H51 - Hampton Magna - Land south of Lloyd Close

As a resident of Hampton-on-the-Hill I am writing to OBJECT to the proposed modifications to the Local Plan regarding the increase in housing in Hampton Magna - references H51 and H20. The Draft Local Plan had proposed 100 additional dwellings in Hampton Magna and the 'Proposed Modification' has increased this number to 245.

Hampton Magna currently has 632 dwellings and the proposed increase will take this to 877, an increase of nearly 40%. Existing amenities are struggling to cope and will be unable to sustain such an increase. Schools and services are already overloaded and will be unable to function with the additional housing. To accommodate the additional housing will require a substantial investment in extending all amenities.

Access to Hampton Magna is by two principal roads (there is a third road which is a country lane - Ugly Bridge Road linking to Woodway and Church Lane); one is Hampton Road through Hampton-on-the-Hill and the other Old Budbrooke Road via a low headroom bridge (12 ft 6 inches) at Warwick Parkway Station. As a result heavy traffic enters along the Hampton Road through Hampton-on-the-Hill.

This situation is exacerbated by the recently extended development at Chase Meadow to1000 dwellings, many of whom use Hampton-on-the-Hill as a means of access to Warwick Parkway station and as a 'short cut' to the A46 and A4177. A traffic survey carried out in September 2015 showed over 18,000 vehicles a week come through Hampton-on-the-Hill. Roads in the Village already show substantial degradation with the current loading and will require much investment just to cope without the burden of the additional traffic. The quality of life in our village is already being fragmented and the additional traffic will destroy it altogether.

If additional dwellings were to be built in Hampton Magna, it would be essential to build a separate road into them from the A4189, Henley Road and factor in the costs of so doing. Such a road would not only improve the environment and traffic flow for Hampton Magna and Hampton-on-the-Hill, but could also be used by Chase Meadow residents to access the Warwick Parkway station, the A46 and A4177. Furthermore, the route of the road could be used to accommodate the additional services (drainage, water, electricity, telecommunications) which will be required for the new dwellings.

I believe the proposed changes are unsound and should be rejected.

I am writing to express my concerns about the local plan for Hampton Magna. I am aware that people need somewhere to live, however, can the present infrastructure cope? We have a flooding problem in Old Bugbrooke Road whenever we have a significant amount of rain which effectively reduces the road to a single lane. We have learned that it`s best not to leave the house to get on to the Birmingham road before nine in the morning because of hold-ups, a situation which will be made worse by building more houses at Hampton Magna. This road is already single lane a little further down because of the railway bridge. Please think again, otherwise a problem will become a nightmare.

Objections of the new developments H27 & H51 , in Hampton Magna.

We give our objections of the new developments in Hampton Magna, as follows.

The village facilities would not be capable to cope with the population increase & construction of the new developments.
Which include the following issues:-
- The medical centre resources.
- Utilities are over stretched , drainage & water.
- Power sub stations capacity.
- Highways safety, road capacity, means of access, visibility, car parking , pedestrians & cyclists. See photographs below.
- The environmental effect, noise & pollution.
- Further possibility of surface water flooding due to the increase of construction & run off.
- Education facilities , further over stretched.

The area itself will lose its character & privacy, together with its community.

1) With these latest modifications now showing a proposal of 245 extra homes at Hampton Magna, bringing with it a foreseeable additional daily movement of vehicles in excess of 500, we strongly urge, even at this late stage, serious rethink on the effect this would bring to the village area.

2) An overview of the Village area shows three entrances: -

* The main entrance being that from the Birmingham Road, encountering, traffic light controlled - single lane - height restricted railway bridge.

* The second entrance, located further up the Birmingham Road alongside the filling station, is nothing more than a single traffic - lowly country lane - passing over a single lane weight restricted canal bridge - and going under a single lane height restricted railway bridge.

* The third entrance, is that passing through the small village of Hampton-on-the-Hill. This route is disciplined by a weight restricted, single lane - chicane controlled traffic flow - and is nothing more that a small country lane.

3) Taking these factors fully into account, it is therefore inconceivable that any authority would propose and support the implementation of a development that would result in serious consequences, due to the large increase in daily movement of traffic within the confines of these extremely restrictive approaches.

4) We state again that a rethink on this complete proposal of development within the village, must be carried out on an urgent basis.

I am a resident of Hampton on the Hill and wish to object to the proposed modification to the Local Plan regarding the increase in housing allocation in Hampton Magna from 100 to 245 units due to the lack of additional infrastructure. If additional housing is to be allocated to Hampton Magna then the following should be provided:-

1) As part of the new development a relief road should be constructed directly to the Henley Road to reduce excessive traffic flows through Hampton Magna and Hampton on the Hill.
2) A provision in the planning consent for the new housing which requires the developer to fund increased provision at the Medical Centre and School.

I completely endorse the objections raised by the Hampton Magna Action Group. However, I wish to emphasise some of the points raised under ' sustainability'.
These are:

- Convenience of travel to Coventry. if the extra housing is designed as overflow for Coventry, then it's a poor choice, particularly for public transport as there are no direct routes: by bus is a minimum of two hours and by train one hour plus a twenty minute walk to Warwick Parkway. So people will drive, thus adding to the nightmare of the junctions at Warwick Parkway, the traffic lights at the A4177 Birmingham Road and Stanks' Roundabout at rush hour and green house gases.
- Access to sites H51 and 27. Is planned to be through the village on residential roads and where there is already gridlock twice a day at the school's opening and closing times (Woodway Avenue, Cherry Lane, Slade Hill and Field Barn Road. The addition of vehicles for 145 new homes, preceded by heavy construction traffic will make flow through the village impossible.
A right of way around two sides of H51 should be noted.
- Parking. Is already an issue in the village; Warwick Parkway commuters, patients for the Surgery, parents delivering and collecting their children from the school. Developers never plan sufficient parking and undoubtedly there will be overflow on to village roads causing more gridlock and problems on the 68 bus route.
- Road Infrastructure. The roads and lanes giving access to Hampton Magna, particularly through Hampton on the Hill, have become rat runs for Chase Meadow residents and are already dangerous for cyclists, ramblers and dog walkers. The addition of vehicular traffic from the extra 145 homes will only increase the danger to unsustainable levels.

The location of these 145 extra houses on H27, and H51, which was previously rejected by WDC, turns Hampton Magna from a viable community, surrounded by farmland into another amorphous mass of housing overflowing from Warwick.

[INCLUDES PHOTOS]
1 Consultation

Warwick District Council did not notify Hampton Magna Parish Council about the new local plan until a briefing on 22nd March 2016. It also failed to allow extra time for the consultation because Easter was in the time period allowed. It, therefore, has failed in its duty to consult on the plan. The documents published by Warwick District Council are incomprehensible, and the form to be returned for objections is difficult to fill in as it is full of jargon and confusing.

2 Size of development

The density of housing on the site off Arras Boulevard, has been increased from 100 houses to 130. This is not in keeping with the rest of the housing in the village. All the houses here were built in the 1960s and, as such, are not built with the same character as housing today. They have also been extended in various ways to accommodate increasing families, so very few are identical, in contrast to the housing developments being built recently in our locality. The new houses will therefore be unlikely to blend in, but also due to the density of the proposed development, be unlikely to have the same propensity for expansion. A large number of residents have been able to remain in their homes here, because of this, and that also means that the housing the village needs, tends to be bungalows, so that the older generation can down size, and first time housing for the children of older residents who would like to stay here. As bungalows tend to need a larger plot, and be less profitable for developers, there is real concern that the village will not get the housing it needs.
The new plan increases the proposed housing in Hampton Magna by 41%, which is a huge increase for a village of any size.

3 Infrastructure issues

There are 3 roads into the Hampton Magna. The main route in is Old Budbrooke Road, which is both height and weight restricted and is traffic lighted under the railway bridge as it is single carriageway there. This is already a traffic problem at rush hour in particular, with traffic to Warwick Parkway railway station, traffic to Warwick, and traffic for the A46, all queuing to get out of the village. This road also floods in heavy rain further towards the village and that means a single lane is then available for traffic there too .
The Ugly Bridge road is also height and weight restricted, due to the hump backed bridge just after the Birmingham Road, and the railway bridge that it passes under. It is a country lane with few road markings, and vehicles have to go on the verges to pass each other.
Hampton Road comes in through Hampton on the Hill, and is mostly down to one carriageway due to traffic calming measures and parking in that village. There is a narrow exit from the village and also a passing place part way along the lane towards Hampton Magna. There are limited road markings.
In addition the Hampton Road and Ugly Bridge Road are used as a cut through to the Birmingham Road by the residents of Chase Meadow, and Hampton Road is a cut through to Warwick Parkway from the Longbridge Island and new A46 island.

To accommodate new housing there would need to be a new road, both in and out of the village, either from the A4189 or the A46. The existing roads could not deal with the predicted 426 vehicles associated with the new houses. The only way to access the proposed developments is via Arras Boulevard, and Daly Avenue, and Minster or Mayne Close, all of which are estate roads or cul de sacs, and were certainly not designed to be thoroughfares.

The plan's only concession to the transport problems, is to make alterations to the roundabout on the A46. Although this is frequently part of the queues into or out of Warwick,this does nothing to help cope with the extra traffic in and around the village, with the existing inadequate roads, and more housing only means more congestion. (Warwick, as a medieval town already has its own traffic problems because the roads were never meant to cope with the volume of traffic there.) There will also be a worsening of public transport as the bus already struggles to get round the narrow roads, and often ends up mounting the verges and pavements to get past other vehicles. The previous Village Sites Appraisal Matrix mentions the major negative transport effects given the site capacity of over 100 dwellings, yet this has been ignored in the new plans.

The water systems in Hampton Magna are already under strain, both the supply and the sewerage, and as above, the surface water drainage; as it was installed when the village was built in the 1960s. There are often complaints to the Parish Council, and although Severn Trent is trying to resolve these issues, it is certain that the drains would feel the strain with even more housing.

In my 30 years of living in the village there have also been substantial alterations to the electricity substations, which used to cut the power off quite frequently before they were altered. I doubt they could cope with the extra consumption of the development.

The plan states we have a primary school, doctor's surgery, shops, a post office, a pub, and village hall. Whilst this is true, the shop is a small Costcutter, with part of the counter used as a post office inside. It has a limited range and it would be difficult to find everything there, as there is a very limited selection of fresh produce, for example. The other shops are a beauty salon which seems to do highly specialised beauty treatments such as permanent mascara, and a church related, volunteer run, coffee shop. The doctor's surgery is completely enclosed by the school, community centre, shops and pub, with a very limited amount of parking behind the shops, which is usually full when they are open. In addition, they have a limited capacity for patients and doctors which would mean increased waiting times for all patients. The primary school has a limited capacity too, and if, as is outlined in the plans, it would have to take pupils from the proposed extra 175 houses at the Hatton development (due to the lack of capacity of Ferncumbe School in Hatton) this would exceed it's capacity. The school is surrounded by the community centre, the doctor's surgery and the shops and houses, and as the school playing field has been deemed unsuitable for building, there is nowhere for it to expand. Parking is already a huge problem in the village, especially at school dropping off and picking up times, when there are cars in every direction parked around the school. In Slade Hill, Cherry Lane, Woodway Avenue, Ryder Close, Field Barn road as well as Styles Close, it is hard to walk past them, as they are parked on the pavements and roads, making crossing the roads very dangerous. The village also struggles with people parking on the other side of the village in Field Barn road and Blandford way, to avoid the parking charges at Warwick Parkway railway station.
4 Land choices

There are a number of problems with the proposed sites, which are all green belt sites. A major drawback for the village is the loss of one of the best views in Warwickshire, over towards Warwick Castle and Northgate church, from the site off Arras Boulevard. This would be a very sad loss for all residents.

The only land that has been considered in the village are 2 plots which the owners wish to sell. They are not joined except by the corner of both sites, and therefore will create twice the amount of disruption to the village, given the limited access.

One of the points made by the plan, is that some of the extra housing is to alleviate Coventry's housing requirements. There is no viable means of public transport to Coventry from Hampton Magna, as the bus journey is over an hour, and the train journey would require a journey into Birmingham, and then catching a different train out again to Coventry, which would also take more than an hour. Therefore, anyone wishing to work in Coventry would be travelling by car on the A46, a 20 minute drive along an already highly congested route at rush hour. There are other areas, much closer to Coventry, such as Bubbenhall, which could be expanded, where there are likely to be more employment prospects than in Hampton Magna. As the train line at Warwick Parkway goes from Birmingham to London, it is much more likely that any new residents would find employment there, and not in Coventry.

During the heavy rains recently, the A46 was restricted to one lane, when water from the field drains flowed straight across the road, causing chaos. One can only imagine what will happen if the new houses are built, as proposed, on the fields above the road. The land south of Lloyd Close is vey poor draining, as it is mostly clay, and as now, when the water table is high, water just sits on the land. This can only add to the water heading down to the A46.

There have been prior notices given to Warwick District Council that there are bats nesting in the area South of Lloyd Close, but this isn't mentioned in the plan, and does not appear to have been investigated.

In addition, there are other green field sites available in Warwick District where a new development could be built as an independent site. This would mean that all the amenities required, such as schools, shops, doctors, pubs and village halls, could be built by the developers as part of their obligations, and this burden would not then come from the public purse. There are clear precedents for this, given that Hampton Magna was originally built and provided for in this way.

Conclusions

The new plan is not sound for Hampton Magna, due to the lack of consultation, the size of the development, the density of the housing, and the multiple problems with infrastructure here. An increase of 235 dwellings, a projected 588 extra people, will strain all local infrastructure beyond it's capacity.

As the air quality is already poor in the village -my doctor referred to it as the sink hole of Britain, because all the pollution sinks to ground level here, meaning high levels of asthma and breathing problems - any increase in traffic is going to cause further health issues. The inevitable outcome of the extra projected 400 odd vehicles, is more congestion, and more pollution.

Coventry is not readily accessible by public transport, so adding extra housing to the plan for their need is pointless. The scale of the increase in the development, 41%, in the village that is least accessible, and only has access to Coventry by car, is disproportionate and unreasonable.

By failing to properly consider other sites, such as the land next to the A46, as well as independent sites within green belt, the plan fails to meet either the needs of the village or of Coventry.

I live down Daly Avenue and am saddened to see that we have been allocated to access points. I understand the need for extra houses, but cannot understand why anyone would allow all the necessary construction traffic ( may not get under the train bridge anyway) and then the individual residents who would then occupy these house to have to travel right through the whole village to get to the new houses, ie Daly Avenue. Daly avenue is a narrow road to start with I am unhappy with the amount of extra t cars this would generate travelling right outside our houses / road every day ...

The traffic is bad enough getting in and out at the traffic lights on the Birmingham road as it is and with the train station the over flow of parking is slowly increasing with in the village for train users . Plus Hampton on the hill is a bottle neck at the best of times with traffic using it as a cut through from Ugly bridge road at Hatton to Warwick & Norton Lindsey to gain access to the M40 ..

My main complaint is that the additional land proposed is "GREEN LAND" . Some residents down our road have been refused planning permission to extend their house forward by 1 foot, as its on Green land but you can allow all these houses &

I have been refused to have a drop kerb as its not in keeping with the area, well 500 houses is not in keeping with the village, espsically on what is supposed to be Greenland.

I do not believe that the sewage system in place here already would cope with the additional houses, the environmental impact, the noise and the light pollution would greatly spoil the quality & standard of living here and we just don't have the infrastructure to cope.

The extra houses will put unacceptable pressure on existing services like the doctors and the school in particular .

Lastly and most importantly if the council are justified in ruling out compulsory purchase of non green belt sites , have they considered other alternatives in the green belt area that would not adversely affect existing settlements . 17 hectares of land off the Hampton Road opposite central ajax has been advertised for sale during the review and is more than capable of accommodating 500 homes, why has this not be considered.

I believe the plan is not legal.
There has been no further consultation with the neighborhood since
since the planned was changed.
2. Council have failed to communicate in a manner that the average person can understand and not made available to everyone online.
3. The consultation was very short and over Easter Holidays.
4. Due to short period of the consultation there were no time to scout out other sites. A43 acre area off the Hampton Road is up for sale.
5. Self builds are not available so does not compliant with the National Planning Policy.
6. The plan is not sound so is unsustainable.
7. The increase in density is higher then it should be according to government specifications..

II. Infrustructure

1. Roads Local traffic situation of peak traffic now is time restriction on the A4177. Even with some changes to increase Stanks roundabout will need more changes. Old Budbrooke Road will still face long waits with more traffic from the proposed new housing in Hampton Magna and Hatton.
2. There are only 3 single roads into Hampton Magna. It seems that that was never considered. More traffic especially the volume will be very dangerous as well as the congestion it will cause.
3. All ways of leaving Hampton Magna are single tracks. Ugly Bridge is a county bridge that is very anrrow. Two single tracks to the A4177 under a railroad and a single road through Hampton on the Hill due to parked cars.
4. The alternative ways of commuting from Hampton Magna will not work if commuting to Coventry. There is not a train line, there is not a bus so the only the way to commute is by car. Trains to London are often at capacity.
5. Supply lines, water, electricity, sewers are not fit for purpose. The systems are very old and there are regular problems. Electric is not reliable, supply pipes have burst several times in the past 12 months,


and lockages of sewer lines as well. With no modifications planned the systems will surely collapse.
6. Bat species in and around site South of Lloyds. This will have a significant detrimental affect on the protected species and their habitat.
7. The amenities while look on paper is not a true picture. There is a small shop with a post office, a Café that accomadates about 26 people a surgery where appointments take sometimes a week to get unless there is an emergency.
8. There is a right of way on the site.

In conclusion, at the present time there is an 800 surplus of homes planned so with all the problems at the Hampton Magna site why is this planned to for over 200 homes more then any other village.

Regarding proposed increase in new homes from 100 to 245., at the above location it will hugely increase the population, and strain the infastructure.

Both locations are Green Belt, I understand that David Cameron pledged protection of Green belt. What sort of a legacy are we leaving for future generations if we build on Green Belt.????? In the Mansion House speech, George Osborne stated in 2014 that there is enough Brown field land in England for 2.5 million new homes , a large proportion of which are in London , so why not build on them???? Also he stated we are a small crowded island keen to protect our green spaces.

There are ALWAYS infastructural issues here with, water leaks, drainage and sewer problems , roads and narrow lanes with potholes , school, and doctors surgery .
Flooding on 9th March on A46 , and the Budbooke Road, caused traffic to come to a standstill all around here, there have been no improvements at all over the years we have lived here , and we now have M40 producing more traffic on all adjacent roads and lanes with the pollution and noise that goes with it., plus Warwick Parkway Station. Train users park all over the place in Hampton Magna causing obstruction. All we have is a country lane in and out of the village unable to cope with all this traffic., and a confusing traffic lights sequence at the junction on the Birmingham Road. A4177. If there was to be a major emergency think the fire, ambulance and police would have difficulty arriving quickly here.

What are your reasons for not considering land off Hampton Road 43 Acres SP2663 3057 which was available for purchase round about August 10th 2015.???? or land at Stanks Farm adjacent to Warwick Parkway. Both of these sites are nearer to the main roads and Motorway.???? and will interfere much less with Hampton Magna .

Instead of viewing beautiful GREEN BELT, green fields, vegetation, hedges and trees, visually the new housing will cause gross disturbance while it is being built, visually it will be unattractive as we look down on field H51, and we will be exposed to much much more air pollution, noise pollution. Instead of hearing sky larks and seeing many wonderful birds, including swallows swifts and house martins . Yesterday I saw 2 buzzards and a wren, sparrows, starlings dunnocks, blue tits, longtailed tits and great tits , and wildlife, we have bats ,which we see every summertime, plus frogs, toads, moles, shrews and field mice,hedgehogs , grass snakes and deer. Also the wild flowers along the hedgerows. Where will all this wild life disappear to???????

There has been a huge increase in noise levels particularly the last 10 years or so from the M40 and of course more traffic on the A46,, particularly in the summer when we would like to be in our garden and be able to leave a bedroom window open overnight, unfortunately because of too much traffic noise we are unable to do this anymore , this can only get much worse ,

Public safety issues. Hampton Magna is a village of pensioners who have lived here since Hampton Magna was built as a new 60,s village on the Budbrooke Army Barracks. home of the Warwickshire Regiment .., They may have visual, hearing or mobility issues and there are lots of young families., where the children can play safely outdoors.
.It has always been a safe place to live., no dangerous avenues or roads, very little crime ,theft, vandalism and drug issues. We would very much like to keep it that way.




HOW THIS AFFECTS US PERSONALLY

Our property at one point is not much more than a meter from the hedge boundary.
Our house at the back is facing SSW we have 5 windows and 3 french windows overlooking H51 what about our gross lack of privacy .
Gross loss of day light and sunlight.
House would be overshadowed by this development.
Street lights will be blasting out instead of a dark open space .
Increased risk of vandalism and crime because of the public footpath along the length of the hedge, as will end up being a cut through instead of a pleasant fields and hedgerows and public footpaths for ramblers, dog walkers and families.
Woodway Avenue will become a dangerous road too for adults and children alike due to the extra daily volume of traffic , already with residents cars, visitors cars, school parents cars , tradesmen and cars from the Station parked all over the place it is becoming more congested....






I accept that there is some need for new housing in Warwickshire, but NOT the huge amount that seems to be happening all over the county, why cant you build on Brown Field sites first.????

In Hampton Magna certainly a small amount of housing suitable for first time buyers might be appropriate plus some sort of suitable dwellings for older couples and singles,WITH some outside space, maybe with a balcony . NOT rabbit hutch size retirement dwellings or flats.. If you want to encourage residents out of their nice 3 and 4 bed houses here in Hampton Magna you need to build something that will have appeal, freehold too. that they can buy . There are many many folk here that have lived in Hampton Magna since it was built nearly 50 years ago. and have no intention of moving away from here. great care and thought should go into the final plans of what is chosen to be built here.

Do hope that this can be sorted out. We are really concerned about the future ,once Green Belt is built on it has GONE FOREVER, for future generations , we are custodians of this beautiful green and pleasant land and should respect and look after it.. All this construction on Green Belt in Warwickshire., and the rest of the country., just cannot be the right way to do things.

After attending the Parish Council meeting, the thought that I came away with was why we should suffer because Coventry fell short with new builds.

We bought our House for the reason that Hampton Magna is what it is, a rural friendly Village, why should we suffer because of shortfalls from other Councils and our Village life become part of a Town.
The traffic when problems occur on the bypass already make Hampton Magna a 'Rat run', more cars will not only make this worse, but there is pollution and safety to consider, we already have a cross section of ages in the Village and at the moment it is safe for the Young and the Elderly to walk/cross roads, there are also many domestic animals to consider. The parking around the School is already at a premium, where will all the new cars park?
The Doctors at present is a small friendly practice where they will if possible always try to accommodate you as soon as possible, how will this happen with an extended demand?
The proposed new build will also dramatically affect the Wildlife and Public footpath in the fields along with for many residents a wonderful rural view, why should that suffer, does the word 'Greenbelt' have no meaning?
The Lorries that would be a continuous blight on our lives for many years whilst the building takes place will have a long term detrimental effect on all the residents with both noise and mess along with traffic delays as the Village only has one way in and out, which then also has an effect on our day to day working life.
I really don't think this has been thought through properly, there are other sites, that are not Villages in Warwickshire that could be built on and I am very disappointed that they are not being considered instead.

With regard to the number of houses to be built in Hampton Magna, I outline a few relevant points.

When we moved to this village in 1973 there were originally 6 shops and now we have only three, the other three have been adapted for housing Therefore with regard to parking outside the shopping area, the parking spaces have been taken over by villagers cars. Obviously this means there are less available parking places when children are dropped off at school. I used to walk my grand-daughter to school every morning, so am fully aware of the difficulties, particularly with regard to parents bad parking, causing big problems for the buses to negotiate their way round them. On a couple of occasions the bus driver has asked me to help with regard to guide him through the badly parked cars!

As you are aware there are problems getting on to the Birmingham road in the mornings. Many a time appointments in Coventry have had to be cancelled because of not being able to get out on to the Birmingham road, as the traffic lights are constantly remaining on red as the cars are at a standstill.

Please note my objection to the increase in house numbers for land H27 and H51 in Hampton Magna.
I understand that new houses must be built and raised no objection to previous plans. The revised plans more than double the original plans to 245 homes and appear to offer no improvements in infrastructure or services.
I would be more accepting of the plans if improved vehicle access were to be built, ideally from the A46. This would of course add huge expense but this would help me consider accepting new plans. Perhaps another access route could be considered, maybe from the farm by the station.
I have concerns over increased numbers for the surgery and school.

I would like to register my objection to the proposed development plans for Hampton Magna.
I have looked at the plan and the information which has been made available and have many objections which I list below:
1) The plan breaches the guidelines set down by the government which indicates that the green belt should not be built on unless there are exceptional circumstances.
2) We currently have quite a good doctors surgery which generally gives good access to a doctor when needed, the development will certainly change this situation fairly dramatically. Being aware of the general shortage of doctors it's difficult to see how the service could be maintained at its present standard.
2) The traffic within the village and with the three routes out of the village are very high at peak periods and the increase of the numbers in the plan will have a very big detrimental effect. Within the village there is a bottleneck starting at the junction of Styles Close and the Fieldbarn road and extending up Slade hill and down Woodway Avenue as far as the Daly Avenue junction. The congestion is particularly bad during the morning rush period and pick up time at the local school and due to the high numbers of parents dropping and picking up children from other surrounding villages. I know that on occasions the local buses have difficulty getting down Slade Hill due to the parking. Any increase in capacity will inevitably draw in more pupils from the outlying villages which together with the increase as a result of this development would be very problematic.
On the routes out of the village the Budbrooke Road has a major problem with the one way traffic light system at the station and at the lights onto the A7177. It also occasionally floods during heavy rain fall. When you have negotiated these hold ups you invariable join a traffic jamb which extends all the way into Warwick and beyond. The route through Hampton -on - Hill has single lane bottlenecks and problems with speed. The route going west and exiting at Ugly bridge has issues with joining the A7177.
3) I believe that there are issues with the sewers and concern that the sewage farm at Stanks farm is close to capacity and unlikely to cope with an increased demand.
4). HM30 land together with the adjacent field verges and footpaths are used by many of the dog owners in the village and others as part of a circular route for exercise. Loss of this would erode the amenity which is currently enjoye

My views is that the Local Plan and Sustainability Appraisal (SA) are not safe. I believe the technical references are Mod Number: H27 and H51;
Paragraph Number; Mod Policies Map -H27 and H51 & Table of Proposed Modifications January 2016, Appendix C Changes, Policy Map 20.

I don't believe the Local Plan is Legally Compliant or sound. I feel it has not been positively prepared (by identifying a previously discarded site) or is justified in terms of services such as school, GP surgery and other services which could not cope with the additional families needed to be catered for with an additional 145 homes. It is certainly not effective in terms of transportation. Budbrooke is a rural village surrounded by narrow lanes accessible only via Hampton on the Hill or off the main A4177, both of which are only single carriageway roads reducing to traffic light controlled single lane flow under the bridge at the entrance to Parkway station. There is no prospect of improving the roadway width or capacity to cope with significantly increased traffic flow. There are significant delays already at school times and peak times with the railway traffic. There are some developments to be made to Stanks Island towards the end of the year but this will not impact on the heavy flow of traffic using the country lanes around Hampton Magna and cutting through the village of Hampton on the Hill. Both villages already have traffic calming measures imposed. I don't believe the new plan is consistent with national policy as it increases the village size of Hampton magna by one third - far too great a number of homes and families to be catered for within an existing village WITH LIMITED RESOURCES. Furthermore to be consistent with national policy the proposal for Hampton Magna should enable the delivery of sustainable development in accordance with the policies in the NPPF. This has not been achieved and more detailed reasons are listed below.

Transport

By the NPPF paragraph 32, plans and decisions should take account of whether safe and suitable access to the site can be achieved for all people.

There is already traffic congestion to and from Budbrooke village at peak times.
This is due to the fact that access in and out of Budbrooke village is by way of a single road. At one end, Old Budbrooke Road becomes a single lane under the railway bridge approaching Warwick Parkway Railway Station and this is controlled by alternating traffic lights system which allows only a few vehicles at a time in and out of the village. When traffic enters the village or Warwick Parkway Station it prevents access out of the village.

The overall affect is that traffic congestion and delays are experienced at peak times. If there is a traffic incident on the nearby M40 motorway or the A46, this causes huge traffic build up in areas surrounding Budbrooke Village which further exacerbates the situation. Traffic flows and congestion will increase very significantly for both peak morning and evening if there are additional housing allocations.

An alternative access route to Warwick is through Hampton on the Hill and on to the Hampton Road but this is subject to two narrow access points in Hampton on the Hill which are subject to priority give way lane control arrow signals resulting in potential choke points in and out of Hampton on the Hill. In addition Hampton Road is subject to busy traffic travelling down the hill into Warwick thus forming an impediment to exit. Traffic (particularly at peak times) also uses this route for access into the village down the Old Budbrooke Road and under the railway bridge for journeys to the Birmingham Road and to Stanks Island. All of this will create additional congestion and pollution for local residents and the risk of accidents.

There is a Strategic Transport Assessment which proposes changes to Stanks Island to alleviate traffic congestion due to increased traffic flow to and from destinations served by Stanks Island. This assessment fails to address and demonstrate how the scheme will enable safe and suitable access to and from Hampton Magna at peak times.

There is a separate technical study (Old Budbrooke Road/Warwick Parkway Station Access Junction - LinSig Assessment) which considers the potential impact of the railway bridge on traffic in and out of Hampton Magna. This shows that the peak morning assessment is near to or exceeding The Degree of Saturation shown and states it is likely that congestion will develop. We contend that the cumulative impacts of traffic from the proposed 245 extra homes at Hampton Magna, the additional proposed housing at Opus 40 and Hatton Park, which feed Budbrooke School, the growing commuter capacity and increasing vehicle use at Warwick Parkway station and the increasing use of Hampton Magna as a cut through route from the Hampton Road are likely to be severe.

Also, the peak morning period is taken as 8am to 9am. It does not show the effects on traffic flows if the peak times are increased, as is the case for many motorists needing to reach their destination on time given increasingly lengthy journey times which result from increased traffic flows in the Birmingham Road/Stanks Island vicinity.

The theoretical modelling study has failed to properly consider the above problems adequately. The additional traffic will also adversely impact on public transport at peak times and could result in emergency services vehicle access being delayed or prevented. So the proposal does not enable the delivery of sustainable development or show with certainty that suitable transport access can be achieved for all people. Therefore it is not consistent with NPPF transport policy.

Infrastructure

The NPPF (paragraph 162) states that local planning authorities should work with other providers to assess the quality and capacity of water supply, waste-water and its treatment, energy, health and education, and its ability to meet forecast demands. It covers other matters not listed here. I feel the plan must clearly show how they providers have been work with to properly assess how they are able to meet forecast demands at Hampton Magna. General and superficial assurances given in the Infrastructure Delivery plan for water supply, waste-water and its treatment, energy are not adequate. No assessment appears to have been made in respect of health, re GP surgery. More details are given in the "Not Effective" section. Therefore it has failed to meet the requirements in respect of the infrastructure policy.


NOT POSITIVELY PREPARED

To be Positively Prepared the plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements.
One of the key requirements is promoting sustainable transport (NPPF paragraphs 29 - 41). In particular, the plan should:

* encourage solutions which support reductions in greenhouse gas emissions and reduce congestion (NPPF policy 29 and 30).

* ensure that developments which generate significant movement are located where the need to travel will be minimized and the use of sustainable transport modes can be maximized (NPPF 34).

For the reasons detailed elsewhere in this response, the additional proposed housing allocation at the sites in Hampton Magna with restricted access to and from Hampton Magna will result in significant increased traffic flow and congestion and conflict with these policies.


NOT JUSTIFIED

To be justified the Local Plan "needs to be founded on a robust and credible evidence base involving research/fact finding demonstrating how the choices made in the plan are backed up by facts."

The new Local Plan in respect of Hampton Magna fails to do this because the proposed figure of 245 additional houses has not been robustly demonstrated as justified even as measured against the Indicative Village Capacity proposed in the Plan.

The Village Profile and Housing Allocations February 2016 document includes the profile for Hampton Magna and contains The Indicative Village Capacity section. This gives a total figure of 180 additional houses for Hampton Magna. It concludes that 180 is indicative and it is reasonable to exceed this "to a degree". However, an increase from 180 to 245 is not "a degree". The proposed 245 is not backed up by facts in the assessment and not justified.

To justify the increase from 180 to 245 houses it uses "the range of services within the village, its sustainable location close to urban area and good quality transport links." However no account has been taken of the negative sustainability impact on certain amenities which will result from the significant proposed number of additional houses, e.g. doctors surgery, primary school and local public and private transport access delays out of the village at peak times.

The plan is also defective in assessing sustainability. The plan says a Sustainability Assessment (SA) for the H51 site for Hampton Magna (land south of Lloyd Close) is not needed because the site has not been subject to change since 2015 when it was originally appraised but not allocated. However this H51 site has clearly changed since 2015 from 0 houses allocation to 145 houses allocation! So there is a huge fundamental change and hence a new Sustainability Assessment (SA) is essential to revisit this. The fact it has not been performed shows no attempt has been made to satisfy the sustainability criteria of justification.

The Local Plan may need to find additional houses in total but it is not justified to allocate another 145 (an increase of 145% to the original 100 houses) simply because Hampton Magna is a village with some amenities. The plan needs to demonstrate precisely how the total figure will be accommodated based on a revised Sustainability Assessment which fully addresses the real problems such an increase will entail.

It does not do this and for these reasons 245 houses in total is Not Justified.

NOT EFFECTIVE

To be effective the Local Plan needs to demonstrate sound infrastructure delivery planning by showing:
* clearly identified policies and proposed solutions
* a schedule setting out who will delivery and when and how it will be funded.
* support for the above by the providers and how it will be achieved.

The Infrastructure Delivery Plan does not do this. The Table in the Infrastructure Delivery Plan shows responses from physical Utility providers in very general terms:

U3 - Water and Sewerage assessment says Severn Trent Water's investment plans for drainage, sewerage and sewerage treatment mean that the development proposals can be accommodated.

U1 High Voltage Electricity Transmission System Electricity assessment says the transmission system will have the capacity to accommodate the additional demand.

However, the poor state of existing water drainage and sewerage systems in Hampton Magna is well known and is acknowledged by Severn Trent Water. There is no current detailed assessment of what work will be required and how and when it will performed to enable the existing systems to adequately cope if additional housing is built.

The existing electricity distribution system in respect of Hampton Magna has also been subject to problems for many years and there no assessment even in general terms as to how the existing system might be affected by the additional housing and how and when any problems arising will be resolved.

Social Infrastructure

- Health GP Services, there is no assessment or proposal in respect of how GP practice at Hampton Magna will cope with the additional patient numbers, whether expansion will be necessary and if so how it will be funded.

- Education.
The January 2016 census recorded 266 pupils against a capacity of 315.

WDC estimate that the total additional proposed homes for Hampton Magna and Hatton Park will generate in the region of 110 primary age pupils. When added to the 266 pupils it would create a total of 376 pupils which is 61 pupils over the 315 capacity. This would entail an expansion of the school from the time the extra housing is built. It does not take account of a future growth in numbers of pupils. However, in respect of such expansion, there is no current detailed assessment of what work will be required, how and when it will performed and how it will be funded with certainty.

Therefore I believe the plan for Hampton Magna fails to satisfy the key requirement to show it is the proposal is Effective


8. Modifications necessary to make the Local Plan legally compliant or sound.

LEGALLY COMPLIANT AND SOUND
As the Plan has failed to satisfy Legal Compliance and Soundness then the allocation of 245 houses should be denied on the basis that such allocation has failed a proven sustainability assessment and the other failures in the Plan as stated in this response.

If the Inspector concludes that the Local Plan is Legally Compliant and Sound in some respects then at the very least it is proposed that there should be a significant reduction in the number of houses allocated for Hampton Magna. How this is achieved is a matter for the Inspector. For instance, he could deny the proposal for the additional 145 houses, or reduce the total 245 number in some other way.

There is potentially a more suitable site nearer to Coventry which should be considered as an alternative, e.g. Bubbenhall, given that meeting Coventry's housing is the focus of the Plan. This would also better meet the Positively Prepared key requirement in respect promoting sustainable transport in accordance with NPPF.

My views is that the Local Plan and Sustainability Appraisal (SA) are not safe. I believe the technical references are Mod Number: H27 and H51;
Paragraph Number; Mod Policies Map -H27 and H51 & Table of Proposed Modifications January 2016, Appendix C Changes, Policy Map 20.

I don't believe the Local Plan is Legally Compliant or sound. I feel it has not been positively prepared (by identifying a previously discarded site) or is justified in terms of services such as school, GP surgery and other services could not cope with the additional families needed to be catered for with an additional 145 homes. And it is certainly not effective in terms of transportation. Budbrooke is a rural village surrounded by narrow lanes and accessible via Hampton on the Hill and off the main A4177 both of which allow only single track carriageway reducing to traffic light controlled single carriageway under the bridge at the entrance to Parkway station. There is no prospect of improving the roadways width or capacity to cope with significantly increased traffic flow. There are some developments to be made to Stanks Island towards the end of the year but this will not impact on the heavy flow of traffic using country lanes skirting Hampton Magna and cutting through the village of Hampton on the Hill which also has traffic calming measures imposed. I don't believe the new plan is consistent with national policy as it increased the village size of Hampton magna by one third - far too great a number of homes and families to be catered for within an existing village WITH LIMITED RESOURCES. Furthermore to be consistent with national policy the proposal for Hampton Magna should enable the delivery of sustainable development in accordance with the policies in the NPPF. This has not been achieved and more detailed reasons are listed below.

Transport

By the NPPF paragraph 32, plans and decisions should take account of whether safe and suitable access to the site can be achieved for all people.

There is already traffic congestion to and from Budbrooke village at peak times.
This is due to the fact that access in and out of Budbrooke village is by way of a single road. At one end, Old Budbrooke Road becomes a single lane under the railway bridge approaching Warwick Parkway Railway Station and this is controlled by alternating traffic lights system which allows only a few vehicles at a time in and out of the village. When traffic enters the village or Warwick Parkway Station it prevents access out of the village.

The overall affect is that traffic congestion and delays are experienced at peak times. If there is a traffic incident in a nearby motorway this causes huge traffic build up in areas surrounding Budbrooke Village which further exacerbates the situation. Traffic flows and congestion will increase very significantly for both peak morning and evening if there are additional housing allocations.

An alternative access route to Warwick is through Hampton on the Hill and on to the Hampton Road but this is subject to two narrow access points in Hampton on the Hill which are subject to priority give way lane control arrow signals resulting in potential choke points in and out of Hampton on the Hill. In addition Hampton Road is subject to busy traffic travelling down the hill into Warwick thus forming an impediment to exit. Traffic (particularly at peak times) also uses this route for access into the village down the Old Budbrooke Road and under the railway bridge for journeys to the Birmingham Road and to Stanks Island. All of this will create additional congestion and pollution for local residents and the risk of accidents.

There is a Strategic Transport Assessment which proposes changes to Stanks Island to alleviate traffic congestion due to increased traffic flow to and from destinations served by Stanks Island. This assessment fails to address and demonstrate how the scheme will enable safe and suitable access to and from Hampton Magna at peak times.

There is a separate technical study (Old Budbrooke Road/Warwick Parkway Station Access Junction - LinSig Assessment) which considers the potential impact of the railway bridge on traffic in and out of Hampton Magna. This shows that the peak morning assessment is near to or exceeding The Degree of Saturation shown and states it is likely that congestion will develop. We contend that the cumulative impacts of traffic from the proposed 245 extra homes at Hampton Magna, the additional proposed housing at Opus 40 and Hatton Park, the growing commuter capacity and increasing vehicle use at Warwick Parkway station and the increasing use of Hampton Magna as a cut through route from the Hampton Road are likely to be severe.

Also, the peak morning period is taken as 8am to 9am. It does not show the affects on traffic flows if the peak times are increased, as is the case for many motorists needing to reach their destination on time given increasingly lengthy journey times which result from increased traffic flows in the Birmingham Road/Stanks Island vicinity.

The theoretical modelling study has failed to properly consider the above problems adequately. The additional traffic will also adversely impact on public transport at peak times and could result in emergency services vehicle access being delayed or prevented. So the proposal does not enable the delivery of sustainable development or show with certainty that suitable transport access can be achieved for all people. Therefore it is not consistent with NPPF transport policy.

Infrastructure

The NPPF (paragraph 162) states that local planning authorities should work with other providers to assess the quality and capacity of water supply, waste-water and its treatment, energy, health and education, and its ability to meet forecast demands. It covers other matters not listed here. I feel the plan must clearly show how they providers have been work with to properly assess how they are able to meet forecast demands at Hampton Magna. General and superficial assurances given in the Infrastructure Delivery plan for water supply, waste-water and its treatment, energy are not adequate. No assessment appears to have been made in respect of health, re GP surgery. More details are given in the "Not Effective" section. Therefore it has failed to meet the requirements in respect of the infrastructure policy.


NOT POSITIVELY PREPARED

To be Positively Prepared the plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements.
One of the key requirements is promoting sustainable transport (NPPF paragraphs 29 - 41). In particular, the plan should:

* encourage solutions which support reductions in greenhouse gas emissions and reduce congestion (NPPF policy 29 and 30).

* ensure that developments which generate significant movement are located where the need to travel will be minimized and the use of sustainable transport modes can be maximized (NPPF 34).

For the reasons detailed elsewhere in this response, the additional proposed housing allocation at the sites in Hampton Magna with restricted access to and from Hampton Magna will result in significant increased traffic flow and congestion and conflict with these policies.


NOT JUSTIFIED

To be justified the Local Plan "needs to be founded on a robust and credible evidence base involving research/fact finding demonstrating how the choices made in the plan are backed up by facts."

The new Local Plan in respect of Hampton Magna fails to do this because the proposed figure of 245 additional houses has not been robustly demonstrated as justified even as measured against the Indicative Village Capacity proposed in the Plan.

The Village Profile and Housing Allocations February 2016 document includes the profile for Hampton Magna and contains The Indicative Village Capacity section. This gives a total figure of 180 additional houses for Hampton Magna. It concludes that 180 is indicative and it is reasonable to exceed this "to a degree". However, an increase from 180 to 245 is not "a degree". The proposed 245 is not backed up by facts in the assessment and not justified.

To justify the increase from 180 to 245 houses it uses "the range of services within the village, its sustainable location close to urban area and good quality transport links." However no account has been taken of the negative sustainability impact on certain amenities which will result from the significant proposed number of additional houses, e.g. doctors surgery, primary school and local public and private transport access delays out of the village at peak times.

The plan is also defective in assessing sustainability. The plan says a Sustainability Assessment (SA) for the H51 site for Hampton Magna (land south of Lloyd Close) is not needed because the site has not been subject to change since 2015 when it was originally appraised but not allocated. However this H51 site has clearly changed since 2015 from 0 houses allocation to 145 houses allocation! So there is a huge fundamental change and hence a new Sustainability Assessment (SA) is essential to revisit this. The fact it has not been performed shows no attempt has been made to satisfy the sustainability criteria of justification.

The Local Plan may need to find additional houses in total but it is not justified to allocate another 145 (an increase of 145% to the original 100 houses) simply because Hampton Magna is a village with some amenities. The plan needs to demonstrate precisely how the total figure will be accommodated based on a revised Sustainability Assessment which fully addresses the real problems such an increase will entail.

It does not do this and for these reasons 245 houses in total is Not Justified.

NOT EFFECTIVE

To be effective the Local Plan needs to demonstrate sound infrastructure delivery planning by showing:
* clearly identified policies and proposed solutions
* a schedule setting out who will delivery and when and how it will be funded.
* support for the above by the providers and how it will be achieved.

The Infrastructure Delivery Plan does not do this. The Table in the Infrastructure Delivery Plan shows responses from physical Utility providers in very general terms:

U3 - Water and Sewerage assessment says Severn Trent Water's investment plans for drainage, sewerage and sewerage treatment mean that the development proposals can be accommodated.

U1 High Voltage Electricity Transmission System Electricity assessment says the transmission system will have the capacity to accommodate the additional demand.

However, the poor state of existing water drainage and sewerage systems in Hampton Magna is well known and is acknowledged by Severn Trent Water. There is no current detailed assessment of what work will be required and how and when it will performed to enable the existing systems to adequately cope if additional housing is built.

The existing electricity distribution system in respect of Hampton Magna has also been subject to problems for many years and there no assessment even in general terms as to how the existing system might be affected by the additional housing and how and when any problems arising will be resolved.

Social Infrastructure

- Health GP Services, there is no assessment or proposal in respect of how GP practice at Hampton Magna will cope with the additional patient numbers, whether expansion will be necessary and if so how it will be funded.

- Education.
The January 2016 census recorded 266 pupils against a capacity of 315.

WDC estimate that the total additional proposed homes for Hampton Magna and Hatton Park will generate in the region of 110 primary age pupils. When added to the 266 pupils it would create a total of 376 pupils which is 61 pupils over the 315 capacity. This would entail an expansion of the school from the time the extra housing is built. It does not take account of a future growth in numbers of pupils. However, in respect of such expansion, there is no current detailed assessment of what work will be required, how and when it will performed and how it will be funded with certainty.

Therefore I believe the plan for Hampton Magna fails to satisfy the key requirement to show it is the proposal is Effective


8. Modifications necessary to make the Local Plan legally compliant or sound.

LEGALLY COMPLIANT AND SOUND
As the Plan has failed to satisfy Legal Compliance and Soundness then the allocation of 245 houses should be denied on the basis that such allocation has failed a proven sustainability assessment and the other failures in the Plan as stated in this response.

If the Inspector concludes that the Local Plan is Legally Compliant and Sound in some respects then at the very least it is proposed that there should be a significant reduction in the number of houses allocated for Hampton Magna. How this is achieved is a matter for the Inspector. For instance, he could deny the proposal for the additional 145 houses, or reduce the total 245 number in some other way.

There is potentially a more suitable site nearer to Coventry which should be considered as an alternative, e.g. Bubbenhall, given that meeting Coventry's housing is the focus of the Plan. This would also better meet the Positively Prepared key requirement in respect promoting sustainable transport in accordance with NPPF.

as attached

I wish to tender my OBJECTION to the NEW LOCAL PLAN with especial reference to Hampton Magna, as being UNSOUND.

I consider the plan to be unsound due to the dangerous increase in residential traffic that would be caused by the extension to H27 and especially the newly proposed site H51.

H51 in particular, with possible access roads being from Daly Avenue would further exacerbate an existing danger spot when exiting Sumner Close. There has always been a problem due to blind bends to the left and right of Sumner Close, (opposite the proposed site H51), highlighted recently when a house on the junction of Daly Avenue/ Woodway Avenue/ Lloyd Close was being extended. Parked construction vehicles made the situation temporarily exceedingly hazardous, which can be expected to be a constant hazard if the proposals go ahead.

Budbrooke Medical Centre and School are already stretched and the proposed increase in residents would mean that these facilities would find it very difficult to cope leading to a huge reduction in service for existing residents.

There is already a problem with noise pollution from the nearby A46 and M40. Site H51 would be much nearer to these roads and the noise pollution would therefore be considerably higher for anyone living on that site.

LOCAL PLAN - PUBLICATION DRAFT REPRESENTATION FORM 2014


PART A. Personal details and whether you wish to be informed.

PART B - YOUR REPRESENTATIONS


4. To which part of the Local Plan or Sustainability Appraisal (SA) does this representation relate?


Modification or SA - Both

* The Modification and in respect of Hampton Magna

* The Sustainability Appraisal Report (SA) and SA Addendum in respect of Hampton Magna Site.


Mod Number: H27 and H51


Paragraph Number:


Mod Policies Map:

* H27 and H51

* Table of Proposed Modifications January 2016, Appendix C Changes, Policy Map 20.


5. Do you consider the Local Plan is:


5.1 Legally Compliant? NO


5.2 Sound? NO


6. If you answered no to question 5.2, do you consider the Local Plan and/or SA unsound because it is not (please tick that apply):


Positively Prepared: þ


Justified: þ


Effective: þ


Consistent with National Policy: þ


THIS RESPONSE IS CONFINED TO HAMPTON MAGNA ONLY. NO OBJECTIONS ARE MADE IN RESPECT OF ANY OTHER ASPECTS OF THE PLAN OUTSIDE HAMPTON MAGNA.


7. DETAILS OF WHY THE LOCAL PLAN IS CONSIDERED NOT TO BE LEGALLY COMPLIANT.


In preparing the plan the local planning authority must have regard to national policies and advice.

The Local Plan in respect of Hampton Magna should be consistent with the principles and policies set out in the NPPF and we contend that it is not.


Further details of this are given under the heading "Not Consistent with the NPPF".


Therefore, for this reason, the Local Plan in respect of Hampton Magna is not Legally Compliant.





DETAILS OF WHY THE LOCAL PLAN IS CONSIDERED NOT TO BE SOUND IN RESPECT OF

HAMPTON MAGNA:


NOT CONSISTENT WITH NATIONAL POLICY


Bold underlined highlights have been included within texts for emphasis.


To be consistent with national policy the proposal for Hampton Magna should enable the delivery of sustainable development in accordance with the policies in the NPPF.


This has not been achieved due to the reasons below.


Transport


By the NPPF paragraph 32, plans and decisions should take account of whether safe and suitable access to the site can be achieved for all people.


There is already traffic congestion to and from Budbrooke village at peak times.

This is due to the fact that access in and out of Budbrooke village is by way of a single road. At one end, Old Budbrooke Road becomes a single lane under the railway bridge approaching Warwick Parkway Railway Station and this is controlled by alternating traffic lights system which allows only a few vehicles at a time in and out of the village. When traffic enters the village or Warwick Parkway Station it prevents access out of the village.


The overall effect is that traffic congestion and delays are experienced at peak times. If there is a traffic incident in a nearby motorway this causes huge traffic build up in areas surrounding Budbrooke Village which further exacerbates the situation. Traffic flows and congestion will increase very significantly for both peak morning and evening if there are additional housing allocations.


An alternative access route to Warwick is through Hampton on the Hill and on to the Hampton Road but this is subject to two narrow access points in Hampton on the Hill which are subject to priority give way lane control arrow signals resulting in potential choke points in and out of Hampton on the Hill. In addition Hampton Road is subject to busy traffic travelling down the hill into Warwick thus forming an impediment to exit. Traffic (particularly at peak times) also uses this route for access into the village down the Old Budbrooke Road and under the railway bridge for journeys to the Birmingham Road and to Stanks Island. All of this will create additional congestion and pollution for local residents and the risk of accidents.


There is a Strategic Transport Assessment which proposes changes to Stanks Island to alleviate traffic congestion due to increased traffic flow to and from destinations served by Stanks Island. This assessment fails to address and demonstrate how the scheme will enable safe and suitable access to and from Hampton Magna at peak times.


There is a separate technical study (Old Budbrooke Road/Warwick Parkway Station Access Junction - LinSig Assessment) which considers the potential impact of the railway bridge on traffic in and out of Hampton Magna. This shows that the peak morning assessment is near to or exceeding The Degree of Saturation shown and states it is likely that congestion will develop. We contend that the cumulative impacts of traffic from the proposed 245 extra homes at Hampton Magna, the additional proposed housing at Opus 40 and Hatton Park, the growing commuter capacity and increasing vehicle use at Warwick Parkway station and the increasing use of Hampton Magna as a cut through route from the Hampton Road are likely to be severe.


Also, the peak morning period is taken as 8am to 9am. It does not show the affects on traffic flows if the peak times are increased, as is the case for many motorists needing to reach their destination on time given increasingly lengthy journey times which result from increased traffic flows in the Birmingham Road/Stanks Island vicinity.


The theoretical modelling study has failed to properly consider the above problems adequately.


The additional traffic will also adversely impact on public transport at peak times and could result in emergency services vehicle access being delayed or prevented.


So the proposal does not enable the delivery of sustainable development or show with certainty that suitable transport access can be achieved for all people.


Therefore it is not consistent with NPPF transport policy.


Infrastructure


The NPPF (paragraph 162) states that local planning authorities should work with other providers to assess the quality and capacity of water supply, waste-water and its treatment, energy, health and education, and its ability to meet forecast demands. It covers other matters not listed here.


We consider the plan must clearly show how they have worked with providers to properly assess how they are able to meet forecast demands at Hampton Magna.


General and superficial assurances given in the Infrastructure Delivery plan for water supply, waste-water and its treatment, energy are not adequate.


No assessment appears to have been made in respect of health, re GP surgery.


More details are given in the "Not Effective" section.


Therefore it has failed to meet the requirements in respect of the infrastructure policy.



NOT POSITIVELY PREPARED


To be Positively Prepared the plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements.


One of the key requirements is promoting sustainable transport (NPPF paragraphs 29 - 41).


In particular, the plan should:


* encourage solutions which support reductions in greenhouse gas emissions and reduce congestion (NPPF policy 29 and 30).


* ensure that developments which generate significant movement are located where the need to travel will be minimized and the use of sustainable transport modes can be maximized (NPPF 34).


For the reasons detailed elsewhere in this response, the additional proposed housing allocation at the sites in Hampton Magna with restricted access to and from Hampton Magna will result in significant increased traffic flow and congestion and conflict with these policies.



NOT JUSTIFIED


To be justified the Local Plan "needs to be founded on a robust and credible evidence base involving research/fact finding demonstrating how the choices made in the plan are backed up by facts."


In our submission the Local Plan in respect of Hampton Magna fails to do this because the proposed figure of 245 additional houses has not been robustly demonstrated as justified even as measured against the

Indicative Village Capacity proposed in the Plan.


The Village Profile and Housing Allocations February 2016 document includes the profile for Hampton Magna and contains The Indicative Village Capacity section. This gives a total figure of 180 additional houses for Hampton Magna. It concludes that 180 is indicative and it is reasonable to exceed this "to a degree". However, an increase from 180 to 245 is not "a degree". The proposed 245 is not backed up by facts in the assessment and not justified.


To justify the increase from 180 to 245 houses it uses "the range of services within the village, its sustainable location close to urban area and good quality transport links." However no account has been taken of the negative sustainability impact on certain amenities which will result from the significant proposed number of additional houses, e.g. doctors surgery, primary school and local public and private transport access delays out of the village at peak times.


The plan is also defective in assessing sustainability.


The plan says a Sustainability Assessment (SA) for the H51 site for Hampton Magna (land south of Lloyd Close) is not needed because the site has not been subject to change since 2015 when it was originally appraised but not allocated.


However this H51 site has clearly changed since 2015 from 0 houses allocation to 145 houses allocation! So there is a huge fundamental change and hence a new Sustainability Assessment (SA) is essential to revisit this.


The fact it has not been performed shows no attempt has been made to satisfy the sustainability criteria of justification.


We appreciate that the Local Plan needs to find additional houses in total but it is not justified to allocate another 145 (an increase of 145% to the original 100 houses) simply because Hampton Magna is a village with some amenities. The plan needs to demonstrate precisely how the total figure will be accommodated based on a revised Sustainability Assessment which fully addresses the real problems such an increase will entail.


It does not do this and for these reasons 245 houses in total is Not Justified.


NOT EFFECTIVE


To be effective the Local Plan needs to demonstrate sound infrastructure delivery planning by showing:

* clearly identified policies and proposed solutions

* a schedule setting out who will delivery and when and how it will be funded.

* support for the above by the providers and how it will be achieved.


The Infrastructure Delivery Plan does not do this. The Table in the Infrastructure Delivery Plan shows responses from physical Utility providers in very general terms:


U3 - Water and Sewerage assessment says Severn Trent Water's investment plans for drainage, sewerage and sewerage treatment mean that the development proposals can be accommodated.


U1 High Voltage Electricity Transmission System Electricity assessment says the transmission system will have the capacity to accommodate the additional demand.


However, the poor state of existing water drainage and sewerage systems in Hampton Magna is well known and is acknowledged by Severn Trent Water. There is no current detailed assessment of what work will be required and how and when it will performed to enable the existing systems to adequately cope if additional housing is built.


The existing electricity distribution system in respect of Hampton Magna has also been subject to problems for many years and there no assessment even in general terms as to how the existing system might be affected by the additional housing and how and when any problems arising will be resolved.


Social Infrastructure


- Health GP Services, there is no assessment or proposal in respect of how GP practice at Hampton Magna will cope with the additional patient numbers, whether expansion will be necessary and if so how it will be funded.


- Education.

The January 2016 census recorded 266 pupils against a capacity of 315.


WDC estimate that the total additional proposed homes for Hampton Magna and Hatton Park will generate in the region of 110 primary age pupils.


When added to the 266 pupils it would create a total of 376 pupils which is 61 pupils over the 315 capacity.


This would entail an expansion of the school from the time the extra housing is built. It does not take account of a future growth in numbers of pupils.


However, in respect of such expansion, there is no current detailed assessment of what work will be required, how and when it will performed and how it will be funded with certainty.


Therefore we believe the plan for Hampton Magna fails to satisfy the key requirement to show it is the proposal is Effective


This "it will be alright on the night" approach is inadequate.


8. Modifications necessary to make the Local Plan legally compliant or sound.


LEGALLY COMPLIANT AND SOUND

As the Plan has failed to satisfy Legal Compliance and Soundness then the allocation of 245 houses should be denied on the basis that such allocation has failed a proven sustainability assessment and the other failures in the Plan as stated in this response.


If the Inspector concludes that the Local Plan is Legally Compliant and Sound in some respects then at the very least it is proposed that there should be a significant reduction in the number of houses allocated for Hampton Magna. How this is achieved is a matter for the Inspector. For instance, he could deny the proposal for the additional 145 houses, or reduce the total 245 number in some other way.


There is potentially a more suitable site nearer to Coventry which should be considered as an alternative, e.g. Bubbenhall, given that meeting Coventry's housing is the focus of the Plan. This would also better meet the Positively Prepared key requirement in respect promoting sustainable transport in accordance with NPPF.

See attached

As a resident of Hampton-on-the-Hill I am writing to OBJECT to the proposed modifications to the Local Plan regarding the increase in housing in Hampton Magna - references H51 and H20. The Draft Local Plan had proposed 100 additional dwellings in Hampton Magna and the 'Proposed Modification' has increased this number to 245.

Hampton Magna currently has 632 dwellings and the proposed increase will take this to 877, an increase of nearly 40%. Existing amenities are struggling to cope and will be unable to sustain such an increase. Schools and services are already overloaded and will be unable to function with the additional housing. To accommodate the additional housing will require a substantial investment in extending all amenities.

Access to Hampton Magna is by two principal roads (there is a third road which is a country lane - Ugly Bridge Road linking to Woodway and Church Lane); one is Hampton Road through Hampton-on-the-Hill and the other Old Budbrooke Road via a low headroom bridge (12 ft 6 inches) at Warwick Parkway Station. As a result heavy traffic enters along the Hampton Road through Hampton-on-the-Hill.

This situation is exacerbated by the recently extended development at Chase Meadow to1000 dwellings, many of whom use Hampton-on-the-Hill as a means of access to Warwick Parkway station and as a 'short cut' to the A46 and A4177. A traffic survey carried out in September 2015 showed over 18,000 vehicles a week come through Hampton-on-the-Hill. Roads in the Village already show substantial degradation with the current loading and will require much investment just to cope without the burden of the additional traffic. The quality of life in our village is already being fragmented and the additional traffic will destroy it altogether.

If additional dwellings were to be built in Hampton Magna, it would be essential to build a separate road into them from the A4189, Henley Road and factor in the costs of so doing. Such a road would not only improve the environment and traffic flow for Hampton Magna and Hampton-on-the-Hill, but could also be used by Chase Meadow residents to access the Warwick Parkway station, the A46 and A4177. Furthermore, the route of the road could be used to accommodate the additional services (drainage, water, electricity, telecommunications) which will be required for the new dwellings.
As a resident of Hampton-on-the-Hill I am writing to OBJECT to the proposed modifications to the Local Plan regarding the increase in housing in Hampton Magna - references H51 and H20. The Draft Local Plan had proposed 100 additional dwellings in Hampton Magna and the 'Proposed Modification' has increased this number to 245.

Hampton Magna currently has 632 dwellings and the proposed increase will take this to 877, an increase of nearly 40%. Existing amenities are struggling to cope and will be unable to sustain such an increase. Schools and services are already overloaded and will be unable to function with the additional housing. To accommodate the additional housing will require a substantial investment in extending all amenities.

Access to Hampton Magna is by two principal roads (there is a third road which is a country lane - Ugly Bridge Road linking to Woodway and Church Lane); one is Hampton Road through Hampton-on-the-Hill and the other Old Budbrooke Road via a low headroom bridge (12 ft 6 inches) at Warwick Parkway Station. As a result heavy traffic enters along the Hampton Road through Hampton-on-the-Hill.

This situation is exacerbated by the recently extended development at Chase Meadow to1000 dwellings, many of whom use Hampton-on-the-Hill as a means of access to Warwick Parkway station and as a 'short cut' to the A46 and A4177. A traffic survey carried out in September 2015 showed over 18,000 vehicles a week come through Hampton-on-the-Hill. Roads in the Village already show substantial degradation with the current loading and will require much investment just to cope without the burden of the additional traffic. The quality of life in our village is already being fragmented and the additional traffic will destroy it altogether.

If additional dwellings were to be built in Hampton Magna, it would be essential to build a separate road into them from the A4189, Henley Road and factor in the costs of so doing. Such a road would not only improve the environment and traffic flow for Hampton Magna and Hampton-on-the-Hill, but could also be used by Chase Meadow residents to access the Warwick Parkway station, the A46 and A4177. Furthermore, the route of the road could be used to accommodate the additional services (drainage, water, electricity, telecommunications) which will be required for the new dwellings.
As a resident of Hampton-on-the-Hill I am writing to OBJECT to the proposed modifications to the Local Plan regarding the increase in housing in Hampton Magna - references H51 and H20. The Draft Local Plan had proposed 100 additional dwellings in Hampton Magna and the 'Proposed Modification' has increased this number to 245.

Hampton Magna currently has 632 dwellings and the proposed increase will take this to 877, an increase of nearly 40%. Existing amenities are struggling to cope and will be unable to sustain such an increase. Schools and services are already overloaded and will be unable to function with the additional housing. To accommodate the additional housing will require a substantial investment in extending all amenities.

Access to Hampton Magna is by two principal roads (there is a third road which is a country lane - Ugly Bridge Road linking to Woodway and Church Lane); one is Hampton Road through Hampton-on-the-Hill and the other Old Budbrooke Road via a low headroom bridge (12 ft 6 inches) at Warwick Parkway Station. As a result heavy traffic enters along the Hampton Road through Hampton-on-the-Hill.

This situation is exacerbated by the recently extended development at Chase Meadow to1000 dwellings, many of whom use Hampton-on-the-Hill as a means of access to Warwick Parkway station and as a 'short cut' to the A46 and A4177. A traffic survey carried out in September 2015 showed over 18,000 vehicles a week come through Hampton-on-the-Hill. Roads in the Village already show substantial degradation with the current loading and will require much investment just to cope without the burden of the additional traffic. The quality of life in our village is already being fragmented and the additional traffic will destroy it altogether.

If additional dwellings were to be built in Hampton Magna, it would be essential to build a separate road into them from the A4189, Henley Road and factor in the costs of so doing. Such a road would not only improve the environment and traffic flow for Hampton Magna and Hampton-on-the-Hill, but could also be used by Chase Meadow residents to access the Warwick Parkway station, the A46 and A4177. Furthermore, the route of the road could be used to accommodate the additional services (drainage, water, electricity, telecommunications) which will be required for the new dwellings.
As a resident of Hampton-on-the-Hill I am writing to OBJECT to the proposed modifications to the Local Plan regarding the increase in housing in Hampton Magna - references H51 and H20. The Draft Local Plan had proposed 100 additional dwellings in Hampton Magna and the 'Proposed Modification' has increased this number to 245.

Hampton Magna currently has 632 dwellings and the proposed increase will take this to 877, an increase of nearly 40%. Existing amenities are struggling to cope and will be unable to sustain such an increase. Schools and services are already overloaded and will be unable to function with the additional housing. To accommodate the additional housing will require a substantial investment in extending all amenities.

Access to Hampton Magna is by two principal roads (there is a third road which is a country lane - Ugly Bridge Road linking to Woodway and Church Lane); one is Hampton Road through Hampton-on-the-Hill and the other Old Budbrooke Road via a low headroom bridge (12 ft 6 inches) at Warwick Parkway Station. As a result heavy traffic enters along the Hampton Road through Hampton-on-the-Hill.

This situation is exacerbated by the recently extended development at Chase Meadow to1000 dwellings, many of whom use Hampton-on-the-Hill as a means of access to Warwick Parkway station and as a 'short cut' to the A46 and A4177. A traffic survey carried out in September 2015 showed over 18,000 vehicles a week come through Hampton-on-the-Hill. Roads in the Village already show substantial degradation with the current loading and will require much investment just to cope without the burden of the additional traffic. The quality of life in our village is already being fragmented and the additional traffic will destroy it altogether.

If additional dwellings were to be built in Hampton Magna, it would be essential to build a separate road into them from the A4189, Henley Road and factor in the costs of so doing. Such a road would not only improve the environment and traffic flow for Hampton Magna and Hampton-on-the-Hill, but could also be used by Chase Meadow residents to access the Warwick Parkway station, the A46 and A4177. Furthermore, the route of the road could be used to accommodate the additional services (drainage, water, electricity, telecommunications) which will be required for the new dwellings.
I believe the proposed changes are unsound and should be rejected.

My objections to The Local Plan are additional to those I submitted earlier which you acknowledged receipt and the factors below apply to both designated areas H27 and H51

THIS RESPONSE IS CONFINED TO HAMPTON MAGNA ONLY. NO OBJECTIONS ARE MADE IN RESPECT OF ANY OTHER ASPECTS OF THE PLAN OUTSIDE HAMPTON MAGNA.

DETAILS OF WHY THE LOCAL PLAN IS CONSIDERED NOT TO BE LEGALLY COMPLIANT.

In preparing the plan the local planning authority must have regard to national policies and advice.
The Local Plan in respect of Hampton Magna should be consistent with the principles and policies set out in the NPPF and we contend that it is not.

Further details of this are given under the heading "Not Consistent with the NPPF".

Therefore, for this reason, the Local Plan in respect of Hampton Magna is not Legally Compliant.




DETAILS OF WHY THE LOCAL PLAN IS CONSIDERED NOT TO BE SOUND IN RESPECT OF HAMPTON MAGNA:

NOT CONSISTENT WITH NATIONAL POLICY

Bold underlined highlights have been included within texts for emphasis.

To be consistent with national policy the proposal for Hampton Magna should enable the delivery of sustainable development in accordance with the policies in the NPPF.

This has not been achieved due to the reasons below.

Transport

By the NPPF paragraph 32, plans and decisions should take account of whether safe and suitable access to the site can be achieved for all people.

There is already traffic congestion to and from Budbrooke village at peak times.
This is due to the fact that access in and out of Budbrooke village is by way of a single road. At one end, Old Budbrooke Road becomes a single lane under the railway bridge approaching Warwick Parkway Railway Station and this is controlled by alternating traffic lights system which allows only a few vehicles at a time in and out of the village. When traffic enters the village or Warwick Parkway Station it prevents access out of the village.

The overall affect is that traffic congestion and delays are experienced at peak times. If there is a traffic incident in a nearby motorway this causes huge traffic build up in areas surrounding Budbrooke Village which further exacerbates the situation. Traffic flows and congestion will increase very significantly for both peak morning and evening if there are additional housing allocations.

An alternative access route to Warwick is through Hampton on the Hill and on to the Hampton Road but this is subject to two narrow access points in Hampton on the Hill which are subject to priority give way lane control arrow signals resulting in potential choke points in and out of Hampton on the Hill. In addition Hampton Road is subject to busy traffic travelling down the hill into Warwick thus forming an impediment to exit. Traffic (particularly at peak times) also uses this route for access into the village down the Old Budbrooke Road and under the railway bridge for journeys to the Birmingham Road and to Stanks Island. All of this will create additional congestion and pollution for local residents and the risk of accidents.

There is a Strategic Transport Assessment which proposes changes to Stanks Island to alleviate traffic congestion due to increased traffic flow to and from destinations served by Stanks Island. This assessment fails to address and demonstrate how the scheme will enable safe and suitable access to and from Hampton Magna at peak times.

There is a separate technical study (Old Budbrooke Road/Warwick Parkway Station Access Junction - LinSig Assessment) which considers the potential impact of the railway bridge on traffic in and out of Hampton Magna. This shows that the peak morning assessment is near to or exceeding The Degree of Saturation shown and states it is likely that congestion will develop. We contend that the cumulative impacts of traffic from the proposed 245 extra homes at Hampton Magna, the additional proposed housing at Opus 40 and Hatton Park, the growing commuter capacity and increasing vehicle use at Warwick Parkway station and the increasing use of Hampton Magna as a cut through route from the Hampton Road are likely to be severe.

Also, the peak morning period is taken as 8am to 9am. It does not show the affects on traffic flows if the peak times are increased, as is the case for many motorists needing to reach their destination on time given increasingly lengthy journey times which result from increased traffic flows in the Birmingham Road/Stanks Island vicinity.

The theoretical modelling study has failed to properly consider the above problems adequately.

The additional traffic will also adversely impact on public transport at peak times and could result in emergency services vehicle access being delayed or prevented.

So the proposal does not enable the delivery of sustainable development or show with certainty that suitable transport access can be achieved for all people.

Therefore it is not consistent with NPPF transport policy.

Infrastructure

The NPPF (paragraph 162) states that local planning authorities should work with other providers to assess the quality and capacity of water supply, waste-water and its treatment, energy, health and education, and its ability to meet forecast demands. It covers other matters not listed here.

We consider the plan must clearly show how they have worked with providers to properly assess how they are able to meet forecast demands at Hampton Magna.

General and superficial assurances given in the Infrastructure Delivery plan for water supply, waste-water and its treatment, energy are not adequate.

No assessment appears to have been made in respect of health, re GP surgery.

More details are given in the "Not Effective" section.

Therefore it has failed to meet the requirements in respect of the infrastructure policy.


NOT POSITIVELY PREPARED

To be Positively Prepared the plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements.

One of the key requirements is promoting sustainable transport (NPPF paragraphs 29 - 41).

In particular, the plan should:

* encourage solutions which support reductions in greenhouse gas emissions and reduce congestion (NPPF policy 29 and 30).

* ensure that developments which generate significant movement are located where the need to travel will be minimized and the use of sustainable transport modes can be maximized (NPPF 34).

For the reasons detailed elsewhere in this response, the additional proposed housing allocation at the sites in Hampton Magna with restricted access to and from Hampton Magna will result in significant increased traffic flow and congestion and conflict with these policies.


NOT JUSTIFIED

To be justified the Local Plan "needs to be founded on a robust and credible evidence base involving research/fact finding demonstrating how the choices made in the plan are backed up by facts."

In our submission the Local Plan in respect of Hampton Magna fails to do this because the proposed figure of 245 additional houses has not been robustly demonstrated as justified even as measured against the Indicative Village Capacity proposed in the Plan.

The Village Profile and Housing Allocations February 2016 document includes the profile for Hampton Magna and contains The Indicative Village Capacity section. This gives a total figure of 180 additional houses for Hampton Magna. It concludes that 180 is indicative and it is reasonable to exceed this "to a degree". However, an increase from 180 to 245 is not "a degree". The proposed 245 is not backed up by facts in the assessment and not justified.

To justify the increase from 180 to 245 houses it uses "the range of services within the village, its sustainable location close to urban area and good quality transport links." However no account has been taken of the negative sustainability impact on certain amenities which will result from the significant proposed number of additional houses, e.g. doctors surgery, primary school and local public and private transport access delays out of the village at peak times.

The plan is also defective in assessing sustainability.

The plan says a Sustainability Assessment (SA) for the H51 site for Hampton Magna (land south of Lloyd Close) is not needed because the site has not been subject to change since 2015 when it was originally appraised but not allocated.

However this H51 site has clearly changed since 2015 from 0 houses allocation to 145 houses allocation! So there is a huge fundamental change and hence a new Sustainability Assessment (SA) is essential to revisit this.

The fact it has not been performed shows no attempt has been made to satisfy the sustainability criteria of justification.

We appreciate that the Local Plan needs to find additional houses in total but it is not justified to allocate another 145 (an increase of 145% to the original 100 houses) simply because Hampton Magna is a village with some amenities. The plan needs to demonstrate precisely how the total figure will be accommodated based on a revised Sustainability Assessment which fully addresses the real problems such an increase will entail.

It does not do this and for these reasons 245 houses in total is Not Justified.

NOT EFFECTIVE

To be effective the Local Plan needs to demonstrate sound infrastructure delivery planning by showing:
* clearly identified policies and proposed solutions
* a schedule setting out who will delivery and when and how it will be funded.
* support for the above by the providers and how it will be achieved.

The Infrastructure Delivery Plan does not do this. The Table in the Infrastructure Delivery Plan shows responses from physical Utility providers in very general terms:

U3 - Water and Sewerage assessment says Severn Trent Water's investment plans for drainage, sewerage and sewerage treatment mean that the development proposals can be accommodated.

U1 High Voltage Electricity Transmission System Electricity assessment says the transmission system will have the capacity to accommodate the additional demand.

However, the poor state of existing water drainage and sewerage systems in Hampton Magna is well known and is acknowledged by Severn Trent Water. There is no current detailed assessment of what work will be required and how and when it will performed to enable the existing systems to adequately cope if additional housing is built.

The existing electricity distribution system in respect of Hampton Magna has also been subject to problems for many years and there no assessment even in general terms as to how the existing system might be affected by the additional housing and how and when any problems arising will be resolved.

Social Infrastructure

- Health GP Services, there is no assessment or proposal in respect of how GP practice at Hampton Magna will cope with the additional patient numbers, whether expansion will be necessary and if so how it will be funded.

- Education.
The January 2016 census recorded 266 pupils against a capacity of 315.

WDC estimate that the total additional proposed homes for Hampton Magna and Hatton Park will generate in the region of 110 primary age pupils.

When added to the 266 pupils it would create a total of 376 pupils which is 61 pupils over the 315 capacity.

This would entail an expansion of the school from the time the extra housing is built. It does not take account of a future growth in numbers of pupils.

However, in respect of such expansion, there is no current detailed assessment of what work will be required, how and when it will performed and how it will be funded with certainty.

Therefore we believe the plan for Hampton Magna fails to satisfy the key requirement to show it is the proposal is Effective

This "it will be alright on the night" approach is inadequate.

8. Modifications necessary to make the Local Plan legally compliant or sound.

LEGALLY COMPLIANT AND SOUND

As the Plan has failed to satisfy Legal Compliance and Soundness then the allocation of 245 houses should be denied on the basis that such allocation has failed a proven sustainability assessment and the other failures in the Plan as stated in this response.

If the Inspector concludes that the Local Plan is Legally Compliant and Sound in some respects then at the very least it is proposed that there should be a significant reduction in the number of houses allocated for Hampton Magna. How this is achieved is a matter for the Inspector. For instance, he could deny the proposal for the additional 145 houses, or reduce the total 245 number in some other way.

There is potentially a more suitable site nearer to Coventry which should be considered as an alternative, e.g. Bubbenhall, given that meeting Coventry's housing is the focus of the Plan. This would also better meet the Positively Prepared key requirement in respect promoting sustainable transport in accordance with NPPF.

In connection with the proposed additional housing to be provided at Hampton magna we have the following concerns to raise:-

Adequacy of the Infrastructure

The original development of Hampton Magna was permitted as this was previous M.O.D. land and the infrastructure that was put in to support this development only as the surrounding area was designated green belt. The services at present are stretched to capacity and unable to support additional houses.

Access Routes

Three access routes are available onto Hampton Magna all of which reduce to a single track in places and all have bad vision splays in certain locations. Last week two accidents were narrowly avoided by my wife breaking abruptly to enable a bus to proceed, Farm vehicles also use these roads and additional traffic will only exacerbate this situation.

School, surgery, shops etc

The plan includes for 40% affordable housing which will generate additional pressures on the existing primary school, the surgery and shops. Parking problems are experienced at peak hours and this will be increased by the additional houses and those proposed at Hatton Park.

Greenbelt

Erosion of the greenbelt has a knock on effect on global warming increasing the carbon emissions. Adequate provision would need to be made to offset these additional carbon emissions. If, Heaven forbid, this additional housing is erected what measures will be put in place to prohibit this becoming an Urban Sprawl and encroaching further into the greenbelt.

Coventry Overspill

The basis of the additional housing needs has been stated as being necessary to cater for Coventry housing needs. Hampton Magna is over 10 miles from Coventry which would necessitate additional traffic on the A46 already congested in peak hours. If the need is for Coventry Overspill provision locations nearer to the City should be considered to reduce travel distances and thus carbon emissions. Additional housing provided at Chase Meadow to support Warwick's needs have resulted in homes being purchased by London Commuters. The presence of Warwick Parkway adjacent to Hampton Magna would make this scenario likely to happen here with the consequential increased parking and traffic problems.

We would earnest suggest that further thought is given to the proposals and the basis of the need for these additional houses.

Even though it purports to follow government guidance, the Strategic Housing Market Assessment (SHMA) is not independent and is seriously defective. It has considered only one side of the equation and only those with a vested interest in growth have influenced its findings. Population and household projections have been wrongly used as if they were forecasts. The assumption on headship rates is questionable and the study fails to get to grips adequately with economic issues, commuting, international migration, student needs and affordable housing. Above all, the SHMA acknowledges the high degree of uncertainty about the future but then plumps for a single figure of so-called Objectively Assessed Need (OAN) which is poorly justified. This figure is seriously lacking in credibility. [section 3]

The local authorities in their Memorandum of Understanding have misused the SHMA by adopting the so-called OAN uncritically and indeed adding to it. They have failed to consider whether environmental and other policy factors limit the ability of the area to meet its housing needs. The decisions they have reached about the distribution of housing provision within the housing market area are arbitrary, opaque and extreme, making the proposed plan unsound and unsustainable. The proposal that Warwick District should take the largest share of Coventry's overspill is reckless and wholly unjustified given the Green Belt status of a large part of the district. [section 4]

The Council have failed to demonstrate that nearly 17,000 dwellings can be built in the district by 2029. All the evidence suggests otherwise. Their response to the low level of dwelling completions in the first four years of the plan period is to allocate even more housing, without considering what (if anything) can be done to improve building rates within the existing allocation. As a result, the proposed plan would have a range of undesirable consequences for urban regeneration, vacancy rates and dereliction, commuting, service and infrastructure costs, housing opportunities and loss of Green Belt which neither the Council nor the Sustainability Appraisal have adequately considered. Those negative effects which the Sustainability Appraisal does recognise have played no apparent part in the development of the strategy. Almost half the dwellings to be built on allocated sites are in the Green Belt. The proposed plan is unsustainable and is directly at odds with policy in the National Planning Policy Framework. [sections 5 and 6]

The proposed plan and the cumulative impact of its development proposals would exacerbate problems which the district already faces such as loss of character and environmental quality, traffic congestion and inadequate public transport. Many of the individual housing proposals - particularly those involving substantial loss of Green Belt - cannot be justified and will do great damage. Nearly half of housing development on allocated sites would be in the Green Belt and the proposed plan does not comply with government policy on housing development in the Green Belt. Insufficient consideration has been given to the infrastructure implications of development on such a large scale. [section 7]

The plan is unsound, unsustainable and unworkable. It stems from a deluded view of the growth potential of Coventry and Warwickshire and is contrary to government policy. The plan needs to be fundamentally re-thought and housing provision of between 10,000 and 10,500 dwellings would be much more appropriate and potentially achievable. [section 8]

3. Defects in the Strategic Housing Market Assessment (SHMA)
The SHMA prepared by G L Hearn was intended to be an objective assessment of housing need in Coventry and Warwickshire. While it purports to follow government guidance, it has the following serious defects which fatally undermine its credibility:
* As a general rule, only organisations with a vested interest in increasing housing provision from its already very high level have been consulted. Those able to take a more detached and balanced view were conspicuously excluded. The local authorities themselves have a strong incentive to push house building rates higher and higher thanks to the New Homes Bonus.
* While the terms of reference for the study are reasonably objective, a wealth of e-mail correspondence between the local authorities and the consultants (released under the Freedom of Information Act ) suggests that there was a good deal of manipulation behind the scenes.
* The study rightly uses ONS population and household projections as the baseline for its work, but treats them as if they were forecasts. On the contrary, ONS say ''The population projections have limitations. They are not forecasts (my italics) and do not attempt to predict the impact that future government policies, changing economic circumstances or other factors (for example, government policies on immigration or student fees) might have on demographic behaviour...... As a forecast of the future population they would inevitably be proved wrong, to a greater or lesser extent..... Projections become increasingly uncertain the further they are carried forward into the future'. Hearns have fundamentally erred in treating the projections as forecasts and failing to consider how the policies or other factors that underlie them may change in future. They assume (paragraph 3.34) that uncertainty is mainly attributable to inadequacies in base data, but the effects of future changes in societal trends and public policy are likely to be far more influential. The SHMA never faces up to these issues.
* There is an unexplained anomaly in the use of the projections. The difference from the 2011-based to the 2012-based projections for the HMA is a decrease of 127 dwellings per annum. However, in Hearns' work this results in an increase of between 472 and 572 dwellings per annum . The consultants do not adequately explain this apparent conflict.
* The approach is based on the implicit assumption that new dwellings will meet existing and future housing needs, but this is not the case. Almost 90% of the private housing market involves existing, not new, housing stock. With the exception of starter homes, the great majority of new dwellings are bought by existing home owners. Except in the very long term, prices are insensitive to the volume of new house building and the market is not particularly effective in ensuring that newly arising housing needs are met.
* The study rightly explores a very wide range of scenarios in its attempts to quantify Objectively Assessed Need but fails to critique the underlying methodologies of the different models in which it places its faith. The study plumps for single figures within the range of possible outcomes (often towards the upper end of the range) that are arbitrary or poorly justified. The eventual recommendation that 4,272 dwellings per annum should be built in Coventry and Warwickshire seems to be a black-box generated number instead of being backed up by credible analysis at each step in the process.
* The 'part return to trend' on headship rates is poorly explained and justified. It is far from certain yet whether the cessation of the fall in average household size in recent years is just a 'blip' or the 'new normal' . The factors likely to influence this lead in different directions and give different outcomes. The consultants assume that a reduction in average household size will resume, but there is very little evidence for this;
* The economic forecasts used by Hearns give widely divergent results. The fact that they are based on past development trends is a major weakness, particularly as only a short, probably unrepresentative period has been considered. They also lack explicit assumptions about the productivity relationship between GVA and job growth. Yet the Local Enterprise Partnership is trying to attract high tech and high value added jobs, which would result in a lower number of jobs for a given level of GVA;
* The Strategic Employment Land Study is based on very arbitrary assumptions and data and has not been subjected to critical analysis. The 'talking up' of Coventry's employment prospects in section 4 of the study is very speculative, verging on wishful thinking, and the whole OAN is consistent with a rose-tinted view of economic prospects in Coventry and Warwickshire, bearing in mind past lower than national growth rates and skills shortages . Hearns have suggested upward adjustments to OAN in some areas in relation to economic prospects, but do not seem to have considered downward adjustments in other areas so the analysis is all one way. The equation made between jobs and people is over-simplistic;
* The assumptions about commuting are unrealistic. Commuting patterns change over time and it should be one of the objectives of a plan to reduce longer distance commuting in the interests of sustainability. Conversely however this plan is likely to lead to significant increases in commuting (see Section 6 below). The assumption that the commuting rate will remain as in 2011 is therefore naive and lacks any credibility;
* Much of the increase in population in Coventry over the past ten years or so appears to be related to the growth in student numbers in the city. A huge amount of development of student accommodation has taken place. The SHMA never properly addresses this issue. It fails to consider whether and to what extent these trends are likely to continue into the future; or the extent to which students require separate housing provision (as opposed to living in halls of residence or shared accommodation). Why should there not be a 'partial return to trend' on this issue, as on headship rates?
* International migration is mentioned in section 3, but there is no discussion of whether past trends are likely to continue. The Government is under intense political pressure on this issue and has maintained its target of lowering net in-migration by more than half. The outcome of the EU referendum is also likely to have a bearing on international migration. In recent years, Coventry has taken more than its fair share of in-migrants. There is no reason to think that in-migration to the city can or will continue at anything like recent levels. In Warwick District, net migration (including international migration) has varied greatly from year to year since 1995 and is inherently unpredictable. Also, net migration is influenced by housing and employment provision so there is an element of circularity in any forecast which is based on past trends;
* The relationship between affordable housing and overall housing need is never convincingly established by the study. Affordable housing should be a sub-set of overall need, not an 'add-on', so Hearns' upwards adjustment of OAN to take account of affordability appears unjustified. It is also debatable whether 'affordable housing' is affordable in practice to many new households. There is no evidence that Hearns have taken sufficient account of recent changes in government policy.
To sum up, the SHMA is a seriously flawed piece of work that should not have been used without critical analysis. At best the resultant so-called Objectively Assessed Need is subject to great uncertainty; at worst it is not credible at all.
4. Defects in the Way the SHMA Has Been Interpreted and Used
Government guidance is that Objectively Assessed Need should be a starting point for assessing what housing provision should be. The National Planning Policy Framework (NPPF) recognises that there may be circumstances in which development requirements cannot be met because of the demonstrable lack of environmental capacity.
In a letter in December 2014 , the then minister said 'A Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints that indicate that development should be restricted.... The outcome of a Strategic Housing Market Assessment is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans......Councils will need to consider Strategic Housing Market Assessment evidence carefully and take adequate time to consider whether there are environmental and policy constraints, such as Green Belt, which will impact on their overall final housing requirement.' Unmet needs from neighbouring authorities should be met 'where it is reasonable to do so and consistent with achieving sustainable development' .
The Local Plans Expert Group have drawn attention to a common deficiency in local plans. They conclude that 'despite the clear test set by paragraph 14 of the NPPF, few authorities compile an assessment of the environmental capacity of their area' . They go on to propose that a proportionate Assessment of Environmental Capacity should be an important part of plan making. The local plan making authority should consider the extent to which the plan can meet OAN consistent with the policies of the NPPF.
This type of approach is conspicuously absent in Coventry and Warwickshire. The local authorities in their so-called Memorandum of Understanding and Warwick District Council in its plan have taken a lemming-like approach which is directly at odds with Government policy. They have decided without adequate explanation that Hearn's Objectively Assessed Need of 4,272 dwellings per annum (already an artificially high figure) should be increased still further to a housing target of 4,408. They have then failed to consider whether environmental constraints prevent this new figure being met in its entirety. The Hearn approach and its results have not been subjected to any critical analysis whatsoever and the uncertainty that runs right through the study has simply been ignored. It is sheer folly to pick out a single figure and stick to it come what may. Such an inflexible approach is certain to be found wanting as the implementation of the plan unfolds. Meanwhile a great deal of damage will have been done. The position is even more serious in Warwick because the modification to policy DS20 opens the door for even further housing development in future to meet unspecified housing needs in other areas.
The housing proposals for individual authorities are unjustified, to say the least. Coventry is deemed (without supporting evidence or argument) to be able to accept only 1230 (64%) of its OAN of 1930 per annum. The remaining 700 is distributed (without explanation) between three Warwickshire districts - Nuneaton and Bedworth, Rugby and Warwick. In Warwick's case, this results in proposed housing provision of 18,640 over the full twenty year period to 2031, which is over 55% higher than its own OAN. This is a fundamentally unsustainable and unjustified outcome.
The Warwick Plan gives no explanation of -
a. Why Coventry cannot meet more of its OAN;
b. How the allocation of the excess to other authorities has been decided. The 'redistribution methodology' has not been explained or justified;
c. The account taken of Green Belt, environmental and other policy constraints, both in Coventry and in the surrounding Warwickshire districts, in making this judgement;
d. The wider effects of 'transferring' housing need originating in Coventry to Warwick and other authorities.
The plan also fails to consider the density of new housing development or whether intensification of use of the existing housing stock could be achieved without loss of quality in the urban environment. On most development sites, a density of 35 dwellings per hectare has been automatically assumed, ignoring the variability between sites and their settings and the potential for higher density. By leaving this vital issue unconsidered, the plan fails to provide adequate justification for the link between the vast quantum of new housing development proposed and the huge land area involved.
The Warwick Local Plan is therefore fundamentally unsound and unsustainable, quite apart from its unquestioning reliance on a deeply flawed Strategic Housing Market Assessment. The approach taken is, quite simply, indefensible.
5. Implementation Problems
Government guidance requires the Council to demonstrate the deliverability of the plan . The Council do not seem to have asked themselves whether it is realistic to expect 16,776 dwellings to be built in Warwick District between 2011 and 2029.
The Council claim that 1,483 dwellings were completed in the district during the first four years of the plan period - 2011 to 2015: an average of 371 dwellings per annum. The plan requires an average of 932 dwellings per annum to be built over the full plan period, including those first four years. If dwellings built in the first four years are discounted, the average for the remaining fourteen years rises to 1,092 dwellings per annum, nearly three times the rate achieved in the first four years (during which the economy was growing). It simply cannot be done.
The Housing Trajectory in Appendix A shows very clearly the unreality of what the Council are proposing. Average completions per annum between 2018 and 2022 are assumed to be some 1,730 per annum, nearly five times the rate achieved in the first four years of the plan. The beginning of this period is a mere two years away and the assumption seems to ignore the lead time required to assemble skilled workers on a very large scale.
The plan states that at April 2016 there will be sites with planning permission for 5,161dwellings. It is very difficult to believe that all these permissions will actually be implemented during the plan period, though that is apparently what the plan assumes (in contrast, for example, to the Rugby Local Plan which assumes low take-up of existing permissions). In reality, allocating many more sites is likely to reduce the take-up rate on existing permissions still further. Over-allocation on this scale would effectively destroy the planning strategy because the Council would surrender control to house builders over where and when dwellings would be built. Adding an arbitrary 'element of flexibility' to housing provision , taking it up to a grand total of 17,557 , makes matters even worse.
A figure of 16,776 dwelling completions by 2029 therefore belongs in the realms of fantasy. National and regional studies have shown that the main factor limiting the scale of house building has been the sharp decline in public sector house building. Despite some recent policy announcements, there is little prospect of a significant revival in house building by this sector. Private sector building has been stuck at around 90,000 dwellings per annum nationally since 2008 and the latest RICS survey indicates that growth in private sector house building slowed considerably during the first quarter of 2016. Overall, housing permissions have exceeded starts by about 50,000 dwellings per annum nationally in recent years .
A recent study by The Guardian newspaper showed that the nine largest national house building companies were sitting on planning permissions for 615,000 dwellings. Either they were incapable of building more because of shortages of labour, materials and / or finance; or effective demand is so low that they had no confidence that they could sell houses if they were built, or they chose to limit their output in order to keep house prices artificially high. Some house builders may also see investment in land as an end in itself in view of rising land prices. The truth probably lies in some combination of these factors. House builders have recently been criticised for 'land banking' by the Local Government Association.
So the prospects of 16,776 dwellings being built in Warwick by 2029 are negligible. Even so, house builders continue to press for high levels of provision so that they will have even more scope to pick and choose the sites that will bring them the greatest profits. This is understandable from their point of view, but should never form part of a credible planning strategy.
6. Likely Effects of the Housing Policies
As a result of this serious over-provision, the plan's housing proposals will have a wide range of unintended consequences -
a. The sites that provide developers with the greatest potential profit will tend to be green field sites outside urban areas rather than brownfield sites within them. The momentum behind urban regeneration will therefore be weakened still further and it will become much more difficult to redevelop windfall sites becoming available within the urban area. The Local Plan is right to have made an allowance for windfalls, but the more green field sites they allocate for housing development, the more difficult it will become to benefit from windfall sites;
b. Over-provision of housing can be expected to accelerate vacancy rates, dereliction and decay in the existing stock, particularly in the more marginal housing areas;
c. The displacement of housing from Coventry into Warwickshire will increase longer-distance commuting and lead to greater car dependency. No proper analysis has been done of this vital aspect of the proposals, least of all by the Sustainability Appraisal. Can the road and public transport systems cope with the extra traffic and passengers? With many roads, particularly in the towns of Warwick, Leamington Spa and Kenilworth, close to or above capacity already, the strong suspicion must be that the Warwick plan is unsustainable in transport terms. Where new roads or improvements to existing roads are proposed, insufficient information is given to demonstrate their financial viability or effectiveness in dealing with congestion;
d. A more dispersed pattern of development will lead to higher service and infrastructure costs once existing capacity thresholds have been exceeded, and will divert severely limited public sector resources away from renewal of services and infrastructure within existing urban areas . Developer contributions are rarely sufficient to provide necessary supporting services and facilities in their entirety;
e. Provision at a level not supported by effective demand is particularly destructive of the housing opportunities available to newer, younger and less well-off households: those most likely to be in housing need. New housing will overwhelmingly not be purchased by newer households. It is not valid to assume that a glut of new housing will result in lower prices all round, making the existing stock more affordable to those in housing need. In practice new homes are generally such a small proportion of the total housing stock that they do not have a significant lowering effect on prices;
f. Very substantial areas of Green Belt will be lost, compounded by losses for other purposes such as the sub-regional employment site. Proposed housing development in the plan accounts for some 500 hectares of Green Belt land and much of this is in strategically significant areas where the Green Belt performs vital functions, meeting all or most of the five purposes of Green Belt. It is very revealing that the plan does not make clear that meeting housing needs is not sufficient on its own to constitute the very special circumstances needed to justify inappropriate development in the Green Belt (see below) and that it generally ignores the recommendations of the Joint Green Belt Study;
g. Rigid adherence to forecasts gives only the illusion of certainty, inhibiting necessary adaptations to new problems and unforeseen opportunities . Warwick and the other Coventry and Warwickshire authorities have chosen to adopt a particularly rigid and unresponsive interpretation of present government policy and their proposals are therefore doomed to fail in practice.
These potential impacts of the Warwick Plan's housing proposals render the plan unsustainable and therefore not in compliance with government policy in the National Planning Policy Framework.
In particular, the plan fails to give sufficient weight to two key aspects of government policy:
a. That the presumption in favour of sustainable development does not apply in the Green Belt ;
b. That need for housing will rarely be sufficient to constitute the very special circumstances required for inappropriate development in the Green Belt. In July 2013, Local Government Minister Brandon Lewis said that 'The single issue of unmet demand....is unlikely to outweigh harm to the green belt and other harm to constitute the 'very special circumstances' justifying inappropriate development in the green belt' This was followed by a DCLG policy statement in October 2014 - 'the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability....of land...and take account of any constraints such as green belt which indicate that development should be restricted and which may restrain the ability of an authority to meet its need . This was in turn reflected in Planning Practice Guidance . Yet Warwick District Council, along with the other Coventry and Warwickshire authorities, seems to have ignored this very important element of government policy .
The Sustainability Appraisal has been updated to reflect the latest modifications to the plan and specifically the huge uplift in housing numbers. However it suffers from a major weakness: that it treats the Strategic Housing Market Assessment and the local authority Memorandum of Understanding as givens without subjecting them to sustainability appraisal in their own right. In general it does not apply sufficiently rigorous analysis and places exaggerated faith in mitigation measures. It plays down some negative effects because of uncertainty about the exact form development will take. It also makes some very questionable individual assessments - for example that the effect of high growth on public transport and community services and facilities will be positive, when experience suggests that provision of these facilities and services almost invariably lags well behind housing development, particularly when it takes place as rapidly as is envisaged in this plan. A positive assessment of the high growth options against 'reduce need to travel' also seems fundamentally misguided when such a high proportion of the proposed development involves meeting Coventry's housing needs in Warwick District.
Impact on the Green Belt should have featured as one of the sustainability criteria used to appraise the plan and its policies. Green Belt is simply subsumed within the much wider criterion of 'Prudent Use of Land and Natural Resources' and it tends to get lost in the process. The appraisal frequently pulls its punches, talking for example about the potential for the loss of Green Belt when the strategy entails certainty of massive Green Belt loss.
Nevertheless the Sustainability Appraisal finds that the two high growth options (900 and 1,000 houses per annum) would have negative effects in relation to six of the sustainability criteria used to assess options. This conclusion is effectively ignored in the plan itself and there is no evidence that it has played any part in the development of the strategy. The Council have wrongly assumed that they have no alternative but to meet so-called Objectively Assessed Need in full, plus the huge uplift to meet Coventry's excessive housing needs.
7. Comments on Specific Housing Policies and Proposals and their Justification
My calculations suggest that some 4,575 (49%) of the new dwellings on specifically allocated sites would be in the Green Belt. This is a staggering figure which cannot possibly be reconciled with Government policy as described above. It is difficult to imagine why Warwick District Council, given the large amount of its land area subject to Green Belt policy, agreed to accept by far the largest individual proportion of Coventry's overspill (6,640 dwellings). On the basis of conflict with government policy and the need to preserve a strong Green Belt to secure the continued separation of the towns in the district from each other and from Coventry, I object to all the locations for housing development listed in paragraph 2.81 as having been removed from the Green Belt.
My comments on selected proposals are as follows:
* Kings Hill (H43) - This development would be a huge and totally unwarranted projection of the built-up area of Coventry into the Green Belt and open countryside south of the city. It would doubtless be followed soon afterwards by an application for a boundary revision to extend the city's area. This is an area of good quality landscape which makes an important contribution to the role of the Green Belt in separating Coventry from Kenilworth. The proposal relies heavily on a new railway station and roads but given the long delay in securing reopening of Kenilworth station there can be no guarantee that a station at Kings Hill will be open before development takes place.
* East of Kenilworth (H40) - This long swathe of development would close the Green Belt gap which currently exists between the built-up area of the town and the A46. On rising ground, the development would be very visible from countryside to the east near Ashow and the National Agricultural Centre.
* North of Milverton (H44) - This would constitute a substantial northward extension of Leamington Spa into the Green Belt, bringing it significantly closer to coalescence with Kenilworth. The safeguarding of a large area of additional land for future development makes the present proposal just the thin end of the wedge. The explanation talks blithely about dualling the A452 but this is unlikely to be feasible within the existing built-up area of Leamington and may not be affordable in any case.
* Baginton (H19) - The Rosswood Farm site, almost in line with the airport runway, seems particularly ill chosen from the point of view of noise, air pollution and air safety.
* Barford (H48 et al) - The cumulative impact of these developments would be expected to have a substantial impact on the character of the village.
* Bishops Tachbrook (H49 and H23) - Taken together, development of these sites could be expected to have a profound effect on the character of the village and would involve projections into open countryside to the west and south.
* Cubbington (H50) - A substantial projection of development into pleasant open countryside east of the village.
* Hampton Magna (H51 and H27) - Taken together, these developments would represent a huge extension of the village into Green Belt and open countryside to the south and east, changing the character of the village in the process.
* Leek Wootton (DS NEW 3) - Although a minority of the site was already developed, this does not justify the proposal, which forms a very substantial westward extension of the village into open countryside and Green Belt.
* Whitnash (H-03) - Whitnash is already a peculiarly shaped and poorly accessed urban extension. This large development will add an extension to the extension, taking the village across the railway to the east and making it stick out even more like a sore thumb. It is noticeable that there is no proposal for a railway station to serve it.

Policy DS New 1 includes vague criteria for allocating land for housing south of Warwick. It is wrong in principle to consult without more clear-cut proposals, leaving local people and interest groups in a position of great uncertainty.
The plan is far too deferential towards the growth aspirations of Warwick University. The plan should not give the university carte blanche to do whatever it wishes to do, but that in effect is what is proposed.
A general problem is the heavy reliance on master planning for comprehensive development of the larger proposed housing sites. This will make it even less likely that the housing proposals will be implemented on anything like the timescale envisaged in the housing trajectory, particularly where land is in multiple ownership.
In new paragraph 1.09, the plan talks about new development enhancing the setting of natural and heritage assets. This is delusional and makes a mockery of what little remains of the plan's environmental credentials.
New paragraphs 2.1 to 2.43 talk about taking land out of the Green Belt so that it can be safeguarded for possible future development. In relation to government policy, there is even less of a case for this than where development is claimed to be needed during the plan period, and I have already shown that the latter is contrary to government policy.
I have not found a policy directed towards controlling or influencing the types and sizes of dwelling to be constructed in the district. This plan seems to treat planning for housing as no more than a numbers game and in doing so it ignores government policy that the nature of new housing is important .
8. Conclusions
The housing proposals in the emerging Warwick Local Plan are unworkable, unsustainable, contrary to key elements of Government policy and against the interests of residents of the borough. They are deluded and unsound. They stem from a fundamentally misconceived growth-orientated strategy that reflects wishful thinking about the economic prospects of the sub-region by the Local Enterprise Partnership and the Coventry and Warwickshire local authorities compounded by some far from independent technical work of questionable quality to support it. The proposals give minimal weight to the environment and character of the district, which have hitherto been cornerstones of successive plans. They will result in the Council effectively abandoning control over planning for housing and in a significant reduction in environmental quality.
Much of the problem with the housing strategy stems from Coventry's overweening growth aspirations, which result in dumping large quantities of housing and employment development on neighbouring local authorities. This is counter-productive, unsustainable and unachievable. If Coventry cannot live within its means, it should not simply decant large-scale development to neighbouring authorities with no thought for the consequences..
The question of what would be a realistic and achievable level of housing provision for Warwick between 2011 and 2029 is a matter of judgement rather than calculation. Taking into account all the factors discussed in this Critique, my view is that provision of between 10,000 and 10,500 dwellings would be appropriate. This would have a good prospect of being achieved and would meet the reasonable housing needs of the district, as opposed to the inflated figure assessed by G L Hearn and the huge additional uplift provided through overspill from Coventry. Provision at this level would allow a much higher proportion of development to be on brownfield sites within the urban area (including windfalls) and would require little or no release of Green Belt land for housing.

I totally support the submission by Hampton Magna Action Group and have added my name to that submission.

I would though like to add some personal comments:

1. Hampton Magna was built in the 1960s on the footprint of the Budbrooke Barracks, home to The Royal Warwickshire Regiment, and has pretty much remained unchanged since then, with generations growing up and still living in the village. There is a strong sense of community and the environment of Green Belt surrounding the village plays an important part.

2. The addition of a further 30 houses at Site H27 and the addition of 115 houses at Site H51 will destroy the character of the village, bring dangerous amounts of traffic, increase noise pollution and annihilate forever the aspect and health benefits that the proximity of Green Belt affords to villagers and myriad others taking advantage of the public footpaths and country walks, and goes against the Council's stated objective to protect and enhance the natural environment.

3. The main reason for the revision at Site H27 and inclusion of the previously rejected Site H51appears to be to take up the shortfall of housing in Coventry. The City of Coventry is some 12 miles away from Hampton Magna and if it is the case that a high percentage of people employed in Coventry have to live elsewhere, then as the only viable way of travelling to Coventry from Hampton Magna is by car that is surely creating a need to travel rather than reduce it, and as such has to be in direct conflict with the Council's stated aim to reduce the need to travel.

4. A recent report by the Campaign for the Protection of Rural England suggests major flaws in the assessment of housing need in Warwickshire, Coventry and Birmingham and the lack of adherence to government planning guidance policy. The Council has failed to prove exceptional circumstances to justify removing land from the Green Belt and more appropriate sites in closer proximity to Coventry have not been fully assessed.

5. Amendments to the Green Belt as now proposed at Sites H27 and H51 should only be made in exceptional circumstances for sustainable development. The infrastructure in Hampton Magna will struggle to cope with the already approved 100 houses at Site H27. The increased 30 houses at that site and the additional 115 houses at Site H51 will bring a huge increase in traffic (an increase in extra vehicles from 174 under the old proposal to 426 if the revisions are approved). This will not only affect the residential roads in the village, which already experience parking problems around junctions and at the school, but will have a major impact on the three country roads which are the only routes in to and out of Hampton Magna.

6. The three country roads mentioned above are accessed either
* from the A425 Birmingham Road by an ancient road bridge over the canal followed by a sharp blind bend into a road with a hill where vehicles even now experience difficulty in passing (Ugly Bridge Road)

* from the A425 Birmingham Road leading to Warwick Parkway, controlled by four-way traffic lights and leading into a single carriageway under the height restricted railway bridge

* from the A4189 Henley Road coming up through the adjoining village of Hampton-on-the-Hill with its mostly single carriageway main street with traffic calming measures, and leading to a rural road with passing place for buses or other large vehicles leading to a sharp blind bend up to Hampton Magna.

7. These totally unsuitable roads are already the route of choice to get to Warwickshire County Council or other places of employment in Warwick, Aylesford School & Sixth Form College, or to the Longbridge Island and the M40. The expanding development at Chase Meadow, also in south Warwick, means of course that these roads are extremely busy in the other direction as well, i.e. from Warwick, Stratford-upon-Avon, and the M40 cutting through Hampton-on-the-Hill and Hampton Magna to get to the A425 and on towards Birmingham and Solihull, or to get to Warwick Parkway station. Traffic on these roads will also increase when the 17,000+ houses are built in Warwick.

8. The revisions do not take account of already at capacity water, electricity, sewerage or drainage systems or the increasing flooding situations in and around the villages. The proposed development at Site H51 and the increase in development at Site H27 is therefore not sustainable, and there are no exceptional circumstances to warrant it.

I would submit, therefore, that new Warwick District Local Plan is unsound.

I fully support the points made in the submission by the Hampton Magna Action Group (submitted by Martin Taylor) and have added my name to that submission.

However, I would emphasise/add the following:

1. I feel that the flaws in the process started with the identification of Hampton Magna as a Category 1 Village without any research into suitable sites available or the effect any development would have on the infrastructure. Once that decision was made the Council were compelled to identify a site(s) in the village and did not fully assess all available options. This is like ordering a new lounge suite without ensuring it will fit in the lounge! The government's policy is against green belt development except in very exceptional circumstances. The Council has failed to identify such circumstances.

2. I would refer to the report commissioned by the Campaign for the Protection of Rural England, which highlights major flaws in the assessment of housing need in Warwickshire and neighbouring Coventry and Birmingham and the lack of adherence to government planning guidance policy.

3. I can confirm that we regularly see bats flying over the land at the rear of Lloyd Close.

4. Hampton Magna will not only have to deal with significant housing growth in the immediate area but the school, GP and other amenities will also have to cater for 175 homes proposed at Hatton Park.

5. The development in and around Hampton Magna is grossly disproportionate with an increase of 41% in housing provision in the village.

Consultation on Revisions to Warwick DC Local Plan
I am writing in response to the consultation on the revisions to the Local Plan which Warwick District Council is currently proposing. Specifically, I wish to object to the revised proposals for Hampton Magna, namely the increase in the density of housing on land to the south of Arras Boulevard, and the allocation of land south of Lloyd Close for 115 houses.
My objection addresses three issues:-
Whether the plan is legally compliant.
Whether the proposals are sustainable in the context of the district's needs
Whether there are alternatives which would better meet the needs.
There are a number of issues which potentially question whether the plan is legally compliant.
The change to the plan for Hampton Magna more than doubles the amount of housing proposed. As a consequence, the plan constitutes a major revision to the proposals. On the grounds of reasonableness, an issue governed by the Wednesbury principle, and indeed under the district council's own policies on communicating with local communities, there should have been consultation on the plan with Budbrooke Parish Council and the local community. There was none in advance of the proposals being published and agreed for consultation. Moreover, the documentation relating to the district council decision was not published until the latest possible date for the consultation, and it is in a form which is unintelligible to a layman.
Secondly, the plan considers proposals for Hampton Magna and Hatton Park separately. Other than a small local shop, there are no facilities in Hatton Park, and residents there use the facilities (school, GP surgery, etc.) in Hampton Magna. The impact of development in both Hampton Magna and Hatton Park should have been considered jointly, and has not been.
Thirdly, at a public meeting, residents of Hampton Magna were informed that the plan has been prepared only on the basis of taking account of land available for sale. This means that a substantial number of sites, indeed most sites, have simply not been considered. Given that a compulsory purchase process takes eighteen months typically, and the plan is for the period up to 2029, this again has to be of questionable legality in a Wednesbury context.
Finally, the proposals for Hampton Magna are all on land currently delegated as greenbelt. Greenbelt development is permitted in situations where an exceptional need is demonstrated. The revised local plan over-programmes the amount of housing required in the district by 800. This would tend to indicate that far from an exceptional need for greenbelt development, for the development of 800 properties there is, in fact, no need whatsoever. The threshold for exceptional need cannot, therefore, be met.
In summary, for the foregoing reasons, there is a significant question of whether the local plan is legally compliant, and I would contend that it is not.
The issue of sustainability relates to a number of factors;
i) whether infrastructure is sound and adequate and has both the capacity and capability to absorb additional load;
ii) whether there is adequate access to employment in a way which does not impact on the environment unduly detrimentally;
iii) whether it meets the district's housing needs in a reasonable way.
On the first of these issues, Hampton Magna has a range of community facilities, a school, a shop with post office, a beauty salon, and coffee shop, a public house and a GP surgery. These facilities are also extensively used by residents of Hatton Park which has only a small shop.
The school has room on site to expand, but parking around the school is a major issue, i.e. it is unsafe, and there is no possibility of sensibly absorbing the additional Hampton Magna and Hatton Park students. Other respondents have, I understand, included photographs of the current parking problems.
The GP surgery does not have room to expand in size, and already suffers from significant parking problems, with a very small number of parking spaces.
The most significant infrastructure constraint is provided by the roads into the village, all of which have severe restrictions. Ugly Bridge Road and Old Budbrooke Road have height restrictions. Both of these and Woodway have weight restrictions (which would have significant implications for developers' heavy traffic). All roads into the village are single lane at some point along their length (although Woodway purports to be two-way, which it is not). A study for the district council demonstrated that with only an additional 130 vehicles the road capacity would be exceeded in the morning rush hour, leading to routine traffic hold-ups. The revised proposal worsens this. There are no road proposals in the parish which would alleviate this (a proposed development at the A46 roundabout would have no effect on the parish roads. Even disregarding other impacts of the development, simply from a transportation perspective, any development on the scale proposed would require new access roads into the village from either the Henley road or the A46 directly.
Hampton Magna has had longstanding problems with its sewerage and drainage systems (the Parish Council have regularly met STWA and local councils about the issues). These would require major upgrading to cope with development on the scale now proposed.
Air quality in the village is poor. The revision to the plan is being proposed to take account of an additional housing need falling into the district from a corresponding shortfall in Coventry. It is, therefore, entirely likely that a reasonable proportion of new residents would have Coventry as their place of work. Despite Hampton Magna having excellent rail links, and some local bus services, travelling to Coventry by public transport would mean journeys in excess of an hour. In all likelihood, as a consequence, car usage would increase significantly in the village, further degrading air quality.
The proposed density of development is different to that currently found within the village, which is relatively low density with plenty of green areas and open spaces. Higher density development would change the intrinsic character of what is, despite it's relatively young age, a very rural village.
The proposal for Lloyd Close would also degrade the amenities of the village in two ways. Firstly, and recognising that no individual has a right to a view, the view across the fields to the south of Lloyd Close is an important public amenity, in that there are very few sites (the proposed area of development and Hampton on the Hill only, in all likelihood) where both of the historically important Warwick North and South Gates (St Mary's Church and Warwick Castle) can be seen together. As such, this is an important vista which should materially affect whether the exceptional use of a greenfield site can be considered in this context. Warwick has had a history of losing significant and important views (for example, through the development of the County Council's Barrack Street building), and it would be tragic to lose this as a public amenity. Secondly, the site, which has a footpath (dating back several hundred years) running across it, is used daily by walkers and dog walkers. Bats, a protected species, have also been reported on this site, and consequently a full survey should have been carried out.
The question of how the employment of incoming residents would impact on the village is an important one. There are very limited employment opportunities within the village. Good rail links exist to Birmingham and London, and intermediate stations, but, as stated earlier, public transport links to Coventry are very poor, and road links are along already heavily congested roads. Additionally, while rail links are good, parking at Warwick Parkway already operates at or near capacity, and four extensions to parking provision have already had to be made, with limited potential for further expansion. New residents from both Hampton Magna and Hatton Park would place additional demands on this parking.
Finally, an important consideration is whether the revised proposals meet the identified needs in the most appropriate way. A number of issues are relevant here.
As the additional need derives from a shortfall of housing in Coventry, having the largest proportionate increase in housing in a village 11.8 miles from Coventry, and without adequate public transport links to the city, is perverse.
The presumption of only using land available for sale was coupled with a wholly unreasonably short period for vendors to notify the Council of land availability (which was, I believe, only fifteen days) means that many potentially suitable sites have simply not been considered.
There is a Warwickshire village, Bubbenhall, which is much closer to Coventry (only 6.7miles), with similar facilities to Hampton Magna (and considerably better facilities than Hatton Park), and with considerably better transport links to Coventry, which has been excluded from consideration as a growth village, by the adoption of an arbitrary cut-off by the district council in a subjectively scored assessment matrix. This is unreasonable, and Bubbenhall should be reconsidered as a growth village.
If development at the revised level is required in Warwick, there are also freestanding greenfield sites (including a large site opposite Ajax football club on the Henley Road, which should have merited consideration for the development of a wholly new village (as Hampton Magna and Hatton Park were when they were developed). This would provide a number of advantages:-
The amenity of existing villages would be substantially unaffected.
The costs of creating the wholly new infrastructure required for a new village are much more readily determinable, meaning that the costs can be much more readily recovered through s106 agreements with developers, rightly limiting the costs falling on the public purse. Writing as a retired local authority treasurer, it is notoriously difficult to recover from developers anything like the full cost of enhancements to existing infrastructure for smaller scale developments.
A new development would much more clearly meet the threshold for exceptional development in the greenbelt, albeit subject to my earlier comment about whether any over-programming of provision could be considered legally to meet this threshold.
In summary, there are significant question marks about whether Warwick District Council's revised plan is legally compliant. There are further significant concerns about the sustainability of the revised proposals, and whether they provide for the most appropriate way of meeting the identified housing need for the district and the overspill need from Coventry. My conclusion would be that they do not.

With view to the proposed housing development, we would like to voice a few of our concerns as follows.
Firstly the increase in the volume of traffic in and out of the village and Hampton on the Hill as it stands at the moment after a recent resistant survey the volume in one week was 28,000 cars passing through I.e. for the train station and cut through for Motorway and bypass build up. The villages are not able to cope with this and the current speed limit being 40 miles per hour which leads to higher speeding.
Through Hampton Magna particularly on Slade Hill corner at school time it is almost impossible to pass due to cars parked on both sides of the bad bend, never mind buses or even emergency services trying to get through. This is a potential hazard waiting to happen. This needs sorting as it is. What are the proposals for this? Also the speed limit needs to be lowered to 20
Secondly, since moving into the village 11 years ago, we now over the last 2 years wake to the smell of sewage, we believed the problem lay in our house but after having several independent companies out to investigate the problem which they couldn't fathom, have discovered at the Council meetings that it is a widely shared issue across the village. This coupled with at least one power cut a day doesn't bode well with adding more houses into the equation.
Being a resident of Minster close if you were to us our road for access you would have to destroy two very old trees and get past the issue of this streets resident parking!
At the Council meetings nothing was mentioned about the 110 houses that are going up on the IBM site, along with the continued building on Chase Meadow and the proposed new builds on Hatton. Couldn't some of these be allocated for the Coventry overflow? Given that the increase on the village housing has risen by double and is double the proposed building amount on other local villages.
It was proposed that the Island on the Birmingham road was going to be made larger at the cost of x amount of millions, we really think this will not solve the traffic issue in and around getting into Warwick as the problem lies in the very small market town called Warwick,, which was never build for 21st Century living.

See attached

I wish to object strongly to the proposal outlined in the current Warwick District Plan to make substantial additions to the houses in Hampton Magna.
I and my family have lived in Hampton Magna for over 45 years and am well aware that permission for building in a Green Belt area was to be strictly restricted to the area vacated by the abandonment by the military of Budbrook Barracks.
This being the case, the infrastructure, such as sewers and narrow access roads provided was only sufficient for a limited number of houses. Indeed, as far as sewers are concerned, they were not even sufficient for the houses that were built, let alone any future development of the village - a fact evidenced by the fact that our garden has been flooded with sewage several times in the last few years.
The original proposal to build 100 houses on the land now owned by the Henry 8th Trust was ill conceived due to the factors relating to the infrastructure, but to increase that number to 130, AND build 115 on the land to the south of the village is, in my opinion, indefensible.
I have been led to believe that the present housing developments such as that to the east of Stanks Roundabout on the previous site of IBM, and the huge development Chase Meadow have already been included in the total that must be bourn by Warwick District. I am told that the increase in number is due to our area being compelled to take up the overflow from Coventry. If that is indeed true, I can only assume that the housing will be for people already working in Coventry - people whose travelling to and from work will add to the ever-increasing traffic congestion on the roads.
It seems to me that the increased designated area was selected without any local consultation and, I can only surmise, without even a site visit. I believe that, as new access and a new sewage system would be required for any additional housing, it would, in the long term, be more cost effective (being closer to the Warwick sewage works) to construct an access road from the A4189 and build on the land adjacent to the A46. This would not only mitigate against an increase of traffic in the village but would also leave a area of breathing space for wildlife between the present and the planned development, away from the hazards of road traffic.
On a purely personal level, as a member of the RSPB, I am concerned for the wildlife in the farmland surrounding two sides of our property. Beside the large number of birds which frequent our garden, it is a joy to hear the song of the skylarks that nest in the adjoining field and watch the flight of the resident bats in the evening.