Publication Draft

Object

Representation ID: 66031

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

HOUSEHOLD SIZE
The JSHMA assumes a rapid decrease in average household size which is not supported by evidence. The base data are questionable and other sources suggest a rise in average household size in Warwick District between 2001 and 2011. If tends are applied household size would fall to 2.30 in 2031. However GLH hearn have applied some senisitivities to take account supression of household formation, meaning household sizes would fall to 2.22 by 2031 - a much greater fall than past trends indicate and is an abuse of sensitivity testing. For instance factors acting in the opposite direction have been ignored such as the trend towards households which accommodate three generations.

PROJECTED POPULATION GROWTH
THE JSHMA is not based on the most up to date population projections. The latest projections show a 29% reduction in growth to the end of the plan period - 6,200 fewer people. This reduces by some 2,800 the number of new homes needed. Suggestions that this should be balanced by increases in Coventry's population growth are spurious as projected growth in Coventry is an artificial projection as a result of the universities' response to changes in their funding régime - incoming students are repeatedly added to each year's projection, but outgoing students are largely omitted. Without this Coventry's population is projected to grow in line with that of the sub-region as a whole.

The impact of this is that housing growth should be in 8100 over the plan period.

The knock on effect of the Council's proposals are that the average household size would be much smaller than projected and this is not consistent with the proposed densities of developments on greenfield sites. This inconsistency futher contributes to the unsoundness of the housing need calculation.

Object

Representation ID: 66398

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The NPPF, quoted at para 1.7, prefers that the Plan should be drawn up over a 15 year period. This Plan (para 1.29) covers the 18 years 2011 to 2029.

Object

Representation ID: 66405

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The tabulation in policy DS7 shows that 3,600 new homes have been completed since 2011 or had planning permission by 31 December 2013, that a further 3,100 sites will become available as windfalls, as Small Urban sites in the SHLAA and through the consolidation of existing employment areas and canal side regeneration; urban brownfield sites allocated in policy DS10 provide 1,300 new homes. The total without any use of greenfield land provides for 8,000 new homes.

The requirement for substantial expenditure on healthcare and education infrastructure would be very much reduced, and the needs of the growing population met by incremental expansion of existing facilities within the existing built up area.

The transport infrastructure requirement would be heavily reduced. The need to accommodate traffic growth, especially from greenfield developments south of Warwick, would disappear. Development sites within the existing built up areas would create much less demand for transport: local educational, healthcare, retail and leisure facilities would be largely within walking or cycling distance of the new homes.

Object

Representation ID: 66406

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation of greenfield sites otuh of Warwick make it impossible to meet to meet transport needs sustainably as required by the NPPF.

The relatively low densities proposed mean more space devoted to roadways and parking. the location will will create journeys as few destinations will be within walking distance. The road network is unattractive for cycling and buses cannot provide the quality of service to compete with the car.

Sustainable transport poliucy is paid lip service (paras 5.28 to 5.59) as evidenced by expenditure splits in the IDP.

The effects of the proposed mitigation on on traffic flows is questionable and raises doubts about the quality of the modelling. They do however show increased jourvey times, worse congestion and worse air quality. There are inconsistencies between the IDP and the STA. The STA also appears to indicate that any Plan which depends on increasing the flow of vehicles through Warwick Town Centre is undeliverable.

The Plan takes no account of previously well-founded objections.

Object

Representation ID: 66407

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation of greenfield sites otuh of Warwick make it impossible to meet to meet transport needs sustainably as required by the NPPF.

The relatively low densities proposed mean more space devoted to roadways and parking. the location will will create journeys as few destinations will be within walking distance. The road network is unattractive for cycling and buses cannot provide the quality of service to compete with the car.

Sustainable transport poliucy is paid lip service (paras 5.28 to 5.59) as evidenced by expenditure splits in the IDP.

The effects of the proposed mitigation on on traffic flows is questionable and raises doubts about the quality of the modelling. They do however show increased jourvey times, worse congestion and worse air quality. There are inconsistencies between the IDP and the STA. The STA also appears to indicate that any Plan which depends on increasing the flow of vehicles through Warwick Town Centre is undeliverable.

The Plan takes no account of previously well-founded objections.

Object

Representation ID: 66408

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation of greenfield sites otuh of Warwick make it impossible to meet to meet transport needs sustainably as required by the NPPF.

The relatively low densities proposed mean more space devoted to roadways and parking. the location will will create journeys as few destinations will be within walking distance. The road network is unattractive for cycling and buses cannot provide the quality of service to compete with the car.

Sustainable transport poliucy is paid lip service (paras 5.28 to 5.59) as evidenced by expenditure splits in the IDP.

The effects of the proposed mitigation on on traffic flows is questionable and raises doubts about the quality of the modelling. They do however show increased jourvey times, worse congestion and worse air quality. There are inconsistencies between the IDP and the STA. The STA also appears to indicate that any Plan which depends on increasing the flow of vehicles through Warwick Town Centre is undeliverable.

The Plan takes no account of previously well-founded objections.

Changes to Plan:
The modification necessary to make the Plan sound in respect of sustainable transport is for the allocation of greenfield land to be withdrawn and for a new transport strategy which respects the policy priorities to match the changed pattern of development.

Object

Representation ID: 66410

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The allocation of greenfield sites otuh of Warwick make it impossible to meet to meet transport needs sustainably as required by the NPPF.

The relatively low densities proposed mean more space devoted to roadways and parking. the location will will create journeys as few destinations will be within walking distance. The road network is unattractive for cycling and buses cannot provide the quality of service to compete with the car.

Sustainable transport poliucy is paid lip service (paras 5.28 to 5.59) as evidenced by expenditure splits in the IDP.

The effects of the proposed mitigation on on traffic flows is questionable and raises doubts about the quality of the modelling. They do however show increased jourvey times, worse congestion and worse air quality. There are inconsistencies between the IDP and the STA. The STA also appears to indicate that any Plan which depends on increasing the flow of vehicles through Warwick Town Centre is undeliverable.

The Strategic Transport Phase 4 and Cumulative Assessments which support the Infrastructure Delivery Plan contain significant flaws. They describe schemes which have not been prepared in detail. Their costs, feasibility, deliverability, and impact are uncertain. Their effect on traffic is questionable: work carried out under the management of the Save Warwick Group, which is making its own representation, raises numerous doubts about the quality of the modelling and the realism of its conclusions.

These conclusions nevertheless indicate increased journey times, worse congestion, and air quality within the Warwick and Leamington AQMAs being worse than it would be without the 'mitigation' schemes.

There are differences between the schemes contained in the three documents, and these differences emphasise that no coherent traffic plan, let alone a transport strategy, exists.

The Plan takes no account of previously well-founded objections.

Object

Representation ID: 66411

Received: 30/06/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Plan is not accompanied in its 'evidence base' by a Heritage Impact Assessment, except for drafts concerning greenfield sites at Gallows Hill and the Asps that are not allocated for development. The effect of the Transport Strategy and its 'mitigation' schemes on Listed Buildings and the Conservation Area of Warwick Town Centre has not been considered. The effects of the transport strategy are likely to be damaging - vibration and air pollution likely to have an impact on listed buildings. By making historic streets primarily conduits for heavy through traffic, the Plan puts at risk the listed and conservation area buildings which line them.The permeability of the town centre would be reduced by the priority given to vehicles. All of these effects would depress the town centre economy, reducing its attractiveness to both residents and visitors.

The effect of trafiic has been recognised by condition attached to recent and current developments eg South West Warwick. But this absent from the new plan.

The Plan therefore fails to meet the NPPF requirement for a 'positive strategy for the conservation and enjoyment of the historic environment'.