H51 - Hampton Magna - Land south of Lloyd Close

I am writing to comment on the proposed development at Hampton Magna. See your Local Plan Places Map 20.
This explosive increase of dwellings represents such a large percentage that it is unfair to existing residents when other more accessible villages have a lesser percentage increase. I am writing to explain why the proposed development at Hampton Magna appears to be flawed and unmanageable. The main reason it is said that Hampton Magna has been chosen for a large percentage increase of dwellings is that amenities are already in place.
We have a doctor's surgery, but this is situated in a very small area sandwiched between the shops, the school and the pub, because the surgery caters for the surrounding villages there is not enough parking spaces for patients. The same applies to the shops, causing congestion and danger to local residents.
There is a school but to accommodate extra children from Hatton Park and the children that the new development in Hampton Magna will generate, it will need to be greatly enlarged. There is already a major problem with parking at school drop offs and pickups.
The rail station has created problems for existing residents of Hampton Magna by the unofficial parking of vehicles around the village, also rail users are speeding through the very narrow country lanes to catch trains this has compromised the quality of life for walkers, horse riders and cyclists.
The lanes, leading into Hampton Magna are only country lanes and already choked with vehicles at peak times.
Why have other sites not been considered? A very large field next to the Warwick by pass on Hampton Road was for sale recently for a considerable time, this field would have had excellent access with potential for even more routes to major roads. It was situated close to amenities schools, doctors, pharmacy, shops and the pub.
The extra infrastructure necessary for this development will be costly, the sewage system is inadequate, the roads are too narrow and often single track. All the other amenities are overwhelmed already.

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.

Policy DS11, DS19
Mod 10, Mod 16
Para. 2.81
Mod. policies map no. Mod PM 20 - H51
We wish to make representations to support the removal of land from the Green Belt namely Policies Map 20 ref H51 - Hampton Magna land south of Lloyd Close. The proposal site forms a natural line of development and is well integrated with the existing development pattern of Hampton Magna.
The land is available for development and can be delivered within the required timescale.

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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.

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The Warwick District Council's Local plan, including the 2016 modifications is not sound.

Justification
Whilst the overall number of new dwellings Warwickshire County is required to take may in total be justified, the process for distribution across the neighbouring Districts and Boroughs is flawed. Each of these Councils identified its own criteria on which to base the number of dwellings, the sites identified and subsequent distribution of numbers to sites. This is inconsistent to such an extent that if one district or borough was in error or identified criteria to restrict site suitability, the all subsequent allocations are unjust.
Positively Prepared
Warwick District Council's approach to identifying sites to meet the modified number of dwellings in the new version of the Local Plan is flawed. The Council's approach of identifying sustainable villages has two major flaws:
First, it uses this information to justify the allocation of additional dwellings in villages that it considers are sustainable, but at the same time refuses to accept the fact that additional dwellings in or around villages that are not sustainable, would improve the potential sustainability of these villages. This is particularly the case in respect of public transport where funding is cut or services not provided because there is no demand. The current approach makes these villages less sustainable, and with aging populations, increases the risk of further isolation and disenfranchises rural communities. Additional dwellings would make these sustainable.
Secondly, although Warwick District has a proportion of its area in Green Belt, the creation of a small new town or enlarged village some distance from the main centre of population on green land would obviate the need to use Green Belt and therefore there would be no need for the use of Extra Special Circumstances for building in Green Belt. This situation does not occur in some other Districts or Boroughs because they are largely green land not green belt. It seems that in this instance the mechanisms for identifying the allocations mentioned above as unjustified.
Consistent with National Policy
National Policy is for planners and one would expect the plan to be consistent, however, I have grave concerns about the quality of expert advice provided by the county council and other statutory providers. Bearing in mind that this plan will play a significant for the future and bring in irrevocable changes over its duration, it would be reasonable to expect that Warwick District Council was diligent in its questioning the reasons for any infrastructure modifications or in most cases the reason why no new or modification of infrastructure was needed.
I take the case of Hampton Magna in which an additional 254 dwellings are planned to be built alongside some 650 or so. A primary school is already in place and has a good reputation. Within the general catchment area, taking account parental choice, a further 200 or more dwellings are due in Hatton Green (3 miles) and Hatton Park (2 miles). The Expert Advice on this is that an extra classroom will be needed. However, the School itself has had no input.
A similar position occurs with the network of roads connecting these villages, including the A4177 and the increasing volume of traffic using the popular Warwick Parkway station. The Infrastructure Report only identifies extra slip roads where the A4177, A425 & A46 meet at a roundabout, and traffic lighting. These modifications in the plan are not new. Prior to the Creation of the Local Plan traffic at this junction had already caused concern and the County Council were already planning to do this work. Local people are concerned that the modifications are inadequate, but also that Section 106 or CIL monies may the being redirected to paying for these. In two years the cost of the same modifications has risen from £1.4M to £3.4M.
The creation of a Local Plan is so significant that not to challenge the experts about their comments is negligent.
Sustainable
The question here is 'what does it mean' in this context. We don't know. The planners don't know. It is certain that those villages where there is no development will not be in themselves sustainable. It is clear from other sources that public transport, help for the elderly, Caring, Education, Health Services all of which are seeing a reduction in resourcing in real terms so these, and the populations and new developments using these cannot be sustainable. I have explained that capital infrastructure on roads is not there and most of the other services - gas, electricity, water and sewerage, and high speed broadband - are provided on a suck it and see basis. There is a miniscule chance that sometime after the end of the Local Plan, when more people have complained, the new developments may be sustainable. But it is too late then.

Conclusion
It is my contention that the Local Plan is so unreasonable that it is so unreasonable that no reasonable organisation acting reasonably could have made it: Wednesbury unreasonableness.

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We, the undersigned, register our opposition to the proposed housing development on the land at Arras Boulevard and south of Lloyd Close, Hampton Magna, H27 and H51.

We object to the loss of green belt land and believe that an additional 245 homes in Hampton Magna will have the following negative consequences:
- Have a significant visual impact on the existing houses.
- Have a significant impact on the existing infrastructure especially in terms of roads and an increase in traffic.
- Increase pressure on existing services and facilities.
- Have a negative effect on air quality, the local environment and biodiversity.
We call upon the Council to reject this proposed amendment to the local plan.

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REPRESENTATION

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: N/A

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: 

Justified: 

Effective: 

Consistent with National Policy: 

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

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 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.

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 are existing water pressure issues. 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. 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


 
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.

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