Myton Garden Suburb

The area west of Gallows Hill is the most appropriate area for development of housing of all the proposed developments in the southern part of the district. This is because of its close proximity to what was formerly known as the Shires Shopping Park, and to the town center.

However, access to this land must be carefully planned. There is no access from the north or West due to the schools and business park. To the west and south are Gallows Hill and Europa Way which are the main southern routes into and out of Warwick and Leamington, indeed dual carriageway has been proposed for Europa Way. Access should be designed to minimize disruption to the flow of traffic on these roads, much of which will be by-passing the new development.

Sound buffers will also be needed if developed with housing. Failure to do this will result in local complaints about traffic noise resulting in lower speed limits in these main roads, increasing journey times.

I am extremely concerned to learn of the plans to build 600 new homes within my area; I do not believe there is an actual need or requirement for this many new build houses in the area and that this is a purely a ploy to get the country back on it's feet by concentrating on the building sector to get the economy moving rather than a real need for new homes.
With regards to the increase in volume of traffic, I am extremely concerned as the traffic is at a standstill each morning (particularly along the Myton Road) and has become even more chaotic since the completion of the new Morrisons development - this will of course worsen once the planned hotel/ offices/flats have been built. This is not helped by the badly thought out and design of the new road layout.
I regularly witness near misses - sometimes involving school children (on foot and on bikes) on their way to one of the many local schools in the area - and believe it will be only a short time before a major accident occurs as we approach the long dark winter nights and bad weather.
Another worry is the level of polution in the area; my son suffers with Asthma and it has been suggested that his condition has not helped by the fact that we have a very high level of polution in this area; I do not know of the exact statistics, but I would ask that this is looked into before making any further committments which will further increase levels of traffic and polution.

The Council is wrong to succumb completely to the green belt argument. They should look beyond the green belt designation and look at the real value of the land. The wedge of green land that has been ear-marked for the Myton Garden Suburb development (MGS) has more value than general green belt - it is the last remaining green space that penetrates into the heart of Warwick/Leamingon Spa and allows them to be identifably separate towns. It provides access for wildlife and clean air into the town. It also has been identified as an area not to be built on, for good reason.

The placement of virtually all the new housing to the south of the towns is a huge imbalance and does not satisfy any demand in the north of Warwick and Leamington, thereby causing more traffic through the centre. Arguments that people living on the MGS site and working to the north of the area will travel via the M40/A46 are fanciful. The reality is that they will travel through the town centres, with all the attendant negative effects. Placing all new housing to the south of the towns simply does not satisfy the towns' housing needs.

Urban sprawl and encroachment into the countryside is going to happen anyway, by building on any green field sites. The question is: what areas can cope with it best? The MGS site is unique for the reasons stated and must be preserved. There is sufficient green belt land to the north of Warwick and Leamington such that using a relatively small amount of it to offset the loss of the MGS site would not materially affect the overall state of the green belt - in particular, coalescence of settlements can be easily avoided.

The Council's original intention of building both north and south clearly makes more sense. The MGS site is a case of exceptional circumstance that should allow the Council to allocate a relatively small amount of northern green belt to offset its preservation.

NLP threatens to overdevelop green space with too little mitigation for extra people, traffic, pupils needing school places.
Road networks will be noisy, out of character with the current pleasant environment, spoiling it for present and future generations.
This NLP threatens to create a conurbation out of communities that now enjoy a rural aspect with natural breaks in separate communities.

Development on this site would lead to more congestion on Europa Way and the roundabouts at the Retail Park and Myton Road. As the capacity of Princes Drive under the railway cannot be increased with the proposed road and junction improvements Princes Drive will become an even worse bottleneck. Since the opening of the Morrison's supermarket the volume of traffic on Princes Drive has already increased and as before during times of very heavy rainfall the road under the railway will flood.

The area south of Myton Road should not be developed and was particularly referred to by the inspector of the previous local plan as an area which should be left undeveloped. Any development should be small scale and in the character of the existing low density homes. To develop with over 3,000 houses in a short time is inconceivable destruction of open countryside. It will bring huge increases in traffic along the Myton Road and adjacent areas and in particular up into Warwick. To place this housing across the other side of town from the employment is plain daft. High Street and the bridge can hardly cope and to turn all the roads into major highways is wanton destruction. Calling this development Myton Garden is deceitful when it destroys the countryside - the works to Banbury Road must require the removal of ancient hedgerows and splendid old trees. The current design standards used by the Council will create densely packed estates nothing like the "garden city" ideal which people might imagine.

Removes valuable green space between Warwick & Leamington.

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.

We are writing to express our strong objections to this planning application. We currently live off the Myton Rd where the school run is extremely slow now due to weight of traffic and this plan will inevitably cause grid lock. Warwick roads were originally built for a few horse and carts and struggle to support current traffic load. We fear these plans would make this great area a considerably less enjoyable place to live.

I live in Brittain Lane which backs on to the proposed site of these homes being built.
We are strongly against these homes being built not only will the traffic increase and pollution /health issues also the surrounding roads will become gridlocked it will take people twice as long for anyone to get to there destination also if there is a emergency on the roads the emergency services wouldent get through so more roads would have to be built in Warwick /Leamington to cope.So at the end of the day once again the tax payers of Warwick/Leamington will have to pay more on council tax for this to happen and we pay enough.

Objection to revised local plan:

I write to object to the revised local plan, specifically, to any development on the Area of Restraint land and fields lying between Myton Road, Gallows Hill and Europa Way in Warwick.
Detailed responses and critical issues have been delivered to you in previous consultations, therefore I would summarise the grounds for objection as follows:
Planning:
1) Development levels within the South Warwick area have been disproportionately high compared to other potential sites, and many times more than the national average. South Warwick is far from being a 'NIMBY' population; rather, we have already endured more than a fair share of housing development over the last decade.
2) Housing developments in the past (e.g. Warwick Gates estate) have yet to deliver on promised infrastructure developments to ensure sustainability (schools in the example of Warwick Gates). There is a need to make up the existing shortfall first before any further development can be considered. Please refer to 2013 admissions guide for Myton School with 594 preferences for 275 places.
Environment:
3) The revised plan would destroy the last remaining green space separating Warwick and Leamington, thereby driving urban sprawl and setting a precedent inappropriate future development.
4) The Area of restraint land within the Myton area is rich agricultural land, supporting many rare and important animal and plant species. The scale of development proposed would destroy irrevocably much of this important habitat, depriving future generations.
5) Flooding risk has been highlighted by Myton residents, with photographic and written accounts (see attached letter from Malin's and Myton Crescent residents from previous consultations). The revised plan does not mitigate flooding; rather it guarantees property damage and environmental damage due to flooding caused by over development. The area of restraint land serves as an important water sink, and in the context of predicted increased rainfall over the next several years, needs to be left alone.
6) Air quality has been extensively studied and reported on in the Warwick area. The WDC commissioned report of 2009 revealed a widespread breach of air quality standard around the entire perimeter of Warwick Town centre. It is clear that the revised plan would cause many thousands of additional car journeys per day that would further deteriorate levels that are already breaching EU requirements. The revised plan represents a major public health risk to current and future generations of inhabitants.
7) Infrastructure within Warwick is not capable of expanding to meet the significant additional demands that the revised local plan would generate. Traffic will clog at the constricted entrance and exit points of the medieval town layout (see photos in the attached previous response). Leamington Spa train station is already often full to capacity and parking expansion seems highly unlikely in the revised plan.
Process:
8) King Henry VIII / Oken Trust, current owners of much of the Myton land earmarked for development, have clear conflict of interest given the position that WDC Councillors hold on the Trustee board. Prior to any formal engagement of land sale, The King Henry VIII/Oken trust must be independently audited to ensure covenants of sale are not compromised.

9) There has already been an overwhelming response by Myton residents to object to previous preferred options (in 2009 and 2012), that were almost identical to the revised local plan. Previous public consultations seemed to have failed completely, as the Myton area is now proposed for even greater intensity of development. Therefore, please take into account previous objections rather than brush them aside.

I'm a resident who lives in Saumur way (off Myton Road) closer to the two farms. We are very concerned on this local plan about building over 800 houses near our street. We moved to Warwick from London over 20 years ago. The reason we loved living in Warwick is pollution rate were very low when we first moved to the area. Within last few years we have felt level of pollution has been increased to unacceptable level. I have been suffering with hay fever for the last few years. Since then every year I suffered very badly. I assume this must be due to increase in car exhaust fumes.
Having attended the meetings regarding the local plan, we strongly object to the proposed site for building 3000+ houses on the farm and the agricultural land between Myton Rd and Europa Way on the following grounds:-

1) Air Quality - due to the constant backlog of stationary and slow moving vehicles on the Myton Rd/Europa Way at most of the time of the day ie school/office hours. Adding thousands of extra vehicles will make the air quality very poor and simultaneously roads will become dangerous.

2)Flood Risk - There had been flooding on Saumur way closer to cycle track and off Aragon drive. Also evidence has been presented to WDC of flooding and standing water in the area of The Malins and Myton Crescent since the development of the Brittain Lane estate on the former Dormer Hall site on the Myton Road. The whole area will be of great risk of flooding if the top soil is removed from the fields/farms. This will give rise enormous burden to the residents around the area.

3) Infrastructure - there is no capacity to widen, extend or improve the over used Myton Road, you are proposing access
to part of this 'garden suburb' via Saumur Way which is a tiny residential road which cannot cope with more traffic - not to
mention adding to our already poor air quality as more cars will queue back from the Myton Road causing more pollution for residents
of Saumur Way.

4)Fairness and quality of life - it is extremely unfair to dump a huge amount of housing on our small area as
we feel it is just viewed as an 'easy' or 'soft' option, showing no consideration or care for the quality of life of residents of Myton.
With regards to quality of life - we will no longer be able to sit outside of a quiet summer's day as you are proposing 15
years of construction at the end of our close, we know from experience - we have had to put up with the construction all of one
summer with Lidl (a big mistake as we told you at the time) then we had constant loud construction noise and road issues with the Brittain
Lane site; just when we thought we might get some peace we had 10 months of misery and upheaval with Morrisons/Aldi and all the surrounding
road chaos.
The amount of houses planning to built in this small area rich land is seriously unfair, and the quality of life people enjoy at present will be diminished.
Further more the land west of Europa way which has always been under careful stewardship of Oken and Henry VIII Trusts and remained until now,
so I wonder why WDC is trying to put a stop to this.

Where is the quality of life for the people of Myton? it seems the planning department of WDC is hell bent on over building and
ruining this entire area.

There is a plan being put forward as you are aware with an alternative proposal spreading the building around the area more evenly
and more fairly to existing residents, this proposal should be considered immediately.

The number of houses 'needed' are not the same as the number of houses 'proposed' and the number of houses you are proposing
should be downgraded significantly; after all, have you taken into consideration the fact that families like ours will consider moving
OUT of the area if you continue to decimate it in this way?

Everyone accepts growth is necessary, but the way WDC is going about this is alienating WDC from the people is it here to present, trust
is very low and the people of Myton feel the WDC is choosing our district yet again as a soft option.

We also object very strongly to the consideration of Planning Applications at this stage for building on an Area of Restraint that has
not been authorised for building on - you cannot grant permission to build on an area which is still an AOR, we are still in the consultation
period at this stage, nothing has been agreed - it is issues like this that make the local residents feel even more strongly that they
cannot trust WDC on the issue of the NLP.

We therefore again call on WDC to reject the New Local Plan in its current form, and for WDC to considered the options presented
to it for smaller housing numbers to be spread evenly and fairly across the whole area.

ps. WDC stands for Warwick District Council, but if this plan goes ahead it might be read as Warwick Destruction Council !!!

Dear Sir or Madam

Having attended recent local meetings regarding the proposals laid out in the new Local Plan. We strongly object to the proposed site for building 3000+ houses houses on the farm and agricultural land between Myton Road and Europa Way on the following grounds.

1) Infrastructure - Myton Road has always been a very congested road at peak times and has got worst in recent months with the addition of lidl and Morrisons being build. This road cannot take any more traffic. You are proposing to access the new site via Saumur Way, a residential road, which cannot cope with extra traffic this will also add to the queuing on the Myton Road which will greatly affect the air quality in this area even more. We would like to add traffic surveys in this area only seem to be carried out in the school holidays when the volume of traffic is not at its peak so how you can predict the traffic use of this area in the years to come we do not know if you can not even get the figures right now.

Furthermore why you have to get rid of a working farm which has been there for many years before we came here is beyond us! especially as we have lost so many over the years.

2)Air Quality - Many Adults and children already suffer from chest and breathing problems due to the air quality in this area by the slow moving traffic on the Myton Road and Europa Way at all times of day and thinking of adding to this with thousands of additional cars is unacceptable.

3) Flood risk - There has been evidence of flooding and standing water in the area of The Malins and Myton Crescent since the development took place on the former Dormer site and to take the top soil from the fields between Myton Road and Europa Way would cause even greater problems. There has also been flooding at the top of Saumur Way. These we understand have all been reported to the WDC.

We have lived here for the past 27 years and to think this lovely peaceful area will soon be spoilt by noise and pollution from building contractors over the next 15 years when we have had to put up with the the construction and building of lidl and the new road system installed becuase of Morrisons over the last year is unacceptable. We thought we might have some respite from all this but no the Planning Department wants to disrupt this quiet peaceful area once again. We do not want our town turned into a sprawling concrete jungle where all the villages emerge into one. We want to keep Warwick as a separate identity and we are sure the people in the surrounding area feel the same about their villages.

So please think again we have seen too many towns spoilt by bad planning over the years, where not enough thought has been put in to making a place where people want to live and work but somewhere planners think this is what is needed and not what the residents of the an area want.

In the Strategic vision section [3.5 Environement] of the new local plan you specifically highlighted
the need to:

a-distribute developement across the district
b-avoid coalescence
It would seem by concentrating the major developement between Europa Way and Banbury Road
you have ignored both of these objectives particularly since in previous plans this area was designated an area of restraint
Warwick will lose its rural setting and become part of an urban sprawl encompassing Leamington and Whitnash.
The effect of the extra traffic generated by this developement will cause gridlock at peak times on castle hill and along Myton Road.
Air quality in the town which is already at unnacceptable levels will undoubtedley deteriorate and cause serious health problems.
One further concern is drainage in the Myton area.When the Technology Park was built Warwick School and the gardens backing onto the school experienced some flooding problems.
I note in the latest plans submitted by the developers it is proposed to route some of the surface water off the new developement down to the culvert under Myton Gardens.
This is a major flood risk factor.
I trust you will give serious consideration to these issues raised before finalising the plan.

Dear Mr Barber

I am writing having been very surprised to hear that you had said at a consultation meeting that you were not aware of the flooding which has affected my property and other properties in Myton Crescent and the Malins. If this is the case you may be quite shocked at the photographs which I enclose. The flooding arose as a direct consequence of the disturbance of the topsoil on the Round Oak/Trinity School playing fields by contractors employed by the County Council to lay new field drains and to level the surface. Neither this drainage nor the other remedial measures taken have solved this problem as the photos taken five years later show.

The Round Oak issue was of course taken up with the County Council rather than the District Council as it was the former's contractors who were responsible for the disturbance of the land. After a series of meetings with County Council representatives and a firm indication from myself and other residents that legal action was contemplated certain, remedial measures were thought up and implemented. These included the building of a bund (see photo) to hold in collected water and the installation of a pump to pipe excess water up the slope to the sewer by the new Round Oak school buildings. Trees were also planted on and around the bund but have barely grown in the time since.

In addition to the above, neighbours at the end of the Malins have been affected by the endemic collection of surface water over the years. Historically it is believed this area was once the site of and known as Myton pools which perhaps explains the fine balance inherent in the current land cover.

These issues were recently raised by myself and other residents in representations submitted to the proposed developers at their invitation. With the flood experience in mind the suggestion was put to them that the land between the Round Oak School playing field and the Myton School playing field should not be disturbed or built on. Planners would do well to take on board this suggestion which would create a continuous band of open space based on the two existing recreational areas which are only a few hundred yards apart. The developers have said that they wish to build 'green space' into their plans and this would be a sensible location to put it with so much of it already largely in place.

That is only the secondary purpose of this email however which is to put you on notice that none of the residents will tolerate the risk of further flooding of the type we have experienced. So far there has been no response or reaction from the developers to the photographs which I supplied. I should be grateful for your confirmation that this will not be the case as far as the planning department is concerned.

Below I enclose the relevant part of an urgent email I sent to the County Council in 2007. From this and the photos taken in 2012 you will see that once the topsoil is removed it is not an easy task to deal with the consequences.

Fri 27/07/2007

Dear Mr Thomas,

26, Myton Crescent, Warwick

You may already have spoken to Ian Grace and learned that our garden and that of our neighbour Dr Ghose was comprehensively inundated again yesterday afternoon. I know Dr Ghose at 28 Myton Crescent was intending to ring you today and that he intended to point out that he also suffered last Friday. In fact I would say that his garden was more affected this time than our own.

I'm also aware that other neighbours have been in contact over concerns about the accumulation of water alongside the perimeter fence and the closeness that the water in the ditch has come to breaching the bund that has been built up. Behind this bund a considerable amount of water has collected. Yesterday it looked like a small lake and the rest of the field was heavily puddled.

What was of greatest concern to us was the amount of water seeping past the bund. On this occasion I took stepladders to examine the field myself. There were at least three places where water could be seen flowing under the boundary fence into the adjacent field from where it flowed into our respective gardens. I have taken photographs of these channels of water and indeed of the 'lake' and other collections of water. I shall of course be happy to let you have these.

Last Friday our neighbour at 36 also had water in her garden so the potential for other properties to be affected remains despite the measures that have been taken so far. I understand from Gary that the pump he used after Friday was not able to operate on the scale required and had little effect. He has suggested that a more powerful pump might be part of the solution although Mr Grace, talking to our neighbour at 34 yesterday, appeared lukewarm on the idea. We would be interested to know what initiatives he has proposed.

As a temporary measure Gary was talking about deepening the ditch and raising the bund. This seems essential but I would point out that a lot of water appeared to be seeping from beneath the bund, something which is perhaps not surprising bearing in mind that no land drains were laid in this corner of the field. Worryingly the fall to this corner of the field is also greater than before because, so Gary informed us, the level of the surface has been raised by about 6 to 8 inches apparently to make it level and 'Sport England' compliant. For whatever reason the fact remains that water is flowing into and collecting in this corner even when the water in the ditch is being held beneath the rim of the bund.

Dear Sirs

I wish to register my grave concern about the proposed local plan for Warwick.

* Traffic Myton road is already overloaded and although there are proposed alterations to the roundabouts, this will not reduce the volume of traffic. Where are you expecting that all the people will be working? Will they have to go through Warwick, over the historic small bridge? Warwick High Street is already very difficult to get through throughout the day. Any vehicle bigger than a normal car causes havoc - and when loading and unloading occurs the traffic is at a stand still.
* Quality of air along Myton road and Warwick high street. As a result of all this slow moving traffic the air quality is dangerous and this is the route than hundreds of school children walk or cycle to their schools each day. The residents too, are subjected to intolerable air pollution which can only get worse with the proposed development.
* Distribution of houses around the area surely this would be beneficial for Warwick and for the villages themselves where there can be a development and return to normal village life with village shops which would be sustainable with more housing. Of course this would be more costly for the builders but do we want another, huge estate spoiling the very nature of Warwick? NO

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.

I object to numerous elements of the WDC Local Plan. I am not a planner and therefore it has taken considerable time and effort for me to draw together a reasoned response - time that many families simply do not have.

In the public meetings I have attended throughout the Consultation I have been astounded at the insistence of Council officers that the Local Plan in its current form is going ahead irrespective of the public response. What kind of Consultation is that?

I have also yet to hear a solid reason why the greenbelt land north of the river, earmarked in the first draft, is no longer being considered. Limited release of this land would create a more balanced and sustainable urban area.

I understand that fairness is not a planning concern. But the concentration of such a high proportion of the proposed new housing south of the river is completely unacceptable. Aside from the coalescence of settlements this will cause, the strain on local infrastructure, the nightmare traffic and corresponding reduction in quality of life for existing residents, it will impact upon Leamington Town Centre, which will cease to be just that, a centre. If the proposed new levels of housing are built south of the river, this will skew the demographic across the District, the Town Centre will become increasingly irrelevant as new residents access retail outlets and supermarkets located south of the river. At a time when Town Centre retailers across the country are struggling, I am shocked at the District Council's blatant disregard for the local economy and their willingness to plan the decline of Leamington Town Centre.

I would like to object specifically to the following areas of the Local Plan:

Level Of Growth
I am not convinced that WDC's required number of houses is based on sound analysis. Recent projections by respected local planners suggest that the District Council has over estimated the need. I am concerned this has been done for expediency, to ensure the Local Plan is passed upon eventual government Examination. Also, I am not convinced that WDC has effectively exercised its Duty to Co-operate with Coventry in cross-boundary housing provision.

Location of Growth
The Local Plan should make more Green belt releases to the north of Leamington. As mentioned above, a spatial rebalancing of the urban form is required away from the southern edge of Whitnash/Warwick/Leamington. This surely would be sound planning practice, creating a more rounded urban area, enabling greater accessibility for the Town Centres (Leamington and Warwick) with them forming two central hubs. If the proposed developments to the south take place, Leamington Town centre will no longer be 'central' to the District's urban area.

Myton Garden Suburb
The proposed development here will result in a coalescence of Warwick, Whitnash and Leamington. Additional traffic on Europa Way and north under the railway would pose serious concerns.

South of Gallows Hill
This area of land is highly visible and covering it with houses would impact on the backdrop of Warwick castle, damaging the local tourism industry upon which numerous businesses in the local area rely. In planning terms it is not a logical extension of an existing urban form, but instead would create a peninsula of development to the south.

Whitnash East
In the immediate vicinity of this site there are areas of historical and conservational interest which must be preserved. I am doubtful that the cost of relocating Campion School in order to gain access to this site can be justified by the number of new houses proposed.

Warwick Gates Employment Land
I am concerned at proposals that this land be reallocated for housing when there is no other land in the urban area that offers this amount of high quality land area for employment in such an accessible location. Why is the proposed housing density in this area so low?

Woodside Farm
Access to the development is a major concern. A single access point would isolate the development from the existing community and create such a volume of traffic that it would be simply unsustainable. How can the significant cost of highway improvements to provide two access points be justified even if physically possible? The proximity of Ashford Road and Harbury Lane junctions surely precludes access via Tachbrook Road and access via Landor Road is precluded by the current road alignment and lack of vehicle capacity. Our local road infrastructure simply could not cope with the numbers of new cars this development would bring. Increased air pollution and traffic noise are real concerns, alongside the danger posed to pedestrians (particularly children) of residents from the new development using Othello Avenue as a cut through to access local shops. The National Planning Policy Framework clearly states that development will not be permitted where it generates significant road traffic movements unless mitigation measures are used to avoid adverse impacts. I do not see any convincing evidence that mitigation measures will be adequate enough in this instance.

The visual impact of this dense development, 83m above sea level compared with 65-68m for established housing in the area, would be unacceptable, making it highly prominent in the local landscape. Furthermore the fact that some houses will be up to three storeys high raises significant concerns of privacy for existing dwellings. Attempts to mitigate this issue using trees for shielding will likely bring problems with shading and access to natural light.

The area proposed for development has steep inclines, as steep as a rise of 5m in 40 (1 in 8). Flooding from the fields is already a concern for those houses that back on to the Woodside Farm area. Given the density of the proposed housing, I am very concerned about the effect of considerable new water run off from hard surfaces in a new development, and the potential flood risk this would pose to existing housing backing on to it.

Woodside Farm is Grade 2 agricultural land. With growing population rates and domestic food production demand rising, it is fundamentally unacceptable to build on land of this quality when brown field sites are available.

Fieldgate Lane/Golf Lane
How is this site going to be accessed? The junctions at Coppice Road/Morris Drive and Whitnash Road/Golf Lane do not have the capacity to cope with the additional traffic these developments would bring, particularly at peak periods.

I wish to respond and object most strongly to the Revised Local Plan. The first point I would make is that the process seems hopelessly flawed. In 2009, before the last election, the fields between Myton Road and Europa Way were earmarked for development and residents in the area objected formally in their hundreds. (Please check records. ) Yet in 2012 the Preferred Options once again earmarked this area: this time for far more development. Last year again we objected. Why is the consultation process not taken seriously?
Level of Growth
It is my understanding that during the last 12 or 13 years Warwick has undergone a large increase in population, indeed 12% since 2000, which is approximately twice the rate of increase for Warwickshire and twice the national average, and indeed three times the increase for the West Midlands. I would therefore strongly question the need for this level of growth and object to it.
Broad Location of Growth and Transport
I object to the urban fringe development of fields to the West of Europa Way. As no doubt you are aware Warwick has geographical limitations because of the river and the historical centre. Traffic from the Myton Road area is funnelled onto the Banbury Road Bridge and through the constricted town centre. The Revised Local Plan would necessitate that perhaps an extra thousand cars per day would need to cross Warwick in order to reach the A46. As someone who lives and works in Warwick and takes the children to school in Warwick, I foresee massive irresolvable problems with traffic by increasing the number of cars on roads which cannot be improved or widened.
I object to the proposed development of this area with relation to traffic on Myton Road. Myton Crescent is impassable for half an hour at the beginning and again at the end of the day due to Myton school traffic. Similarly, the Banbury Road end of Myton Road suffers in the same way when Warwick Preparatory School and Warwick Senior School begin and end.
If new employment is being created in Coventry and Gaydon, surely the sustainable planning option would be to build dwellings there? Alternatively, local villages where there are good transport links and the potential to improve road access should be developed, rather than the urban fringe development of Warwick. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46.
Historic Environment and Green Infrastructure
I object specifically to developing the area west of Europa Way. It was designated an area of restraint when building work on the Technology Park took place. The notion that the Myton area will be some sort of 'garden suburb' seems to be nonsense when you look at the number of buildings proposed and the impact on the environment.
Climate Change
I try to walk my children to school when I can and I am horrified by the discovery that the entirety of Warwick town centre road network is in breach of Nitrogen Dioxide levels. This problem has been in existence long before the Preferred Options have been set out (Warwick District Air Quality Action Plan 2008), and remains in breach of these regulations today. I object to the increased public health risk which adding more cars to the centre of Warwick at peak times will certainly contribute to. Slightly outside the centre of Warwick, anyone who lives in Warwick knows how congested Myton Road is for 1.5 hours at the start of each day and again from 3.30pm until about 6pm at the end of each day. I walk past stationary vehicles and noxious fumes as I walk my children to and from school. The new Morrisons has increased congestion further. The idea of adding thousands more houses to this area and cars to this road network is desperately poor planning.
Myton Crescent floods whenever we have heavy rain, even if only for a short period of time. Houses in Myton Crescent and The Malins are at serious risk of flooding if the relief offered by the fields on the area of restraint were to be removed by building on these fields. The Revised Local Plan would seem to me to be negligent in that it is not future-proofing residents against our increasingly erratic weather patterns. I attach a photograph taken this week to stress my point.

I wish to object to the Local Plan and its emphasis on putting 4,500 homes south of Warwick on the following grounds:

The numbers of homes proposed are far greater than the local need of about 6,000, and a considerable number of these can be accommodated within brown field sites and where planning permission is already given

The proposal to build south of Warwick is illogical in that employment is generally north of Warwick, towards Coventry, and traffic would be required to cross Warwick / Leamington on roads that are heavily congested at peak times. The suggestions to mitigate the problem by changing road junctions is not credible. Creating a commuter area where everyone has to travel some distance to work is not sustainable.

The growth of Warwick, and associated traffic will increase pollution, which is already exceeds permitted limits locally, to encompass the schools on Myton Road, which would further endanger the health of thousands of children.

Specific proposals to develop land owned by Oken Trust and Henry VIII trust West of Europa Way endanger Myton with flooding. The risk is such that the proposals acknowledge this in including 'Sustainable Urban Drainage' SUDS within the initial plans. Recent published material and guildlines indicate that if SUDS are proposed, then it is probable that building should not be carried out on that land anyway.

I believe the plan should looked at afresh, so that any large developments should be able to stand alone in terms of infrastructure - schools, transport, health, drainage etc, without relying on Warwick / Leamington s historic , and limited resources to absorb their demands.
This will mean that land owners and developers will not be able to make a killing, because they will have to cost in the infrastructure, rather than the Councill tax payers having to pick it up

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I object to the the proposed local plan on the grounds that;
There has not been sufficient evidence put forward on the requirement for 12,000 new homes and there is contradictory evidence for this requirement.

The plan to only build in the south of the district is unfair to the local residents and will has a serious impact on there quality of life.

I do not believe the reasons given for not building on greenbelt land in the north given that the same council has given permission for greenbelt land to be used in the Gateway project.

The local infrastructure cannot support such a massive development with the schools would be overloaded the local hospital and GP,s could not cope with up to 20,000 extra residents.

The road infrastructure could not cope with the extra volume of traffic, being an out of town development most of the new homes would have a car with professional people probably having two which would be an extra 16,000 plus cars on the roads. Many of those new residents would have to travel though the Viaduct or Castle Hill to get to work, two areas that are already congested.

There will be a serious risk of flooding if the farmland behind Saumur Way is built on.

School children using the footpath that runs past the end of Saumur Way will be put at risk by the extra traffic crossing it.

I dispute the need for 12,000 houses in Warwick District as independent sources indicate less than 6,000 required and ask what is in it for the council to build so many houses.

Such a massive development would turn the historic town of Warwick into an urban sprawl.

The already overstretched infrastructure cannot cope with what would be a massive increase in traffic, being out of town most people would have a car, working couples possibly two. The road bottlenecks at Castle Hill and the viaduct cannot cope with thousands of extra vehicles.

I dispute that no building can take part on the green belt to the north as the council have already allowed green belt land to to be included in the Gateway project.

I object to large areas of farmland being built on as this will have a serious impact on wildlife with the removal of hedges.

There also a serious risk of flooding in the Aragon Drive / Saumur Way area if the adjacent farmland is cleared.

Allowing traffic to access any new building behind Saumur Way will increase the risk to the many school children who use the cycle path that runs past the proposed development.

The council is being less than open about the developments as the plan calls for 12,000 homes but only 6,000 identified so far. With no building in the North of the district the other 6,000 can only be built in the South but WDC have been evasive when asked the question about this.

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