BASE HEADER

Gwrthwynebu

Revised Development Strategy

ID sylw: 56307

Derbyniwyd: 29/07/2013

Ymatebydd: Linda Bromley

Crynodeb o'r Gynrychiolaeth:

Objects to the proposal for 12,300 houses in Warwick District and nearly 4,000 new houses in Warwick on following grounds:

* Warwick Councillors asked that the proposed development should be equitably distributed over the District but half of the homes proposed are south of Warwick.

* Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and necessary infrastructure has never been put in place.

* The development south of Warwick is not sustainable as defined by the NPPF.

* Priority not given to existing brownfield sites and regeneration of poorer housing in urban areas (in accordance with NPPF 111).

* Contrary to the NPPF (76) in respect of protection of green space. 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

* The exceptions given in NPPF 89 and 90 to development of Green Belt land do not apply to the proposed Local Plan.

* Local Green Space is already designated and the scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents.

* urban sprawl will result rather than the stated aim of housing being distributed equitably.

* As alternative, proposes that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced reflecting urban/ rural population distribution, and to help sustainability of villages.

* Stratford-on-Avon Council has stated there are exceptional circumstances to develop on certain areas of Green Belt. Why doesn't WDC take same point of view? There is land available north of Leamington and in Kenilworth which is nearer to employment in Coventry and the Gateway.

* The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as a green buffer zone to separate Warwick from Leamington Spa.

* The District has 85% green [belt] but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich and versatile agricultural land, precious landscape and wildlife habitat.

* This green space also prevents coalescence which is one of aims of the Local Plan. The existing local green space provides open space, sports and recreation and such land, including playing fields, and should not be built on! (in accordance with The NPPF 109 )

There are alternative areas which were identified in the Core Strategy options which have not been considered this time:

* Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick.
* The Warwick Parkway area provides a first class rail link.
* Hatton has a station and access to the A46 and Barford has immediate access to the M40 and A46.
* Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.
* There is land to the west of Bishops Tachbrook which avoids gas pipe lines.
* the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

The argument that there is nowhere else to build is totally flawed.

Concerned that proposed development sites are located within areas susceptible to flooding contrary to NPPF (para 100)

Areas at risk of flooding have always been designated areas of restraint but these are proposed for development. More development must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End.

The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs.

This area designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3.

Concerned regarding ongoing local surface water flooding issues in the area around Myton Crescent. There is little indication that the seriousness of this flooding is being taken into account.

The Garden Town suburbs concept is admirable but naiïve when the number of buildings proposed and the impact on the environment is considered.

* This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600.

* Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. Provision of Green wedges doubtful since Council has admitted that where these are proposed, it will be reliant on private landowners to permit their development. Funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

* WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as seen in other recent developments. For example:

* Warwick Gates school and Chase Meadow play area never materialised but £1.4m of Chase Meadows developers' contribution was used instead for St. Nicholas Park remediation. The area allocated for sport/play area at CM was then developed for more houses

* After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction.

Concerned regarding the timely provision of infrastructure.

* The council confirm that infrastructure will not be put in place before building commences despite requirement of NPPF (17, 162) to plan for adequate infrastructure to meet local needs.
* The Council hopes that infrastructure will be provided from developers' contributions although it admits that this may not raise enough to cover escalating costs of infrastructure..

* If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out.

* The Council has admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out.

* No detailed information has been provided including site plans showing all the necessary infrastructure in place, potential costs, or results of studies.

* Warwick has already lost its police and fire stations, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point.
* Utilities such as water, sewers, electricity provision will have to be provided at escalating cost. Sewage treatment works at capacity. How will they cope with sewage from another 4,000 houses in Warwick, and at what cost?

* Buses have not proved to be sustainable. The only service for Myton Road is one per hour and is underused.

Concern regarding traffic congestion and air quality, in particular in the vicinity of the town centre:

* Does not meet NPPF requirements relating to: the role of planning in contributing to reducing pollution (17), reducing greenhouse gas emissions (95), ensuring planning decisions are consistent with local air quality management plan (124), and the importance of town centres to communities and of policies to support their viability and vitality (30).

* The Traffic Assessment acknowledges that the schemes "have not been tested to a sufficient level of detail to determine that they are the optimum solution" and that "an obvious concern surrounding the implementation of this strategy is that this will result in an increase in the overall levels of traffic travelling through the town centre"

* The Warwick District Air Quality Action Plan 2008 identified the entire road network within Warwick town centre as exceeding maximum pollution levels set out Air Quality Regulations (England) (Wales) 2000.

* Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the RDS.

* There is no management plan to address these levels. The Government says there is a definite link between pollution and traffic causing health problems such as asthma, some cancers, heart problems, etc.

* The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. There are schools in the town and in the areas of high traffic congestion such as Myton and Banbury Roads with playgrounds and playing fields and children are already being exposed to nitrous-dioxide above legally permitted levels, risking asthma and all the other health problems associated with pollution.

* Why is scale of development being proposed when the Council has admitted that it does not know how carbon emissions can be reduced 20% as currently required? It will inevitably add to congestion and air pollution.

* Requests that a Health Impact Assessment be carried out including air quality testing well before any Local Plan is approved.


* The green space forms the approach to Warwick and views from Warwick Castle. WDC say the area south of Warwick is environmentally sensitive but then proposes development - why?

* Parks will not be sufficiently protected from development once the old area of restraint is removed.

* The vibrancy of the town centre is important and the effect of additional traffic, on people sitting outside cafés in danger of being knocked over and from traffic related pollution funneled through Warwick needs to be considered People won't want to shop in Warwick because they won't be able to get into the town. There will also be an adverse affect on Tourism.

Traffic congestion impacts on the historic environment also need to be considered in accordance with NPPF (112)

* The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre.

* One of the mitigation measures suggested includes a gyratory system at the Castle island which, with its traffic lights etc. will severely harm the setting of the castle in a conservation area.

* Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge which already carries 20,000 vehicles per day cannot sustain an increase in traffic without threat to its very structure.

* Should be trying to reduce this traffic to prevent the bridge collapsing, not increase it.

* An impact assessment to ensure its conservation is required and English Heritage have offered to help with this.

The Strategic Vision states that in 2026 Warwick District will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands that have developed and grown in a way which has protected their individual characteristics and identities....." This could not be farther from the truth.

The Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable.

The Plan should be completely revised , specifically reducing the numbers of housing proposed for Warwick.