5.1.13 Infrastructure Requirements

Expansion of existing secondary schools seems like a bad idea and put additional pressure on existing schools and infrastructure in the area. Building a purpose modern school to serve the needs of Warwick Gates and the South Sites would reduce traffic issues and build more of a community feel to the area.

Special needs provision should be made at new schools, putting additional pressure on existing schools doesn't feel right.

These seem very well thought out proposals which include far more quality of life considerations than the 2012 plan. The transport mitigation details look very feasible and the country park proposals are a huge improvement as there are large areas in this region with no public footpath at all at present. I warmly welcome the cycle track provision proposals.

increased traffic flowing through warwick town centre

Whilst we note an intention to make adequate educational provision for this area we note that previous efforts (Warwick Gates) have failed and have limited confidence in delivery.
We note the general style of highway improvements proposed and fear these will both increase the urbanisation of our rural area and also fail to deliver the capacity which such developments will demand/require and there will be significant knock-on impact on all the adjacent areas especially the "rat-run" villages who currently suffer significant commuter rush-hours traffic. 5.1.32 - 5yr supply is clearly open to challenge and is a WDC self inflicted obstacle!

These road improvements are unlikely to be adequate for the increase in traffic caused by such a concentration of growth to the south and will severely urbanise the area.

The GREEN INFRASTRUCURE proposals are good and should be increased to take the Country Park across to meet with Warwick Castle Park

Reorganization within the NHS is not an excuse for failing to properly consult and plan health development.

Warwick Hospital is the only general hospital in district and serves communities as far as south Warwickshire. With closures and downgrading of services at other hospitals it is coming under pressure. For example maternity has nearly 50% more deliveries now than 15 years ago and occasionally closes due to lack of beds or cots. The A&E is failing to meet waiting time targets which is indicative of other wards in the hospital becoming full.

As a land-locked site it is unable to expand but for the proposed levels of housing, it must expand its services to cope with the increased population. Will the expansion be upwards on the Lakin Road site by building tower blocks or will land be put aside for re-development elsewhere?

Ref Para 5.1.21
Sport England has been supporting WDC in the preparation of the playing pitch strategy and sports strategy. Therefore we support this statement.

Infrastucture investment will need to be put in place before develop and not as an after thought. Education provision needs to be planned all the way up to 6th form to cope with the additional number of school pupils that will result from the development.

Improvements to the road network need to be take into account access to the major services of the area are north of the canal/river. Improved river crossings may be required and will not be easy to implement.

Although road and junction improvements are planned these will not ease the points where roads cross the river,canal and railway where improvement is not possible snd with the increase in traffic volume these points will become bottleneck. It is doubtful that it will be possible to provide the necessary schools and local facilities from the Developer contributions through Section 106 and the Community Infrastructure Levy.

The improvements included in the plan are needed now to help with the current congestion at various times of the day. If the proposed number of houses where built the improvements will be inadequate.traffic volumes will be massively increased and due to canal/railway crossings which cause pinch points, there is no realistic solution.

The drive for growth on this scale requires inevitably huge infrastructure improvements. We just don't want this amount of destruction of our town.
Reconstruction of roads, bridges etc to double the width, to conduct larger numbers of cars about will destroy the county town and its peaceful environment.
5.1.1.27 Local people neither want or need an additional 12,300 homes. It is a complete misinterpretation of statistics. It is not necessary to have this level of growth at all.

I do not believe that the proposed highway improvements will mitigate the expected severe impact of the levels of housing increase that is proposed. It will also have the effect of severely urbanising the area.

I don't believe that these are needed because the housing is not needed.
The County Park idea to buffer Bishops Tachbrook from urban sprawl is inadequate.

To much Traffic for these to make a difference

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.

Infrastructure
It is important that the infrastructure is put in place first eg the schools and Community centres and the roads and shops. Based on past experience at Warwick Gates it would be helpful to have an endowment fund for running the Community Centre as many of them cannot pay their own way

This plan still fails to address the shortfalls of the current infrastructure let alone look at the long term needs of the Warwick and Leamington.
There needs to be some means of linking the two main routes between the towns to provide flexibility and better flow control rather than forcing all traffic into the congestion hot spots at either end. Consideration also needs to be given to provide a means of linking Whitnash and Cubbington/Lillington as the current situation forces all traffic either into town or to use M40/A46 routes that already have difficulties with the current levels of traffic

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.

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

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

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

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

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

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

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

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

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

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

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

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

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

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OBJECTION TO THE LOCAL PLAN FOR THE REVISED DEVELOPMENT STATEGY

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

My major objections are as follows:

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

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

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

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

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

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

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

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

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

In the last 15 years 2 large developments have been built; one by the racecourse and the other on the edge of Whitnash. The result has seen a substantial increase in traffic on all roads leading into Warwick Town Centre yet the road infrastructure hasn't expanded to cope and of course the geography of the area means there is a limit on what can be done.

I travel through Warwick Town Centre everyday to get to work and on many occasions it has taken me almost 20 minutes to journey the short distance from my house opposite Myton School to the roundabout at Bridge End a distance of half a mile. In the evening, I have crawled down Jury Street again for 20 minutes or so during rush hour and this distance isn't even a quarter of a mile. I have also watched traffic heading into Warwick during the evenings from the Business Park behind Warwick School crawl for an hour into Warwick. This summer during the period of road works leading to the New Supermarket at the end of our road I have observed cars and buses take 1/2 hour to drive 200 metres past our house on Saturdays. Once I got caught in this traffic and it took me one hour to reach the roundabout by the new supermarket.

Clearly, we all have to live somewhere and I don't object in principle to the building of New Houses but I have to ask if those who have drawn up these proposals actually experience the problems of getting about Warwick in any form of road transport during the busy periods or when any sort of work is being done on the local infrastructure.

Maybe I could suggest building a road through the grounds of Warwick Castle to bypass the Town Centre? Of course this is preposterous but it appears that building in effect a small town next to a small town isn't!

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