4 - DS11 (H39)

Local Plan Focused Consultation December 2014 including Stratford Road Gypsy & Traveller permanent site at Stratford Road.
from Bishops Tachbrook Parish Council

Part A - Personal Details

Sean Deely, Chairman, Bishop's Tachbrook Parish Council.

3. Notification of subsequent stages of the Plan.
Please specify whether you wish to be notified of any of the following

The submission of the Plan for independent examination Yes

Publication of the recommendations of any person appointed to carry out an independent examination of the Plan Yes

The adoption of the Plan Yes




Part B - Your representations
Representation 1
4. Which part of the plan does this representation relate?
Focused changes
Paragraph number REFERENCE 1.
POLICY number DS9
POLICIES MAP 2(Reference 5, 11 & 12)
5. Do you consider the Plan is:
5.1 Legally compliant? Yes
5.2 Complies with Duty to Co-operate Yes
5.3 Sound? Yes
MODIFICATION Delete 8ha employment land north of Gallows Hill & 3.7ha at Opus 40 & add 11.7 ha employment land at Stratford Road Warwick.
Bishop's Tachbrook Parish Council SUPPORT this amendment
Because a) It is a better employment location than Europa Way because it is immediately adjacent to the M40 junction 15. This would minimise any resultant traffic on Warwick Town Centre. The Europa Way employment location would have added significant additional employment related traffic on both Warwick and Leamington as well Europa Way itself and Greys Mallory roundabout and the links to junctions 14 and 15 on the M40. The modification is betteras it reduces traffic congestion, air quality in the towns, traffic noise to the new residential areas and global CO2 emissions.
b) It releases land on the 2 sites for residential use and in the case of Opus 40 increases the amount of brownfield utilised in the Urban area.
c) It improves compliance with Strategic Policies DS3 (b), (c), (e) & DS4 (a) & (c).


Part B - Your representations
Representation 2
4. Which part of the plan does this representation relate?
Focused changes
Paragraph number REFERENCE 2 & 3.
POLICY numbers DS11 & DS14 SITE : H01
POLICIES MAP 2(Reference 6 & 7)
5. Do you consider the Plan is:
5.1 Legally compliant? Not certain
5.2 Complies with Duty to Co-operate No
5.3 Sound? No
6. If you answered no to question 5.3 , do you consider the Plan unsound because it is not
Positively prepared No
Justified No
Effective No
Consistent with National Policy No
MODIFICATION Amend the following in relation to land west of Europa Way to increase number of dwellings from 1,190 to 1,300 and add Infrastructure requirements and other uses : add "Community Stadium and associated uses".
Bishop's Tachbrook Parish Council DO NOT SUPPORT this amendment.
Because a) The number of dwellings stated of 1,300 does not reflect the capacity of the site released. If 8ha of employment land is released and a community stadium is located on 3 ha then 5 ha is available for additional housing. The local retail, medical and community facilities, including 4 football pitches and a running track that is available for community use, are already allocated at the southern end of the recently approved 735 dwelling proposal. Hence working on 35 dw/ha, 5 x 35 = 175 to add to the declared 1,190. Hence 1,365 dwellings could be expected.
b) 35 dwellings per ha is the density accepted for market homes. However, 40% of the site should be affordable homes. To be affordable a density of 50 dwellings / ha can provide a perfectly spacious layout for affordable homes particularly where one and two bed dwellings provide a reasonable part of the mix, as is shown in countless examples around the country. The affordable and market homes should be mixed, giving a better distribution of open space.
If 1,190 homes are built at 35 dw/ha As the current frat of the Local Plan, they will occupy 34 ha. If 5ha. are added to that, then 39ha are available. If market homes are built at 35 dw/ha and affordable homes at 50 dw/ha, then the capacity of the whole site west of Europa Way is 1,550 dwellings. (60% of 1,550 = 930, at 35dw/ha requires 26.572ha and 40% of 1,550 = 620, at 50 dw/ha requires 12.4 ha. Total land requirement = 39 ha.)
c) Proposed "Community Stadium and associated uses". This is described elsewhere as a 5,000 seat stadium with conference and other facilities to make it financially viable together with associated parking and other external facilities. Bishop's Tachbrook parish council OBJECT to the location of such a development as inappropriate for this area west of Europa Way which is designated for over 1500 houses. It is out of scale with new garden suburb residential development and the massing of a stadium of this nature will be an unacceptable intrusion. A stadium designed for and occupied by a professional football club conflicts with
* the interests of families growing up in this new residential area and
* the traffic implications when match days coincide with normal peak times would be totally unacceptable on Gallows Hill and the roads around Warwick, Leamington and down to the Motorway which are already overloaded before any new housing is built
* light and noise pollution from evening and night time games that would be disruptive to the residents;
* problems of pedestrian and vehicular movements within the housing complex as crowds seek to get to the stadium.

Current trends are to move stadia away from residential areas, not to put them close to new garden town suburbs.
The proposal appears to be uncosted and the costs will be high in
* land costs (even if county land, it must be accounted for at alternative use value that could go to the County if released for housing) and
* construction costs for the stadium, pitch(es) facilities (Stadium ground not normally used for training so additional training area is likely to be necessary), parking
* running costs that are unlikely to be met by gate income even if there are conference and other facilities attached.
These decisions should not be made without a well costed business plan without which the club could get into serious financial difficulties and the District Council would not be able to bail them out. The Ricoh Arena in Coventry is an example of what can happen.
d) If the stadium is moved to this location, it will take land that could be used for housing, moving the housing further out towards the valued landscape of the Tachbrook Valley. The net car travel miles from housing and pitch activity will increase. This does not comply with the NPPF either for protection of the natural environment, protection of best & most versatile agricultural land and unnecessary increased car miles, so it is not a sustainable development.
e) If the land is used for housing instead, then the capacity of the land west of Europa Way increases to 1,670. (60% of 1,670 = 1002, at 35dw/ha requires 28.64ha and 40% of 1,670 = 668, at 50 dw/ha requires 13.36 ha. Total land requirement = 42 ha.)
The Opus site gives a further 100 dwellings. That is a total of 1,770 dwellings compared with the existing allocation in DS11 of 1,190 which is an additional 580 dwellings. Thus, any further encroachment into the Tach Brook Valley on either Grove Farm or Lower Heathcote Farm is not justified to meet the objectively assessed housing need.
f) The proposal does not comply with strategic policies DS3 (a), (d), (e), and policies Be1 (a), (f), (m), Be2 (d), (h), Be3 & TR2

Part B - Your representations
Representation 3
4. Which part of the plan does this representation relate?
Focused changes
Paragraph number REFERENCE 4.
POLICY number DS11
POLICIES MAP 2(Reference 9 & 10)
5. Do you consider the Plan is:
5.1 Legally compliant? Yes
5.2 Complies with Duty to Co-operate Yes
5.3 Sound? Yes
MODIFICATION Add new site under urban brownfield H39 - Opus 40, Birmingham Road, Warwick
Bishop's Tachbrook Parish Council SUPPORT this amendment for the reasons set out in our response to Reference 1 paragraph (b) and Reference 2 & 3 paragraph (e).
11 December 2014

Part B - Your representations
Representation on Stratford Road Gypsy & Traveller Permanent site.
4. Which part of the plan does this representation relate?
Focused changes
Stratford Road Gypsy & Traveller Permanent site.
5. Do you consider the Plan is:
5.1 Legally compliant? Yes
5.2 Complies with Duty to Co-operate Yes
5.3 Sound? Yes
Bishop's Tachbrook Parish Council SUPPORTS the proposed site off Stratford Road, for the use of permanent pitches for the Gypsy and Traveller community. In summary this site offers a larger number of positive characteristics than any other site proposed during the previous rounds of consultation.
Specifically this site can better meet the health needs of residents, with a number of GP surgeries and dental practices within walking distance: Warwick Hospital is only a short drive away. Educational needs are well served by a number of schools also within close walking distance.
Access to and from the highway for articulated vehicles is made safe with excellent sight lines along the Stratford road in both directions. Also this site provides excellent access to major roads, the M40 and A46 which is important for periods of touring.
This site is lower lying and the proposal would have minimal impact on the local landscape and create negligible visual impact, particularly with the proposed landscaping. Flooding risk has been assessed as low and we note that the ecology report is awaited.
Finally the site is well served by public transport and there are a range of amenities available in nearby Warwick.