, the network is fundamentally flawed as there are key bottleneck's. All roads tend to lead through the centre of Warwick or Leamington.
Warwick is not able to further increase the flow of traffic due to the smaller streets. Leamington has several rivers and bridges. Access over these bridges are limited.
Therefore, making better junctions will not improve the situation when adding additional cars on the road.
How can this make our region grow and thrive? What will it do to our open spaces? How would this affect the current lifestyle that we enjoy today? How can our roads be safer with more cars on the road?
Have the planners considered this when building the plan? If so, what is their response to traffic management, other than making roads bigger / wider? (which we suggested does not solve the root cause).
With these issues of traffic build-up within the town, it can be seen that issues along the A46 and M40 will also arise during peak periods, adding to the problem.
See a link to an interesting article published by the Project Manager for Transport and Safety in York.
(http://democracy.york.gov.uk/mgConvert2PDF.aspx?ID=12475)

6) Air Quality
Given the traffic buildup at peak times, the schools and homes based along these main roads, it will be apparent that air quality will be affected. According to tests currently being undertaken, the air quality in certain parts of Warwick are not acceptable and increasing traffic flow by 9,000 - 18,000 cars.
What is the planners response to this? Again, is this responsible planning?
In addition to this, new research proves that air quality is linked to the higher risk of lung cancer and heart failure.
See the following link:
(http://www.guardian.co.uk/society/2013/jul/10/air-pollution-lung-cancer-heart-failure)

See point 124 - NPPF : "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf


7) Infrastructure - Schools - Hospitals - Water - Drainage
With the added demand placed upon schools, expansion of existing schools is required plus additional new schools to be built. What does this mean to the overall quality of the existing schools today? Are they able to adequately expand to meet this demand? Will they be over subscribed per classroom, such that the quality of education in these schools drop?
I have 3 children in Primary and Secondary education and this is a very important concern that I have. Taking additional demand in existing schools as well as building a new school will incur a huge investment, of which children's education could be compromised. How does the planned respond to this? What assurances can they provide, not only for children in the area, but also children who wish to move into the area?

Added demand to Warwick Hospital. This is a site which is set within a residential area. Is it possible to expand this hospital to cater for any additional 40,000 - 50,000 people? What is the planners response to dealing with this additional demand. Are there enough beds within specialist wards within the hospital to cater for this growth? (As point 6 reveals, with the added pollution in the area, additional demands may be placed on hospital services).

Water and Drainage is already something of an issue, as works have been carried out within the town to repair this. How would the additional infrastructure cope with this increase in capacity?
Also, would the building of these new homes be placed on any land prone to flooding? Is this something that should be avoided?

See point 162. - NPPF : " Local planning authorities should work with other authorities and providers to:
●● assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands; and
●● take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

8) Alternative plans?
Given that the expected number of homes appears to be excessive and not clearly explained within the notes, the majority of these new sites are south of the region.. Why? Has it been explored if some capacity could be shared in the north of the region?
The protection of green belt land has been discussed for the North, but this is something that I believe should be explored further. Is it not already possible for the local authority to change the use of this green belt for the north? Why has this not been explored? Why is the focus of all the development concentrated on the south?

Has the planning office consulted with planners in other regions surrounding Leamington and Warwick?
What other plans have been submitted in Stratford or Kenilworth districts? Are there other developments already going ahead that the planners in Leamington and Warwick don't already know about? Is there some planning duplication being made upon the number of houses being built?


As mentioned before, I am opposed to these plans and have described over 8 separate and individual objections.

I would welcome a response to the issues raised and a chance to meet and discuss further.

We write to support the Revised Development Strategy, which recognises that the exceptional circumstances to develop the Green Belt to the North of Leamington do not exist. Much of this land is used for agricultural purposes and it is clearly in the country's interest that we do everything possible to maximise home production. Recent reports have emphasised the possibilities of future world food shortages and we must be doubly determined to preserve greenbelt land, because once it is built on, it will be lost to the nation's larder for ever.

It is also very important to limit urban sprawl by preserving the limited green space between Leamington and Kenilworth, which distinguishes the area and avoids the prospect of Leamington and Warwick being merged with the West Midlands conurbation.

Specifically we support the Revised Development Strategy because it:

1. Has a fair distribution of new housing across the District.

2. Removes the proposal to build 2,000 houses on the North Leamington Green Belt. Through the better use of sites, only 325 further houses are proposed on greenfield land, as opposed to the proposals in the Preferred Options for the Local Plan published last year.

3. Proposes that a substantial proportion of the new development is located close to where there are employment opportunities (to the south of Leamington & Warwick), providing an opportunity for people to live close to their place of work. This is obviously a sensible approach and furthermore there is almost unlimited green space to the south of Leamington where the nearest town is Banbury.

4. Provides improvements to the road network south of Leamington to relieve the existing congestion and to cater for the new development. It is important that these road improvements are carried out as part of a coordinated plan that will reduce traffic movements, ease congestion and reduce pollution.

5. Provides for the necessary schools and other infra-structure required to support the new development.

We do not have the information to query the number of new houses included in the Revised Development Strategy, but we must always be vigilant in restricting house building to that which is absolutely necessary and avoid the concreting over of attractive, productive land, which is a key reason why people choose to settle here.

I wish to object to the local plan in the strongest possible terms

The projected housing need of 12,300 new homes to be built is much too high. Half this number will be sufficient to meet local needs. It is a complete nonsense to suggest that it is possible to forecast a housing need as far into the future as 2029. It is wrong to allocate greenfield land now based on this wildly inaccurate projection and once used the greenfield land cannot be recovered.
The National Planning Policy Framework requires the approval of sustainable development which meets an established housing need, but planning applications already made or imminent for much of the land meet neither of these criteria. A realistic forecast of housing need would mean that the District already has the required five-year supply of sites, enabling economic growth and matching the housing market.
The agricultural land between Warwick, Whitnash and Bishop's Tachbrook is an 'Area of Restraint'. Building on it would merge our built-up areas, turning them into a single suburban sprawl. This green space is as important as the Green Belt to the north of Leamington and Warwick, and it should be safeguarded just as strongly.
Transport: sprawling development is inevitably car-dependent. The transport strategy is car-based, just squeezing more congested traffic on to existing road network.

Air Quality: the already illegally dangerous pollution in streets in centres of Warwick and Leamington would be made worse by the increase in traffic. Noise and vibration would be constant, business would be damaged
The historic environment would directly be damaged by the increase in traffic and by building wide new junctions cluttered with traffic lights and signs at beautiful places: in Warwick at Bridge End, over the Castle Bridge, on Castle Hill, and at St John's; and on the approach to Leamington via Europa Way, destroying the first impression of the spa town.
Other Infrastructure: I understand that development would be conditional on it funding schools, and healthcare facilities. As a regular user of the local hospital I know that it is already grossly overstretched and I am very concerned that the funding and provision would be inadequate. There would also be risks to water supply, sewage and drainage.
There are better alternatives. Lower housing numbers which meet local needs, especially for affordable housing, instead of encouraging in-migration; the gradual release of land for development as demand grows; giving absolute priority to using brownfield and infill sites; building homes close to jobs and not mainly within 20% of Warwick District .

Unfortunately I was unable to attend the presentation of the Warwick Local District Plan on 15 July but I have had feedback on the meeting and am concerned that the Council are not actually listening to the residents of Warwick in respect of this plan. It sounds as if the meeting was less of a consultation and more of this is what we have decided will happen. I have serious concerns about the consultation process and the politics of the situation but will concentrate on issues that relate to the planning process. I have sent a copy of my concerns to The development Policy Manager at Warwick District council.

My particular concerns with regard to the plan are as follows:

HOUSING PROJECTION AND LOCATION

The projected housing need of 12,300 new homes to be built seems far too high for the area. While the National Planning Policy Framework requires the approval of 'sustainable development' which meets an established housing need, planning applications already made, or imminent, for much of the land meet neither of these criteria. A realistic forecast of need would mean that the District already had the required five-year supply of sites, balancing housing with employment growth and matching the housing market. I feel it is inappropriate to forecast so far into the future and to allocate greenfield land now. This will allow uncontrolled growth leaving developers to decide what to build and when.

Also, it has been reported that Stratford District Council have approved a "draft" strategy to build a new 4000 home "town" in the Lighthorne area just south of Warwick. If that goes ahead it would also have some effect on the infrastructure requirements, (as mentioned below), within the Warwick Local Plan; yet no mention is made of that scheme has been taken into account when preparing the Warwick Local Plan.

The land between Warwick, Whitnash and Bishop's Tachbrook is rural and agricultural and present policies respect this. Building on it would merge our built-up areas, making them a single suburban sprawl. The green land is as important as the Green Belt to the north of Leamington and Warwick and should be safeguarded.

I feel there are better ways of ensuring there is adequate housing to meet local needs, especially for houses which people can afford such as gradually releasing land for development as demand grows, giving priority to using brownfield and infill sites near schools, shops and railway stations, building homes close to jobs and co-operating with other local authorities, instead of competing with them for development.
ROAD INFRASTRUCTURE:
Much is made in the plan of the proposed improvements to road junctions, new traffic lights, etc. to enable traffic to move faster into Warwick & Leamington, but no solution is given to the problems caused when the cars reach the towns. Warwick has natural "bottlenecks" in The Butts, Jury St., High St., Smith St., Nicholas Church St. Friars St., Hampton St., and Theatre St. etc. etc. Contrary to transport policies, it would make walking and cycling less attractive, and would have serious implications for public transport. No solution to this is offered in the "Plan" and needs to be prior to any approval for new houses.

I feel the historic environment, which attracts so many people to Warwick, would be damaged by the increase in traffic and by wide new junctions cluttered with traffic lights and signs at beautiful places, e.g. Bridge End in Warwick, Castle Bridge, Castle Hill and St John's.

AIR POLLUTION
Pollution from vehicle exhausts in many streets in Warwick and some in Leamington is already worse than is legally permitted. The District Council is required to improve air quality, but the plan and its transport strategy would worsen it. Noise and vibration would also be constant, businesses and tourism would be damaged and the long-term health of residents of these streets would be even more threatened. The revised plan does not address these problems.

HEALTH
Apart from the additional health problems that can be caused by any increased traffic congestion there is no mention of the capacity of Warwick Hospital to cope with a massive increase in population. The present hospital is surrounded by housing and cannot expand, can it cope with such an increase as is projected by the "Plan"?

SITES FOR GYPSIES & TRAVELLERS
The need for such sites is recognised and the concept supported. However, even a casual glance at the Plan shows a marked imbalance of the distribution of the possible sites over the whole of the District. Of the 20 possible sites listed only four are in the northern part of the District with the remaining 16 in the southern part, with the biggest cluster just south of Warwick. This should be re-examined to ensure a more equitable spread of the burden on the residents of the District. Again, it seems so much protection is given to the green Belt and so little to our other green land.
CLOSING OBSERVATIONS
The above points are general rather that specific but clearly indicate a need for a more "in-depth" approach to what the District as a whole needs. From the information provided the people who have drawn up the Plan do not seem to have considered all the facts nor how to overcome, or at least alleviate, the problems that will be created by placing the bulk of the predicted new dwellings into one main location. To gain the support and the trust of the residents of Warwick District more openness and consultation than in the past is now required. In addition, serious consideration should be given to giving equal protection to open land to the south of Warwick and Leamington as that given to the "green belt" area located to the north of the towns so that all the open "greenfield" sites can be considered equally and the load spread more equitably.

As one of our elected representatives, I do hope that you will do all that you can to ensure that these concerns are addressed.

1. Infrastructure must be the primary consideration of any Draft plan and this appears to be ignored by the current proposals. The thoroughfares of Warwick cannot cope with the addition of further traffic. We already have a situation whereby all traffic from the north (Coventry), north-west (Kenilworth) and north-east (north Leamington) is funnelled into Coten End and St. Nicholas' Church Street. The facilities for traffic wishing to turn right into Coventry Road from Coten End are such that, earlier this week, the traffic lights had to change four times before traffic could proceed from Coten End into St. Nicholas' Church Street because of buses and heavy vehicles trying to turn right.
All of this traffic then meets up with further traffic at the southern end of St. Nicholas' Church Street. This further traffic represents all traffic from south Leamington and traffic from the south including traffic leaving the north-bound traffic of the M40.. This already creates major delays during the morning rush-hour and at school times. Traffic is frequently 'backed up' on Myton Road beyond Myton Crescent and on the Banbury Road beyond the Barford turn. To increase the amount of traffic entering Warwick without major road building would be criminally negligent. Having regard to the existing development, the only possibility appears to be a feeder dual carriageway between the A46 running parallel to the M40 between Junctions 15 and 13 with a dedicated access to Gibbet Hill.

2. I believe the population of Warwick currently to be about 32,000 but the construction of 12,300 new homes could well increase that population by more than 75% based on a family unit of 2.4.
What facts and information exist to show that industry, commerce and services can expand to provide employment for such an increase in population? If the sources of employment do not increase by such a factor then even more pressure will be placed on roads and public transport as these new residents commute over longer distances to and from work. Surely the sensible plan is to proceed far more slowly matching residential construction to employment needs.

3. The whole concept of community is being eroded and will be worsened by the proposed development. Certainly provision is envisaged for new schools but far more is needed in the provision of community facilities such as leisure centres, youth clubs, creches, churches, shops and services. I watched the development of the Clifton estate on the south-west side of Nottingham and the development of the Amington estate on the north side of Tamworth. These were disastrous with husbands having to use the sole family car to commute to work, being absent for long hours because of commuting time and not facilities for the wives and families left at home. Infrastructure and such facilities must be provided before land is released for residential development.

New Homes and Projected Numbers

I struggle to understand the long term plan to increase the volume by 12000 and in the south of the District by over 4000 in the next phase. This will completely transform the dynamics of the community to the south of Leamington and severely damage the appeal of the area. I would want to see clear evidence that the local economy and new employment will demand such growth. This said, in planning terms the recommended solution seems to be an easy planning option. A huge swathe of housing adjacent to Myton is not clearly thought through.

We already have a large vacant property stock and many brown field sites which with imagination and thought could be brought back in to play to regenerate the town and restore its character.

Why cannot we see smaller developments around the outskirts, both north and south of Leamington rather than one' big bang '.
The constraint of green belt seems to have been overcome and modifications made by other District Councils . Is there joined up thinking across the whole of the County both in terms of policy and capacity?

I am also concerned at the impact the Plan has on the land close to and surrounding Warwick Castle - a major economic attraction to the District.

Office Buildings

Why are there proposals for more office accommodation?
There remain significant office buildings vacant in Leamington - indeed many offices have been unoccupied for some years. Proper planning should bring these buildings back into the equation. They also provide options for redesignation / modification as housing.
In this way the gradual decay of our town centre could be addressed. It remains too easy simply to build outwards!

Transport

The proposed modifications / widening of roads to meet expected volume changes does not acknowledge the fact that as roads draw closer to the centre of Leamington there are unavoidable bottlenecks with simply no where for traffic to go! Peak travel would become impossible if we extrapolate the average number of cars per proposed new dwellings in terms of vehicle growth.

Health Services, Schools and infrastructure

While any developments would need to balanced by additional health centre and GP services it is difficult to see how Warwick Hospital and both its general and maternity services could cope with increased patient numbers which in the long term could rise by up to 50,000 The hospital itself is landlocked with no scope for expansion.

The quality of education in existing schools could well be undermined if capacity is not accurately calculated. I am uneasy about class numbers rising above accepted norms.

Has the current work regarding drainage in the town taken account of the impact of such a large increase in dwellings?


In conclusion I remain very unhappy about the Plan. It does not appear to have been thought through with any in depth knowledge of the District but and with somewhat dubious population statistics and economic forecasts.

The Town Council meeting on 17 July 2013 voted unanimously to reject the latest Local Plan proposal and to support Leamington and Warwick's MP, Mr Chris White in his call for the District Council to rethink its ill-conceived proposals.

Additionally, there was considerable surprise and concern that the District Council had chosen only to note the clear advice given by Mr Andrew Langley MP, Leader of the House of Commons, in answer to issues raised by Chris White MP in the House of Commons, that residents of his constituency felt that their voice was not being respected, regarding the Local Plan Consultation.

The advice was that in the formation of the Local Plan, and that in the expectation of the Localism Act 2011, the District Council should not only apply the National Planning Policy Framework, but do so in the context of local decision making by local people.

Warwick, Whitnash and Bishops Tachbrook residents deserve to be heard, as were the residents of North Leamington, and their clear preference was that south Warwick District should not become a single urban sprawl, with the loss of those green areas, which define the boundaries of those parishes, but that housing should be limited to levels which the community and residents were able to support.





The greenfield sites, which are of considerable importance to the towns and villages affected, and which the Local Plan proposes for some 4,300 houses and flats, have been roundly rejected not only in the context of the current plan, but also in respect of the 'Core Strategy'. The strong local objection was known to the District Council before work commenced on this Local Plan and entirely ignored.

The importance of the green rural and agricultural land between Warwick, Whitnash and Bishops Tachbrook has been entirely discounted on the grounds that it was not Green Belt, but these green areas are as important to those residents, as the Green Belt in Kenilworth or Leamington Spa, is to those residents.

Indeed the loss of this green land is being dictated by;
i) The apparent willingness to provide developers with land to develop and to massively over provide for the housing needs of the Warwick District.
ii) The direction from Warwickshire County Council, confirmed by County Councillors, that in order to achieve maximum funding from development, that development needed to be allocated in large blocks.

In the Town Council's view local need can justify only approximately half the number now proposed and the Local Plan proposal provides for uncontrolled growth within the South of the District, which will lead to even greater congestion onto the existing road network and will impose intolerable traffic congestion in Warwick and Leamington Town Centres and the approach roads over the river crossings on the Avon.

The levels of traffic from some 4,300 houses and flats, based upon census findings, will generate in excess of 7,000 additional vehicles and which will worsen the levels of air pollution in the Town Centre of Warwick, when levels already exceed the legal limits imposed by the Air Quality Regulation (England) 2000.

That the levels, are exceeded was determined by the District's own officers, and formed the District Council's policy to work in proactive a manner to reduce the existing levels of unacceptable air pollution. Nothing in the Local Plan addresses the need to reduce the existing levels of nitrogen dioxide pollution in Warwick Town Centre and residents' health will suffer.

The traffic solutions outlined in the Local Plan and the mass of development proposed by the plan will seriously damage the setting of the Town, and consultants have previously recommended that the land south of Gallows Hill, which provides an historic setting for the Town and Castle, and Castle Park, should be protected from development. This area appeals to residents and visitors alike and is an important factor in the Town's tourism economy.

That impact on the tourism economy and the vitality of the Town will be made worse by the increase in traffic and wide junctions with traffic lights, in historic and sensitive locations in the Town, which will turn Warwick into a Town to be avoided by visitors. A further impact on the vitality of the Town and directly impacting on the Town's economy.

The issues regarding traffic congestion and pollution will be exacerbated by Stratford District Council's proposal to build 5,000 houses at Gaydon and in the Town Council's view, it is impossible to continue with a Local Plan, which already generates housing greatly in excess of local needs, when development directly intended to provide for employment needs is to be provided in Gaydon, effectively providing for the employment needs of the area, and in relative close proximity to the major development proposed in south Warwick.

Discussions must take place with Stratford District to produce a rational solution, for a new town type development at Gaydon, will directly reduce houses needed in Warwick District and demand for employment land. The take up of the latter has been so reduced that the District Council has already released designated employment land for the other users.

House building in Gaydon will greatly impact on the need for housing for employment migrants into Warwick District.

Notwithstanding, the large scale development in the south of the District centred in such large numbers will generate high levels of infrastructure from roads to sewage provision and water supply, schools, policing, doctor's surgeries, hospital demands and all health care facilities. Funding has been outlined in the Local Plan, but at this time the District Council cannot demonstrate that funding levels to be generated will meet the costs of such infrastructure.

There is also the doubt as to the deliverability of needed infrastructure and it will not be lost to the District, of the failures and delays regarding the provision of infrastructure at Chase Meadow, for the traffic scheme is not yet complete and sports playing fields have never been provided.

The Town Council does believe that there is a better alternative to the present Local Plan and one which local people would support. That alternative would be to reduce the total number of houses to that required to meet local need and in particular affordably social housing. Then if LPA allocation of employment land is taken up, additional land could be released to meet housing demand with development concentrated on brownfield and infill sites and near to schools and other needs.

Additionally a greater co-operation with adjoining authorities and in particular Stratford would allow for a joint approach, rather than a competition for jobs and houses.

The Local Plan has located a high number of possible Gypsy and Travellers sites in the south of the District and the Town Council consider that if the needs of the Gypsy and Traveller communities are to be met, then more rural sites should not be ignored, rather than the District Council just repeat the decision to ignore local representation and concentrate Gypsy and Traveller sites in Warwick, Whitnash and Bishops Tachbrook.

Regrettably therefore the Town Council finds itself in the position of repeating its objections to previous consultations objections, which have been ignored along with the views of local people.

The Town Council's objections are:

1) The projected housing development does not reflect local needs and the plan as proposed offers uncontrolled growth, and is a charter for developers,
2) The plan does not provide for development evenly throughout the District.
Almost total protection is given to Green Belt, as demonstrated by the decision to delete land at Old Milverton.

No concern is given to the importance of the greens areas between Warwick, Whitnash and Bishops Tachbrook and 4,300 houses and flats will spill over the historic boundaries to create a single urban sprawl.

3) Local views are being ignored, despite the support of Leamington and Warwick's MP.

4) The impact on traffic has not been assessed as an impact on the Town's tourism and commercial economy. Warwick would become less attractive for residents and visitors, if large traffic light controlled junctions were constructed and even greater congestion was created.

5) No thought is given to transport policies relating to cyclists and pedestrians.

6) Traffic generation will further increase the existing excessive air pollution and not reduce the pollution as provided by the Districts policy. Residents' health will suffer.

7) The historic environment would be directly damaged and the plan makes no provision to protect those historic buildings or the Conservation Area.

The purpose of the Local Plan is to develop Warwick District as a great place 'to live, work and visit' and the Local Plan should be assessed to ensure that this aim is met, throughout the District, and not just in parts.