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In conclusion: I have to object to this plan that would be especially disastrous to Warwick. It has little relationship to the needs of the District as opposed to providing development opportunities for developers and shows little consideration for the context and environment of the county town of Warwick. The housing targets proposed for the plan are excessive and are well in excess of the needs of the district for the next fifteen years. The land allocations which these relate to have been made with a mind to enabling and funding large scale and inappropriate road "improvements" in the development areas and elsewhere in the district, several of which will channel more traffic into and through the historic and vulnerable core of Warwick - ignoring agreed policies designed to conserve the centre and reduce traffic (hence air pollution) in the centre. Finally, the plan does not take note of the key decision by Stratford on Avon District Council to locate a new town of up to 4800 houses in the vicinity of Gaydon and Lighthorne - which will have an added impact on Warwick through the traffic it will generate and the patterns of journeys to work the residents will have to take.


1. Concentrating development on the south of Warwick in preference to the more distributed pattern contained in the previous iteration is a bad plan which will a) seriously affect the county town b) introduce new pressures on and imbalances in the provision and use of services and c) generate patterns of traffic that are counter-sustainable which will have a disproportionate effect and will impose intolerable traffic conditions on Warwick and Leamington town centres and their approaches.

The potential for serious damage from excess traffic is compounded by the decision of Stratford on Avon District Council to propose a "new town" of up to 4800 houses at Gaydon/Lighthorne - which is too recent to have been taken into account in the preparation of the Warwick Local Plan but which will have a considerable effect on Warwick, and on traffic movements and services available in Warwick District.

The over-provision of development sites in the plan has a knock on effect on traffic generation patterns. Despite assertions to the contrary, the new plan by avoiding development in North Leamington is less, not more, one promoting dispersal. A more distributed set of more moderate allocations of development sites would have a less disastrous impact on traffic and obviate the need for highway "improvements" that would be seriously damaging for the reasons outlined above.

A key factor is the decision to delete the housing sites which were to be located within the greenbelt at Old Milverton. By deleting this site and concentrating development in the south the Warwick/Leamington area will become an unbalanced complex with the centres of gravity of Warwick and Leamington pushed southwards to the detriment of both town centres and leading to an undesirable coalescence of Warwick, Leamington and Whitnash and Bishops Tachbrook.

The previous proposals were for relatively modest intrusions into the green belt. These would have contributed to a distributed pattern of development in the district - far more sensible and conforming to the principles stated for the plan.

The decision has been justified on the basis of policies that were established more than 50 years ago. Times have moved on and the new local plan gave an opportunity to review the policies and areas covered by green belt restrictions which has been missed. This missed opportunity means that areas within the greenbelt which could have been developed with minimal damage to the landscape are to be saved at the expense of areas which the Council's own consultants acknowledge to have landscape value - and wanted to preserve..

The choice has therefore been made for new developments concentrated to the south of Warwick and Leamington which are excessive in scale and will be more distant than is necessary from the main services, sub regional employment centres and the facilities serving the district. A moderate release in the north Leamington area would have had little impact on the gap with Coventry and would make a good contribution to meeting the actual housing needs of the District. Furthermore, a north Leamington site would provide homes which would be relatively close to Leamington Town centre which would have easy access to the sub regional employment site and to other sources of employment in the sub region. The South Warwick sites on the contrary would require journeys to work that would cross the congested hearts of Warwick and Leamington (or via an improved M40 - the approval of which by the DfT is speculative and which would run contrary to the principles defined for the Traffic Assessment).


2. Development of the areas to the south of Warwick would be damaging to the setting of the town and would be contrary to the advice of the Council's landscape and environmental consultants. More note should be taken of their advice and to the preservation of the landscaped setting of the approaches to the south of Warwick

The District Council's report by RMA consultants states in respect of the land South of Gallows Hill & The Asps that "The largest part of the study area, is prominent in approaches to Warwick, is valuable in the setting of the town and provides the historic context for Castle Park. The recommendation remains that this area should be protected from development." The plans show that the Council have disregarded this advice which refers to an area much appreciated by residents and visitors alike and is an important factor in bringing millions of visitors to Warwick and generating much of the income which sustain Warwick's town centre's businesses.

In elaboration, the most attractive approach to Warwick and a classic piece of urban design is the view northward to Warwick along the Banbury Road. Cresting the rise and taking the bend north of the Asps opens up a vista ending with the distant view of the steeple of Saint Nicholas Church in its sylvan setting. In disregard of this, the plan appears to show a totally inappropriate ribbon of housing development to the east of and fronting the Banbury Road, (something that was stopped by the Ribbon Development Act in 1935) - with the Business Park or extension to the Warwick Technology Park intruding from the east as well as a car park! (Park and Ride). The frontage to Banbury Road and hence the vista along this approach to Warwick could be protected from this intrusive development by the extension of the "Asps" country park by way of a landscaped strip along the eastern side of Banbury Road and taking in the "Strawberry Field". Reducing the amount of development allowed in this area would not only preserve the appearance of this important landscape area and the contexts of Warwick Castle but would relieve some of the traffic pressure that will accumulate on the Banbury Road if it is developed.



3. The proposed land allocations trigger a need for road proposals that pay scant attention to the impacts of a) the traffic generated and b) the proposed mitigation measures on the existing urban fabric. Surprisingly, in several cases proposals are put forward without being backed by the evidence of traffic modelling. There is also little sense that the locations of proposed land allocations have taken account of the impact they make on the existing fabric, particularly in respect of the impact of the traffic they would generate. On the contrary it is clear that the objective has been to propose blocks of development that will be large enough to achieve a "critical mass" that will fund large scale traffic improvements which in several cases would be inappropriate and damaging to the Conservation Area of Warwick. Furthermore, with the absence of any mention in the plan or the Traffic Assessment of the need to safeguard the conservation areas from the impact of traffic it appears that planning has been solely concerned with accommodating the traffic generated from new land allocations rather than reducing their impact and safeguarding the interests of residents of areas affected. Indeed, the proposals in the plan for the highway improvements said to be needed to cope with the extra traffic are engineering solutions that pay little or no attention to their impact on their setting. They appear naïve, with little regard, for example, to their potentially catastrophic effect on town centre businesses and homes and hence are inappropriate or impractical.

For a plan for historic towns I am surprised and dismayed that I can find no mention in the proposals of measures to be taken to mitigate the effects of traffic and the new developments on historic buildings and conservation areas. Similarly, for an area that is already suffering from the impact of excessive traffic I can see no proposals for measures to improve the environmental wellbeing of such sensitive areas. The areas that are sensitive to the impact of the new developments include town centres and areas peripheral to them. These are areas already affected by the impact of excessive traffic and in some cases are subject to excessive levels of Nitrogen Dioxide which are damaging to health. If the plan is implemented residents of these areas will increasingly be affected as the years go by.

The Phase 3 Transport Assessment admits to the potential for heavier loadings of traffic on these sensitive areas and states "Routes into and through the town (Warwick) are likely to suffer substantial increases in the overall level of delay" and "increased congestion and reduced speeds ... occur within the town centre (slow moving and idling traffic being a major contributor to air pollution)." It also states that "The consequence of this increase is that areas peripheral to Warwick town centre all appear to suffer severe increases in queuing and delay" - and the pollution and environmental damage that will go with it.

The Warwick conservation area is of considerable architectural, historic and heritage value bringing hundreds of thousands (if not millions) of tourists to the district each year and is a major contributor to the local economy. Although it is a subject considered in the Town Centre plan, the impact that the developments proposed in the local plan will have on the area cannot be disregarded. The channelling of the traffic from the new development areas to the south of Warwick into Warwick town centre via the Banbury Road and the Grade ii* listed Avon Bridge will have a major adverse effect on the areas adjoining the Banbury road including Archery Fields, Bridge End, Warwick School, St Nicholas Park, Warwick Boat Club, Warwick Castle, the town centre conservation area as a whole and will be of particular importance to the safety of the children who walk and cycle to and from school in Myton Road.

The proposals for "mitigation" seem designed to funnel more traffic into the conservation area rather than managing traffic away from the sensitive areas of Warwick. Recent history is of a series of improvements to traffic management in Warwick Town Centre which have been controversial and have done little to improve the congestion and nothing to improve air quality. As a result Warwick residents are distrustful of road proposals affecting their town. What would restore their faith is a plan which reduces through traffic, improves air quality and contains proposals that respect the importance of maintaining the fabric of the historic core of Warwick and improves the quality of life of residents and people who work there. Solutions such as a five lane approach from a four lane Banbury Road which funnels into the two lane Avon Bridge are simply inappropriate to the point of being absurd and would be completely unacceptable!

We cannot be convinced of the need or desirability for such "improvements" especially as in several places the Phase 3 Transport Assessment makes clear that the evidence for the plan's proposals are still in question.

E.g., "At this stage no adjustments have been made for mode shift as a result of the delivery of the P&R, nor has a detailed level of optimisation been undertaken with regards to the amendments to the existing mitigation as well as proposals for any additional mitigation such as bus lanes and bus gating, etc." "It is recommended that the following risks are assessed at the earliest opportunity although it is acknowledged that the assessment of these risks prior to the adoption of the allocation strategy is, in some cases, unlikely to be possible:" "there are a number of assumptions that have been included within the modelling that may require further detailed analysis at an appropriate stage within the assessment period." "That, once the preferred allocation strategy has been determined, consideration should be given to undertaking an assessment to confirm that the proposed mitigation will still operate within acceptable levels." My emboldening.

Clearly, the plan recognises that there would be considerable adverse effects from extra traffic on the Bridge End and Banbury Road area and on central Warwick but rather than action recent agreed policy decisions on the need to reduce through traffic to Warwick it proposes a series of "improvements" that will remodel intersections and redirect traffic flows that are designed simply to accommodate extra traffic over and above the current excessive levels. This does not inspire trust or confidence in the plans or the value of and commitment to agreed policies.



4. The current pattern of journey to work in the sub region is for over 7000 vehicles to travel to and from Coventry each day in both directions across our area. The provision of major new or extended employment areas at Gaydon, south Coventry and to the south of Warwick will encourage additional daily journeys along roads that are particularly congested at peak periods already with consequent congestion and environmental damage. The park and ride proposal in the plan for a park and ride facility in the south of Warwick is not a priority as it will tend to increase cross town traffic rather than reducing it. The priority should be the development of the site to the north of Leamington.

It makes little sense for a park and ride facility to serve incoming workers from Coventry to be located in the South of Warwick area. Such a location merely encourages more cars to travel to their car park from Coventry through either of the congested centres of Warwick or Leamington on a journey to the south of Warwick business areas or its car park. A location to the North of Leamington would be far more effective in picking up the Coventry to Warwick commuters for their journeys to work in the employment areas to the south of Warwick. This is illustrated on the following drawing. "Principal journeys to work"




The plans for 12,300 new houses over 15 years contained in the plan are excessive. By planning to concentrate development on the areas to the South of Warwick the Council is both taking an easy option - allowing development where developers want to develop. - and is creating a bad and geographically unbalanced plan for Warwick and Leamington. With provision of only another 22.5 hectares of employment land which will support less than a potential 3000 new jobs the plan is also unbalanced in its provision of employment land and will consign the vast majority of new residents to becoming commuters. This issue is reinforced by the new decision of the Council to open the door for the Gallagher Business Park to be developed for housing. There is, therefore, no sense that this plan promotes sustainability in economic terms.

Apart from potentially destroying some of the most attractive approaches to Warwick the proposed developments would generate unacceptable extra traffic onto the road network to the south of and into Warwick town centre. The effectiveness of solutions contained in the Transport assessment proposed for the traffic problems appear in several cases to be unsupported by evidence and they do not inspire trust or confidence. Furthermore, there does not appear to be any acknowledgement in the plan to the importance of the contribution that heritage makes to the local economy. Neither do the transport proposals pay any respect to the sensitivity of one of the most important Conservation Areas in the County to the effects of increased traffic. Most obviously, the traffic plan proposes to channel ever more traffic onto the Banbury Road into Warwick town centre and over the already congested Grade ii* bridge over the Avon. Due to the timing of the consultation the plan has not taken into account the Stratford on Avon District Council proposal for a new town at Gaydon/Lighthorne which will add even more to traffic flows into and out of Warwick via the Avon Bridge. The suggestion that through traffic can be diverted away from south Warwick and onto the M40 is not likely to be welcomed by the DfT and an improvement to that road is unlikely to be either a short or even medium term priority.

The solution as far as the adverse effect of traffic on the southern approaches to Warwick Town Centre lies in a thorough review of the proposals for south Warwick, either to reduce the area for development or to reduce the amount of traffic from the area channelled through Warwick and thus the management of this traffic away from the Banbury Road and the bridge over the Avon.

Regrettably the plan focuses almost exclusively on the allocation of new development land. With some minor exceptions such as for cyclists and pedestrians (which are incomplete and not worth commenting on) it does not appear to seek to address the shortcomings that our town currently faces and it avoids issues in the town centre. In some respects we will look to the town centre plan to do that but the proposals in the local plan affect the centre and it would be remiss if the plan did not address the need to address issues such as the levels of nitrogen dioxide generated by traffic through our town and to take steps to address the morning and evening congestion around the Banbury and Myton Road junction - rather than the plans for development merely compounding the problems there.

In summary the following need to be attended to:-
1. The overall target for housing needs to be reduced to a more moderate level and to cater only for local needs and perhaps a modest expansion.
2. The areas for development need to be rebalanced.
3. The development areas to the north of Leamington should be reinstated following a review of the green belt around Warwick and Leamington
4. The plan's proposals should be reviewed following consideration of the potential impact of the development of a new town at Gaydon/Lighthorne
5. The approach to traffic assessments should be modified so that they are no longer geared to development areas that achieve a critical mass that would fund costly road proposals.
6. Reconsider the allocations of development land to the south of Warwick with the intention of reducing the impact of traffic generated from the new development areas on, in particular, the town centre of Warwick and its approaches
7. Introduce measures in the traffic assessment that will implement agreed policies to reduce the level of traffic in and through Warwick Town Centre as opposed to accommodating extra traffic.
8. In establishing a park and ride site, take greater account of the predominant patterns of journeys to work affecting Warwick and Leamington, and provide a location that captures traffic and reduces cross town flows and reduces traffic in Warwick Town Centre and its approaches - by giving priority to a location to the north of Leamington.
9. Protect the southern approach to Warwick along the Banbury Road from visually and environmentally intrusive new development
10. Rebalance the provision of employment sites within the area to provide local jobs for the new residents rather than having to commute
11. Delay decisions on development land allocations where traffic assessments are currently inadequate, until we can judge their validity

I look forward to hearing that the next iteration of the plan will take proper note of what are serious shortcomings in the current version and that the council will address them by making significant changes in response to the needs identified and the numerous objections being made to the proposals that especially affect Warwick.