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Gwrthwynebu

ID sylw: 66724

Derbyniwyd: 27/06/2014

Ymatebydd: Stephen Trinder

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

Vehemently object to a proposal which is not as yet part of the Draft Plan but which has been proposed with just days to spare by Lynnette Kelly, prospective Parliamentary Labour MP for Leamington Spa and Warwick at the next general election.
Not sure that I'm able to object to something that's not yet officially - and I believe deserves never to be - part of the Draft Plan.
Objections to the soundness of Kelly's proposals are summarised below:
Positively Prepared
"This means that the Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development."
"Objectively Assessed Development"
Any possible amendment from Lynnette Kelly to the WDC Local Plan 2029 i.e.5000 houses on King's Hill on the WDC-Coventry boundary could not, as of June 2014, be positively prepared because:
There appear to be no current objectively assessed development and infrastructure requirement figures behind Kelly's proposals at the time she made them (late June 2014), and nor could there be.
With new ONS figures still under scrutiny, initially appearing to show lower figures for population increase in the WDC area than forecast, then Kelly's housebuilding proposals of 5000 houses for King's Hill could not possibly be based on a sound basis of need.The figures were still in flux.
No figures for infrastructure requirements and how they impact on her proposals appear to have been made.
Kelly's proposals also appear not to meet a neighbouring authority's unmet requirements, i.e. Coventry's. No suggestion that the boundary of Coventry be extended to include the new houses - indeed, Coventry's intervention in the whole affair was to offer to sell the land at King's Hill (currently owned by Coventry) to Warwick.
At no time was Kelly's call to move the 5000 Warwick houses to King's Hill presented as assisting a neighbouring authority. These would be Warwick houses.
WDC Plan, on the other hand, is sound and has been positively prepared, based as it is on has been objectively assessed development and infrastructure requirements. New ONS figures appear to show lower figures for population increase in the WDC area than were initially forecast if anything suggest a need for fewer dwellings needed to be built in the WDC area over the Plan period.
No objective justification whatsoever for a wholesale unloading of 5000 housing units onto the edge of a neighbouring authority.
Achieving Sustainable Development"
The Kelly 5000-house to King's Hill transfer also makes a mockery of sustainable development because:
The proposed site, sits within yards of one of the thinnest greenbelts in the West Midlands and this whole area already faces massive turmoil and destruction from HS2. Construction traffic for King's Hill would, unbelievably, share narrow roads with that for HS2.
Traffic to and from the regionally vital University of Warwick, which injects £222 million-a-year into the local economy, already snarls up the same B-rated Stoneleigh Road that 4000-odd cars would disburse onto from Lynnette's proposed King's Hill mega-estate.
Construction of a new, dedicated A46 access point for the site would entail colossal delays and expense, on top of the Kenilworth Bypass closures already scheduled during HS2 construction.
Over 4000 local people (from 1931 households canvassed) signed a petition against just 3500 houses on this exact location when they were proposed in 2009. Resistance remains extremely strong.
Justified
"The Plan should be the most appropriate strategy when considered against reasonable alternatives, based on proportionate evidence."
The Kelly proposal is not based on proportionate evidence, and is not the most appropriate strategy when considered against reasonable alternatives. She has no up-to-date ONS figures to show a need for Warwick DC houses in King's Hill, there is no sustainable transport plan, takes no account of the turmoil and considerable destruction this area is already scheduled for from HS2 from 2017 onwards, and neglects to consider that many of the roads construction traffic for King's Hill would clog are already HS2 construction-traffic routes.
Not the most appropriate and reasonable strategy, but are a political move.
Effective
"The Plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities."
Consistent with national policy:
The King's Hill site is not a solution which supports reductions in greenhouse gas emissions, reduces congestion, or facilitates the use of sustainable modes of transport. Reservations were made in 2009 about the ability of the site to achieve sustainable modes of transport.
With this route now scheduled for far greater use as part of the Electric Spine electrified railfreight line from Southampton to Nuneaton and thence to the North, it is unlikely that many slow, stopping trains could stop at a halt at the King's Hill development and no suggestions for such a rail line have even been included.Most of the 5000 house-dwellers on King's Hill would thus be expected to be car users, making this a wholly unsustainable transport site.
Most traffic to and from the site would be expected to use the A46, effectively an M road, the lack of opportunities for sustainable transport mode use would increase the pressure for new major transport infrastructure near and around the settlement.
Greatly increased traffic from King's Hill would further snarl up traffic along the B-rated Stoneleigh Road, which is used by very heavy numbers of Warwick University commuters going to and from their work, visits and study to the University.
The lack of sustainable access would greatly increase the need for new and widened traffic infrastructure on and around the site - such as a new southern relief road off the A46.
A Transport Statement or a Transport Assessment" has not yet been advanced.
As Kelly is proposing the King's Hill site as a Warwick settlement in WDC's area, her proposals run foul of NPPF Section 34's recommendations. New Warwick and Leamington Spa housing constructed in the vicinity of these settlements would better satisfy this advice. Warwick and Leamington people moving to King's Hill would need to commute back to these towns to work and burden an already extremely busy A46 Kenilworth Bypass as well as heavily used smaller roads
Most of the traffic from the King's Hill site would need to disburse onto and come off the A46 Kenilworth Bypass. This is, in effect, an M-road and unused by pedestrians, cyclists and bus services. The site would not, and cannot, have pedestrian, cycle, and high quality public transport facilities along its principal means of access and egress, the A46.
Lack of pedestrian footpath along Stoneleigh Road.
As the King's Hill settlement is proposed by Kelly as a Warwick settlement, the movement of largely Warwick people to and from a site eight miles from their normal jobs, friends, places and routines runs completely counter to a planning policy guided by Section 37.
The Kelly proposals of increasing the number of houses proposed from the 3500 under a previous proposal, which incorporated community parks, to 5000, which presumably would have far less area available hardly constitutes an attempt to "evolve designs that take account of the views of the community."
5000 houses on the King's Hill site, rather the 3500 discussed in 2009, would make delivery of shared space and community facilities, most especially parks, that much harder, if not impossible.
Density of the King's Hill site under Kelly's 5000-house suggestion would make NPPF recommendation very hard to achieve.
Building 5000 houses at King's Hill would run a coach and horses through points 1,2,3, and 4 of NPPF Section 80.
The setting and character of Kenilworth would also be damaged by King's Hill as it sits on an elevated position, giving views to and from Kenilworth and Coventry.
Putting 5000 Warwick District overspill houses on King's Hill would not retain or enhance King's Hill's landscape, its visual amenity or its biodiversity.
There are no 'very special circumstances'.
The King's Hill houses satisfy none of the criteria listed as acceptable for greenbelt building.
The landscape is valued by the people who signed a petition against possible construction of houses on this site in 2009. Placing 5000 houses, with little room for community sites or parks on elevated ground like this is not enhancing or protecting a valued landscape.