Hampton Magna

Since I made my objection known in the first local plan I see you have upped the total of houses to be built.

I feel the district council are ignoring the feelings of the village and am so perplexed as to why you required our parish councillors to write a village plan and then totally ignore it.

Our village is fully utilized and this amount of housing will seriously affect the well being of its residents.

Also why do we have to provide all of these sites for Gypsies? You call them showmen in your description of them but the ones we see are usually tarmacing people's drives from white vans which have magnetic false company names attached to the sides to make them look legitimate. Or they do gardening (as they did for an elderly neighbour) then dumped the cuttings down the road in a gateway. Council had to remove it at goodness knows what cost. So I do question why they should receive special treatment and be found land when they don't contribute to council coffers as everyone in this village has to. It's just not fair or right.

Gypsy & Travelers sites

I have considered this consultation and agree that Warwick District Council needs to address the matter and identify suitable sites. Rather than consider all the available sites, because each will have a local context I have considered the 6 sites that WDC has identified that are nearest to and that would impact on my parish and its residents.

These are our views:

* Budbrooke Lodge [Site gt11] although this area sometimes floods, it has particularly good access to local shops and Warwick town centre, by public transport [bus stop adjacent to Budbrooke Lodge] and reasonable access to the main arterial roads. Servicing the site will be potentially low cost. Not sure if this is green belt site.
* Norton Lindsey [site gt14] is green belt, outside main development, dangerous location on a busy road, no public transport, not easy access to infrastructure /facilities.
* A46 [sites gt17 & gt18]- green belt, outside main development, particularly dangerous location on bypass, considerable air and noise quality issues, no public transport, not easy access to infrastructure /facilities
* Oaklands farm [site gt19] access is an issue identified by Warwickshire Highways Authority on numerous planning applications, proximate to canal so would impact on tourist, walkers and canal users, dangerous access on Birmingham Road and Ugly Bridge Road, both busy roads, loss of greenbelt, previous refusal because of business needs & hazardous sites.
* Watery Lane [site gt20] is green belt, outside main development, particularly dangerous location on bypass A46, M40, and Junction 15, considerable air and noise quality issues, no public transport, not easy access to infrastructure /facilities it floods.

The Local Plan
I have carefully considered the paper by Ray Bullen, which was supported by Rural Parish Councils, and the response from WDC on 18th July 2013. I regard the overall estimated residential development growth in the Local Plan to be significantly out of proportion to the local need; unrealistically high and untenable.

The District Council as failed to acknowledge, address or take account any of the issues identified in Budbrooke Parish Council's response to the first consultation in this second document. [1]

In respect to development in Budbrooke:
* All proposed development is in the green belt and there are no special reasons for using the green belt [reference: NPPF 2012 development in green belt is inappropriate.]
* Taking land out of green belt for development, I.e. re-drawing green belt boundaries, is tantamount to a gross misapplication of NPPF 2012. To do so is not a special reason.
* Loss of green belt will mean a loss of prudent use of land potential loss of value to special/ high landscape value
* Identifying potential sites in green belt, when there is other unused land outside the green belt and outside the local plan, constitutes a breach of NPPF 2012, referenced above.
* Budbrooke Parish Plan has not identified any significant demand for development locally.
* Hampton Magna is surrounded by high grade agricultural land
* Negative effects on strategic siting such as increased levels of traffic
* Air, Light & noise pollution will increase especially in the construction phase
* Presence of Railway will be a nuisance to potential development

People live here because they like the area, any development, and in particular an up to 25% increase, will have a significant impact on the nature and locality. This issue must be considered as it has previously been accepted by WDC in its dealings with other councils.

Capacity of the Infrastructure
Hampton Magna was built on the site of an army barracks in 1960s to the standards that prevailed at that time. Little or no improvement has been made since the site was first built on, and none since I came here in 1979.
* Minor cosmetic road improvements were made to accommodate a substantial increase to traffic due to the building of Warwick Parkway Station. Car parking since originally built has increased 3 fold with no change to roads or traffic management.
* Consequently, traffic is already extremely heavy. Approaches - Birmingham Road, Old Budbrooke Road, Woodway, Church Hill and roads to Hatton via Ugly Bridge, and through Hampton on the Hill. Any additional development will have a considerable negative impact on roads and traffic
* Traffic issues have not been addressed or even assessed
* Sewage arrangements is a major concern of the PC - Although adopted, prior to privatisation the system falls below the standard normally required.
* The main local electricity supply arrangements area the same as those for the barracks which left nearly 50 years ago. Supplies into the village are subject to frequent fluctuations and outages.

Budbrooke School, with only around 50% children resident in Hampton Magna, already draws traffic from surrounding areas -Hatton, Hatton Park, and Chase Meadow - and the county lanes are increasingly congested and hazardous. Increasing the size of the school to accommodate the 25% increase increases the congestion and hazard, and fails to address the Green Agenda unless additional resource is allocated in the current catchment areas, which idea has been discounted.

Sustainability
The argument that additional development will help address the sustainability of local facilities and services is flawed. There is no evidence is provided to show that this would be the case.

Without the publication of specific sites. I can make little assessment of the local internal impact of any development other than to state that in my judgment all development will have a significantly high negative affect on the community and community facilities. I challenge the council to draw up any development plan that doesn't have a negative effect on residents.

1. The proposed increase of homes in Hampton Magna up to 150 will result in some 300 additional residents (currently Hampton-on-the-Hill has about 200). Existing amenities and infrastructure could not absorb this increase. Budbrooke School is already at capacity; the single road through the villages is used as a "rat run" of speeding traffic to Warwick Parkway railway station and the M40. It is essential to preserve the rural character of Hampton Magna and Hampton-on-the-Hill and ensure that only the current amenity and infrastructure shortcomings are addressed.
2. The increase in housing estimates from 10,800 to 12,300 needs to be challenged. A Parish Council has published an assessment of housing requirements for Warwick District and considers the increase to be unrealistic. Indeed they estimate the need to be 5,400 homes. Also, our MP - Chris White - has written to the leader of the WDC, Cllr Doody on 24th June 2013 expressing his concern stating "I would urge you and your colleagues to reconsider and look again at the number of developments, their location, the impact on local infrastructure whilst respecting the views of local residents."
3. The need to provide pitches for Gypsies & Travellers has long been ignored by the WDC. The need has been assessed at 31 permanent pitches in the 15 years to 2029. This is in addition to the 12 pitches for transient use. The LPRDS now suggests twenty different sites to accommodate 206 pitches. We realise that not all the sites will be required and a choice must therefore be made about those appropriate for the needs of the travelling community.
4. There are six proposed sites within two miles of Hampton-on-the-Hill amounting to 41 pitches and we consider this an unnecessary burden on the local community. It has been suggested that instead of using existing sites, the Gypsies & Travellers could be accommodated within the development of the new housing areas where all the amenities they require will be at hand.
The Plan could be carried out without adding 500 houses to 5 Category 1 villages, by simply adding these houses to the areas designated 2,3,4, 5, 6, 11, 12 on the map of development sites, or onto Chase Meadow, where there is plenty of unused land. There is no justification or rationale to swamp Budbrooke with what is effectively another Hampton-on-the-Hill (approx 90 dwellings).
7 The Plan does not propose much development on the east side of Warwick / Leamington, compared to west and south. Why not?
8 A Parish Survey was carried out in 2010 by the Budbrooke Parish Council. 69% of respondents did not want any further housing development in the Parish. The views of residents should be respected. Adopting this proposal would merely serve to worsen the quality of life for the current residents.
Summary
Hampton Magna is unsuitable for further development due to its location between two major roads and proximity to Warwick Parkway. These already cause seriously over crowded local roads which are heavily used by commuters. This proposal would just make matters worse.
There is no compelling case for this proposal.

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.

Hampton Magna and Budbrooke

I wish to register my objections to the new local plan which includes the erosion of the Green Belt to build a further 150 homes and encircle the area with traveller sites.

My objections are based on the following:

Budbrooke has already had the Green Belt eroded by the building and expansion of Chiltern railway station and car parking development which already has a huge impact on traffic in and around the village and associated parking by rail users unwilling to pay to park, causing obstruction and danger within the village. Further development will exacerbate this problem.

The village is already used as a "rat run" and further housing/development of traveller sites will raise this to a much larger volume, which, as there is a single track access to the village under the rail bridge will result in more incidence of "red light" runners from impatient commuters and eventually fatalities.

Chase Meadow, Hatton Park and developments on land near Budbrooke industrial estate are already threatening the loss of village character and further development will mean Hampton Magna will not longer be a village but become part of the Warwick/Leamington conurbation.

Travellers choose to live their lifestyle and should purchase their own land and build houses themselves if they wish to be a settled community, and government should not use taxpayers money to compulsory purchase Green Belt land for this purpose. I am taxpayer and object to this use of my taxes. I paid for my own home and land. So must they.

The percentage of the developments (housing and traveller sites) in regard to the size of the current village is totally inappropriate.

Current school places are already oversubscribed, medical services fully utilised and not viable to take more. There are few facilities for young people or families.

Plans are contradictory to themselves. Green belt will not be protected and countryside will be eroded.

Brownfield sites have not been considered for all developments (including large supermarket developments such as Morrisons and Aldi) before giving them over to commercial development where there are already similar businesses.

1. During the first consultation exercise we pointed out, by way of on-line submissions, that there was a major flaw in the process of developing the Local Plan in that Hampton Magna had been designated as a Category 1 Village although no sites had been identified for housing purposes and no investigations had been made to identify any traffic problems. This meant that it was not possible to comment on specific sites. It also meant that the Council would be pressured into identifying inappropriate sites in order to meet the stated allocation for the village.

2. We further pointed out that that all the sites other than Category 1 and 2 Villages had been identified after careful research and proposals were made for infrastructure improvements to help mitigate their effect. The designation of category 1 and 2 villages, however, was an arbitrary decision based on the need to identify sites for a further 850 houses somewhere in the District. This was identified as another flaw.

3. These flaws have now been compounded by the Council identifying Hampton Magna as a Primary Service Village based on the services available resulting in an increase in the number of houses allocated for the village to 150. Although the identification of Hampton Magna as a Primary Service Village purports to be based on identifiable data relating to services available it is still only an arbitrary decision to accommodate the 850 houses. No thought has been given to the infrastructure problems or the availability of suitable sites in the village.

4. No account has been taken of the following representations we made during the first consultation:

'The Old Budbrooke Road, which in reality is just a country lane, is already
over used. Not only would additional traffic add to road safety issues but
would also make getting out of the village at peak times even more
difficult. The amount of traffic exiting the village at the Birmingham Road
junction will (has) already be increased by the additional parking at the
station. Traffic on the Birmingham Road will be increased if the proposed
development at Hatton, Shrewley, Rowington and Lapworth is approved which
will further impact on the roundabout over the bypass. Delays on this
roundabout are a major cause of tailbacks on the Old Bubrooke Road.

Any suggestion that CIL money could be used to improve the infrastructure
would only be acceptable if possible improvements were identified and
assessed BEFORE the Category 1 /Primary Service definition for the village is confirmed. In our view, because of the particular circumstances of the problems, no amount of road improvements would solve them.

Any increase in the size of the local school to accommodate additional
pupils would exacerbate the existing problems caused by parents parking
near the school when dropping off and picking up their children. Because of
the lack of suitable parking some parents are forced to park in dangerous
positions.'


5. Apparently a number of sites in the District have been put forward for development by owners, but as they have not been identified we do not know whether they are in Hampton Magna. One site to the south of Arras Boulevard Hampton Magna has been mentioned but despite contacting the Council we have been unable to ascertain the exact status of this land. We reiterate the point made in our previous representations that it would be perverse of the Council to identify any land to the south of the village because of high landscape value, existence of public footpaths and existing noise nuisance. Other areas of the village also have high landscape value. (see below)

6. The lack of any identified sites in this latest stage of the process means that we are still unable to comment on specific sites. By the time the sites are indentified we will be even further into the process and it will be more difficult to argue successfully for changes

7. The compounding of these two flaws means that the Council will be under even more pressure to identify sites in Hampton Magna to accommodate 150 houses even if roads serving the village are not suitable and/or the sites would not otherwise be acceptable.

8. During the first consultation we tried to mitigate the effects of the lack of identified sites by commenting on the possible sites in the village, although the comments could have been made more effectively if they related to identified sites. These comments were as follows and we resubmit them as part of the current consultation process:

'All the land to the south of the village should be discounted as any
development there would conflict with three separate considerations
identified by the Council ie:

i. The document Helping Shape the District under ' providing well
designed new developments that are in the right location' provides that
the Council will make sure new developments are designed and located to
maintain and improve the quality of built and natural environments
particularly historic areas and buildings, sensitive wildlife habitats and
areas of high landscape value. This is repeated in the Guide to Assessment
Tables under potential impact.

The views over this land are incredible and include views of the historic
town of Warwick and stretch as far as Brailes Hill at Shipston on Stour.
There is no doubt that they come under the definition of 'high landscape
value.'

ii. Also included in the Guide to Assessment Tables under physical
constraints is reference to 'physical aspects directly affecting the site
such as flood risk, protected trees and woodland, public footpaths, ground
contamination, access difficulties,overhead power lines'.

There is a public footpath running from east to west across this land and
another one running from Hampton on the Hill to the Hampton Road. In
addition to the designated public footpaths local residents have been
walking around the fields for at least 30 years and would be able to claim
public rights of way over the land.

iii. The Guide to Assessment Tables under Environmental conditions also
includes reference to aspects of the site's location which may impact on
the living conditions of future residents such as proximity to areas which are
the source of noise or atmospheric pollution or which are of poor environmental
quality as well as, for example, the remoteness of the site in terms of access to public transport, jobs and services

The residents of properties adjoining these fields, in fact residents of
most of the village suffer from noise pollution from the bypass and
motorway. This is well documented with regular complaints to the Parish
Council and the County Council

There are other sites adjoining the Old Budbrooke Road/Woodway junction
which also has high landscape value.

Discounting all the land to the south of the village and other land with
high landscape value considerably reduces the number of possible sites'


SUMMARY

9. The process is even more flawed because Hampton Magna has now been designated as a Primary Service Village before any sites to take 150 houses have been identified. No investigations have been made into the amount of suitable land available in the Village or infrastructure problems. This will result in the Council being put under pressure to identify sites even if they are unsuitable or the local road network cannot cope with the additional traffic.

10. If the designation is confirmed it would be perverse of the Council to
identify any land to the south of the village because of high
landscape value, existence of public footpaths and existing noise nuisance.
Other areas of the village also have high landscape value.

11. Hampton Magna should be taken out of the list of Primary Service Villages until thorough investigations have been made into the availability of suitable land and the need for and feasibility of improving the road network serving the village.

I felt that I needed to contribute my objections on certain areas of the local plan.

The overdevelopment South of the river seems very excessive given the total imbalance between North and South. Previous suggestions including developing North of Warwick seem to have been discounted. I know the argument for "Green Belt" but surely if the times require such a large expansion of the house building requirement, the "green belt" becomes of secondary importance compared to the relevance of the county town and access to and around it. It is inevitable that employment will be attracted to the Coventry Gateway scheme and I note also the proposed Thickthorn development, if the vast majority of housing is situated South of these then surely a very great strain will be added to the already overburdened road infrastructure in and around Warwick. I DO note the proposals for improving the traffic flow but you cannot escape the fact that there are only a limited numbers of crossing points of the river and there do not appear to be any proposals to increase this, hence you perhaps move the traffic to the chokepoints more quickly but there is then still the increased delay due to the limitations of the crossing points. If the view is that employment is more likely to move from North to South then the same arguments apply in reverse! Given the very poor air quality in Warwick itself, I believe higher than medically acceptable, the situation will inevitably get worse particularly in light of the almost complete absence of any form of policing of bad, inconsiderate or illegal parking. In short I object to the housing plan as it is unfairly distributed, will be unable to cope with the increase in traffic and that peoples health will suffer as a result.

Turning to the suggested development around my own village of Hampton Magna, I consider the proposed site unacceptable and the additional burden on our local infrastructure unfair. The land in question may well have been landfill in a previous era and insufficient research has been done to verify this or re-assure the local resident that this was not so. Current property transactions are being affected by this and additional insurance seems to now be required before a transaction can be completed. In addition our local school has already had the burden of Hatton Park placed upon it and the attendant problems with parents driving children to and from school and their very frequently discourteous, inconsiderate, downright dangerous and often illegal parking will only get worse along with those who use the railway station but park in our village. I assume that consideration of the capacity and capability of the Doctors surgery have been duly considered?

The vexing question of "traveller" sites is with us yet again and I note that two sites being considered are those on the A46. Surely it is inappropriate that slow moving vehicles and caravans are allowed to enter and leave these sites on an already overburdened major road which is only a dual carriageway in any case at those points. This MUST be dangerous. The proximity of young children to such a major road is unthinkable and again it will place an additional burden on our local schools and medical services. I leave aside the obvious worries of these sites proximity to the local houses and the inescapable fact that some of these "travellers" are less than honest, it must surely have been considered?

see attached

see attached

see attached

BPC has carefully considered the paper by Ray Bullen, which was supported by Rural Parish Councils, and the response from WDC on 18th July 2013. Budbrooke Parish Council regards the overall estimated residential development growth in the Local Plan to be significantly out of proportion to the local need.

The District Council has failed to acknowledge, address or take account any of the issues identified in Budbrooke Parish Council's response to the first consultation in this second document.

In respect to development in Budbrooke:
* All proposed development is in the green belt and there are no special reasons for using the green belt [reference: NPPF 2012 development in green belt is inappropriate.]
* Taking land out of green belt for development, i.e. re-drawing green belt boundaries, is tantamount to a gross misapplication of NPPF 2012. To do so is not a special reason.
* Loss of green belt will mean a loss of prudent use of land potential loss of value to special/ high landscape value
* Identifying potential sites in green belt, when there is other unused land outside the green belt and outside the local plan, constitutes a breach of NPPF 2012, referenced above.
* Budbrooke Parish Plan has not identified any significant demand for development locally.
* Hampton Magna is surrounded by high grade agricultural land
* Negative effects on strategic siting such as increased levels of traffic
* Air, Light & noise pollution will increase especially in the construction phase
* Presence of Railway will be a nuisance to potential development

People live here because they like the area, any development, and in particular an up to 25% increase, will have a significant impact on the nature and locality. This issue must be considered as it has previously been accepted by WDC in its dealings with other councils.

Capacity of the Infrastructure
Hampton Magna was built on the site of an army barracks in 1960s to the standards that prevailed at that time. Little or no improvement has been made since the site was first built on.
* Minor road improvements were made to accommodate a substantial increase to traffic due to the building of Warwick Parkway Station. Car parking since originally built has increased 3 fold with no change to roads or traffic management.
* Consequently, traffic is already extremely heavy. Approaches - Birmingham Road, Old Budbrooke Road, Woodway, Church Hill and roads to Hatton via Ugly Bridge, and through Hampton on the Hill. Any additional development will have a considerable negative impact on roads and traffic
* Traffic issues have not been addressed or even assessed
* Sewage arrangements is a major concern of the PC - Although adopted prior to privatisation the system falls below the standard normally required.
* The main local electricity supply arrangements area the same as those for the barracks which left nearly 50 years ago. Supplies into the village are subject to frequent fluctuations and outages.

Budbrooke School, with only around 50% children resident in Hampton Magna, already draws traffic from surrounding areas -Hatton, Hatton Park, and Chase Meadow - and the county lanes are increasingly congested and hazardous. Increasing the size of the school to accommodate the 25% increase increases the congestion and hazard, and fails to address the Green Agenda unless additional resource is allocated in the current catchment areas, which idea has been discounted.

Sustainability
The argument that additional development will help address the sustainability of local facilities and services is flawed. There is no evidence that this would be the case.

We cannot find any justification for sites in Hampton Magna.

I have attended a number of local meetings regarding the local plan and do recognise the difficult position elected members and officers have been placed in in pulling this document together. However I continue to feel that it is unfair and untenable.

Just because North Leamington residents got together quickly and financed themselves into a position to lobby and discredit the first plan option of building between Milverton and Blackdown should not mean that there is no development north of the district. One key reason for building affordable family homes in the north was to re-invigorate a fossilising community. The demographic trend in Milverton, Cubbington and beyond is for older people and this is storing up problems for the future. Neighbourhoods and villages work best with a good spread of community - old and young sharing services and supporting each other. An additional reason to re-consider some development in the north of the district is with the successful Coventry/Warwick Gateway developments application. I note officers stated that this will open up jobs for Coventry people more that Warwick District residents but I also believe many will come from and/or want to live in Warwickshire. Because of this late- in-the -day decision I do feel planners should go back to the drawing board on developments north of Warwick district.

In terms of developing close to villages - particularly Hampton Magna - it is now apparent that families purchasing homes here need to have special land checks completed and organise specific insurances to cover the fact that some homes are built on landfill. (When we purchased 37 years ago we believed the site was Budbrooke Barracks but further investigation is showing a land fill sites also). The development land proposed on the outskirts of Hampton Magna could well feature ex-landfill sites and therefore become more expensive tracts to build on or develop. Additionally the local school and doctors surgery are full to capacity and would struggle to cope with additional demands on services - particularly having recently coped with influx of residents from Hatton Park and Chase Meadow.

Feedback on the proposed gypsy and traveller sites includes the unfairness of just how many sites are located around the county town of Warwick. I, and most people I know, recognise that sites need to be developed but again these need to be fairly distributed around Warwick District not only for current residents but also for travelling families to have some choices of where they settle. Planners may well quote that fairness is not a legal requirement but it is certainly a community requirement. I don't believe the developments alongside the A46 (ex Little Chef sites North and South) are appropriate. Not only is one site on green belt land - they are both immediately adjacent to a very fast road and have poor or no walkways or public transport access. Families and domestic animals should not be placed so closely to a fast road and they should have access to available services (see above for lack of school and GP capacity).

I feel the Racecourse site is also inappropriate due to it being placed on a major gateway into the County town and this site is also a transient site for travelling circus/fairground people through out the year - again making this choice an unfair one. Sites such as Barford and Kytes Nest Lane are significantly more appropriate due to their locations. I am also surprised that Radford Semele has little or no development proposals. There is capacity in the school there as well as good road and public transport links.

Please carefully consider all the above. I look forward to the next round of suggestions.

I wish to register my objection to the increase in houses within the village of Hampton Magna on the following grounds:-

1. The green belt has been eroded by the building of the parkway station, and by further extension to the car parking area.
2.The road leading to the village has been narrowed to single carriage way under the railway bridge, restricting the flow of traffic to and from the village.
3.The infer structure is unable to take more pressure as frequently we have burst water pipes.
4.The internet is very slow.

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Revised Development Strategy
1. The increase in housing estimates from 10,800 to 12,300 is in our view to be without foundation. A detailed and authoritative report produced by Bishop's Tachbrook Parish Council suggests the likely requirement is 5,400 homes, less than half the WDC estimate. The WDC need to re-consider their estimate taking into account the homes required in neighbouring authorities (Coventry; Rugby & Stratford) and rationalise the estimate to be sure there is no duplication of need. Even the proposed 5,400 homes will add over 10,000 people and some 15,000 vehicles to the area which will result in unacceptable traffic congestion and consequent air pollution which is reportedly already illegal in Warwick.
2. Within the WDC estimate, is a figure of 100-150 new homes in Hampton Magna. The existing amenities there are already overstretched and to add an additional 300 people - more than double the population of Hampton-on-the-Hill - will mean they will be unable to cope. Also the single road through the two villages is already used as a 'rat run' by speeding traffic to Warwick Parkway Railway Station and to the M40 Motorway. Indeed more and urgent attention needs to be given to improving the existing transport infrastructure to accommodate the current population.
3. With an estimate of 5,400 homes, no development needs to take place in the villages mentioned in the Plan thereby protecting the Green Belt and the Rural nature of the district which makes it the pleasant place in which to live.
4. We urge the WDC to heed the concerns expressed in the letter from our MP. - Mr Chris White - to Cllr Doody dated 24th June 2013 in which he expresses his concern about the housing estimate and urges the WDC to 'respect the views of local residents.'

Sites for Gypsies and Travellers
The need to provide sites for Gypsies & Travellers has long been ignored by the WDC leading to the reason often given by the travelling community for the illegal occupation of some sites. The requirement is for 31 permanent pitches and 12 transit pitches. Now there are twenty proposed sites amounting to 206 pitches in all which seem to have been selected in a somewhat haphazard manner. We realise that only one or two sites will be selected from the twenty suggested but the number and location of so many sites has caused unnecessary alarm among residents. For example, there are six sites within two miles of Hampton-on-the-Hill.
Site GT 13 at Kites Nest Lane has been the subject of an Inquiry with a decision due in October 2013. How can it be considered a viable site? Site GT 20 is the site of Morrison's compound when the A 46 flyover/M 40 modifications were being constructed during 2009/11. On completion of that work it was offered as a possible site for the travelling community and turned down by the WDC as unsuitable; being too distant from the amenities required by them. How then can it now be regarded as a viable site?
Instead of proposing the twenty sites, why not instead consider housing the 31 pitches on the fringes of the other larger proposed housing developments. In this way the travelling community will have convenient access to the amenities they require.

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Having lived in and enjoyed living in Hampton Magna for almost 20 years I am of course concerned about what goes on locally, and this seems to be the biggest single thing so far. We have had proposals to turn the former Warwickshire Regiment parade ground into a mini-industrial site (now a livery stable, much more in keeping with the surroundings), a telephone signal mast on the verge of a blind bend (thankfully not materialised) and of course the reality of Warwick Parkway Station. This is a very useful facility, although I am dismayed at the way the car park is gradually creeping across the land on the other side of the road, and of course the surrounding promised landscaping never happened (weeds galore instead of properly planted and maintained grounds by the station building). The other issue is that complaints regarding commuter parking in Hampton Magna are not taken seriously. Further afield there is Chase Meadow and Hatton Park - the land is considerably less green than when we first moved here and thought how nice it was to be living in the countryside. The green belt has been eaten into enough around here in the last 20 years - what's the use of it if you keep allowing it to be built on?

Moving on to the proposed housing. Whilst not really wanting any change personally, I agree with the broad principle that new housing, both large and affordable homes, are needed locally and that all communities should be prepared to accept some new housing. The problem I have with the current plan is the percentage scale compared with the size of the existing community of Hampton Magna. Up to 150 new houses added to the current 600 is actually a 25% increase in the size of the village as a whole. This seems to me an unreasonable increase - for a village whose residents are used to open fields and countryside around them an increase of 25% is breathtaking. An increase of any size is unwelcome, but in line with my view above an increase of 5% - 10% would show that we are not "nimbys" and are prepared to shoulder our fair share of the burden. There lies the word - FAIR - 25% is NOT.

The other worry I have is local access and services. Wherever you see new housing the local services are slow to follow - bus services, extra school places, community facilities all take a ridiculous second place. How long have the first houses been up at Chase Meadow? They are just getting their community centre now. It isn't good enough. Hampton Magna needs a new community centre to replace the current tired and cramped building - how about these developers should replace this first as a gesture to the community in return for destroying so much green belt land for their profits? The school is full to bursting with current and future known students, never mind the extra ones from the proposed new houses - again the developers should help to pay for new school buildings to cope, and at the same time ease the burden on us taxpayers.
Hampton Magna suffers from restricted access due to the 2 sets of traffic lights and the road narrowing out onto the Birmingham Road - it can take 15 minutes to leave the village at peak travel times, and this by all logic will only get worse with 10% more housing, never mind 25%. At the latter percentage and two cars per house that's an extra 50% increase in traffic every day. We already have a considerable amount of "rat run" traffic, the roads have blind bends, narrowings etc. and really do not need more cars. Going out the other way through Hampton on the Hill is no better - blind bends, more narrowings, a blind summit and a fairly dreadful junction out on to the Henley Road.

Gypsy sites - oh such an emotive subject, and quite rightly so. Again logic says if they are so keen to be called travellers why do they need permanent sites? Who pays for them to be built, maintained and administered? I think I can probably make a shrewd guess of the answer on this one. What do travellers get on these permanent sites? Do they pay rent whilst they are there in residence? Are there penalties imposed for misuse? You should provide a lot more information to us permanent, sitting-duck, tax- and council-tax, national insurance, private pension-paying residents so that we can see why you are so keen to accommodate these people on our doorsteps. Just saying central government has told us to doesn't impress I'm afraid. I am not in favour at all, especially as the Hampton Magna/Budbrooke/Hatton area has the majority of the proposed sites, but maybe I would be a bit more flexible if I could be assured that I would not be driving past a dirty smelly tip passing for a residential complex on a daily basis. My experience of travelling people is not happy - a fight amongst 6 year olds at my childrens' primary school within 2 weeks of travelling children being temporarily enrolled, having to park at work after travellers illegally used it as a place to live and left behind all manner of disgusting and unnecessary mess, and the burglary of a neighbour's house where I used to live directly linked to travellers in the area.

All in all, I am not in favour of your local plan as it stands - please at least decrease the number of houses Hampton Magna is expected to take and insist that developers make a significant contribution to local infrastructure before they build. Please distribute the gypsy sites fairly throughout the area - we should really only have to put up with one small one like everyone else if we have to have any at all.