Testun llawn:
I am objecting to the modification to the Local Plan because I believe that that the site in Old Milverton has been included the area of search for a Park and Ride scheme in North Milverton in error.
At the Public Examination session in October 2016 dealing with the proposed allocation of this land for residential and park and ride uses, I understood that Warwick District Council Officers had agreed to remove this land from the areas of search for a park and ride facility.
The Planning Inspector's required main modifications to the Draft Local Plan instructs Warwick District Council to revert to the areas of search for a park and ride scheme included in a previous version of the Local Plan, known as the "Submitted Plan", which did not include this site in Old Milverton. The modifications identified included an explanation of the need for only one P&R site to the north and one to the south. Also that the planning permission at the Asps including P&R removed the need for an area of search to the south. It advised that a description of their locations should be added by reference to those shown on the Policies Map for the Submitted Plan.
In addition, the Inspector required a modification to the 2016 Modifications proposed Policy DSNEW2, which identifies land to be safeguarded for longer term development. This modification required the removal of references to Land North of Milverton, otherwise known as Site H44, from the proposed Policy DSNEW2. The inspector included a modification to Policy DS15 requiring it to be amended as required by other main modifications and which include the modifications to Policies DSNEW2 and TR5.
The proposed modification of Map 2 - Milverton has included as an area of search for P&R land which was being promoted by a developer for housing and which proposal included a potential site for P&R. This is inconsistent with the Inspector's Modifications which stated: 'Explain that two Areas of Search to the north are identified and briefly describe where they are (i.e. those on the Policies Map for Submitted Plan)'. The land north of Milverton was not identified as possible P&R site until the 2016 Modifications and it was not shown as a P&R Area of Search on the Submitted Plan Policies Map.
Map 2 - Milverton is also inconsistent with the 2017 published Main Modifications which describes the P&R Areas of Search as set out above in paragraph 10. It is inconsistent in two respects, firstly the modified Policy TR5 refers to two Areas of Search, whereas the modification of Map 2 - Milverton implies three Areas of Search; Bericote, Blackdown and north of Milverton. Secondly, it does not mention an Area of Search to the west of A452.
In addition, I do not believe that such a Park and ride Scheme is viable and object to the proposed modification because:
It must be expected that the conclusions on feasibility of a potential Park and Ride facility would be affected by the less convenient location that would be available in the Area of Search shown north of Milverton. The Council has no evidence that it would be successful in this location and it is reasonable to conclude that this Area of Search is included only because the housing developer that promoted the land for future development suggested that it could deliver the P&R facility as part of that development.
Given that one of the requirements of a P&R facility is that it is convenient to passing drivers to maximise its attractiveness and to offset the disadvantage of changing modes from car to bus. The relative disadvantage in journey time of that change of made increases if the length of the bus journey reduces. Moving the P&R towards Leamington Spa is likely to reduce its potential to attract commuters travelling into the town. Accordingly, any proposed park and ride scheme to the north of Leamington should be situated as close to the A46 as possible. Placing a P&R further south toward Leamington will encourage parking in Leamington town centre rather than the park and ride as the relative benefit of parking outside of town decreases directly to the reduction in distance to the town.
As a resident of Old Milverton Lane adjacent to the proposed area of search for the North Milverton Park and Ride it is evident that the land north of Milverton would either require an access on Old Milverton Lane which would be dissociated with the main road or would require a new junction on A452. Any junction at this location is likely add to traffic congestion between the A452 Bericote Road roundabout and Old Milverton Road Roundabout, thereby encouraging people to proceed directly into town to park to mitigate delays incurred.
There is sufficient car parking available and the road layout in Leamington does not cause any significant traffic congestion.
Warwick District Council acknowledges that to make such a scheme work it will be
necessary to deter parking in Leamington by reducing available parking and increasing
car parking charges. The effect of such a move is likely to discourage visitors to the town and
will negatively impact on the livelihood of independent retailers who provide the distinctive
nature of Leamington's shopping experience. Furthermore it will encourage free road side parking
beyond the any chargeable parking zone in roads around Northumberland Avenue and Cloister Crofts rather than encouraging use of a Park and Ride scheme.
Warwick District Council is investing in a new multi-story car park in the centre of Leamington which is inconsistent with developing a Park and Ride scheme.
A Park and Ride Scheme will result in significantly reduced car parking revenues to both Warwick District Council and Warwickshire County Council and therefore it is unlikely to be supported by these Councils
The operators of the scheme (Stage Coach) believe that dedicated bus lanes will be necessary on the A452. There is no money available to make the A452 into a dual carriage way and these proposals have been withdrawn from the Local Plan.
The scheme is very unlikely to proceed and the areas of search included in the Local Plan blights the neighbouring properties
In conclusion I believe The Council is proposing a modification to the WLP that is contrary to the requirements of the Inspector and which has not been subject to any assessment of its suitability for this use and if such an assessment were made it would become clear that a Park and Ride Scheme in either North Milverton or Blackdown is unjustified