BASE HEADER
Mod 15 - paras 2.66 to 2.68
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 68232
Derbyniwyd: 13/04/2016
Ymatebydd: Miss Carol Duckfield
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Where is the infrastructure plan to ensure that you can still move around Leamington/Warwick when all these new homes have been built?
Leamington is bound to the south/west by river, cannal and railway lines with only 4 routes to get over these obsticles - where is the plan to deal with the existing problems this causes before an additional 18k cars are added to the equation?
Where is the plan for a relief road to link Whitnash and Cubbington?
This revised plan appears to be completely lacking in an overall infrastructure review to explain how the area will remain mobile when all these proposed home have been developed - already getting anywhere at peak times take an inordinate amount of time and simply dapping developments around without considering the infrastructure requirements is irresponsible and reckless.
Leamington is separated from Warwick by a river (prone to flooding) and a railway line with only a single crossing over the river and is separated from the south of the town by no only the river and the railway line but also a canal with only 3 crossing points.
The recent changes to Princess Drive and Europa Way are a missed opportunity to start to address the blockages that Leamington suffers from but has nothing but tinker with things. Surely it would have been sensible to start to dual the roads.
There is also a need for a relief road to the East of Leamington to provide a means of linking Whitnash and Cubbington and an alternative route
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 68410
Derbyniwyd: 19/04/2016
Ymatebydd: Leamington Society
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Development of land off Europa Way is not sustainable or environmentally responsible. Road traffic increases in the town of Leamington and Warwick will increase to an unacceptable level
The major and growing challenges of congestion, air quality and climate change are clearly recognised as critical planning issues within the NPPF.
4.29 The transport system needs to be balanced in favour of sustainable transport modes,
giving people real choice about how they travel.
4.32 Plans and decisions should take account of whether:
the opportunities for sustainable transport modes have been taken up, depending on the nature and location of the site, to reduce the need for major transport infrastructure.
4.35 Plans should ... be designed ... to give priority to pedestrian and cycle movements, and give access to high quality public transport facilities.
The SA consultation considers "Likely Effects of the Local Plan Modifications" (pp 21-25) on Transport & Accessibility, Air Quality and Climate Change. It acknowledges in each case the "potential to increase the significance of negative effects". It then comments on "a range of mitigation strategies ... which will contribute to reducing the extent of these negative effects" but will not eliminate them.
The SA also shows extensive colour coded charts featuring numerous question marks in the various boxes. Thus we are offered a verbose, shuffling, imprecise narrative, which suggests the outcome may not be all that bad.
Cefnogi
Proposed Modifications January 2016
ID sylw: 69050
Derbyniwyd: 21/04/2016
Ymatebydd: Environment Agency
We support the wording of the proposed modification.
See attached
Cefnogi
Proposed Modifications January 2016
ID sylw: 69169
Derbyniwyd: 22/04/2016
Ymatebydd: Lioncourt Strategic Land - Andy Faizey
Asiant : Savills
SUPPORT the requirement for a Development Brief for Kings Hill provided that a clear timetable and framework for this document can be agreed at the earliest opportunity.
It should be noted that there is already a consortium and associated agreements in place to ensure that a comprehensive, sustainable and deliverable development can be achieved at Kings Hill.
see attached
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 69241
Derbyniwyd: 22/04/2016
Ymatebydd: CEG Steel/Pittaway
Asiant : Nexus Planning
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Preparation of Development Brief including safeguarded land S1 is not a viable option and would be allocating / making land use assumptions on future policy. Could clearly be construed as going beyond the remit of supplementary planning documents or other guidance in detailing matters which should be reserved for local development documents.
With safeguarded land, not possible to determine wider community facility needs or impacts - Council cannot force owners to do so.
Development Brief required by Policy DS15 for this area would have no planning status, would lead to piecemeal development of a significant growth area.
see attached
Cefnogi
Proposed Modifications January 2016
ID sylw: 69340
Derbyniwyd: 15/04/2016
Ymatebydd: Crest Strategic Projects Limited
Asiant : d2planning
These representations should be read in conjunction with our representations in respect of Mod 14 in relation to Policy DS15 Comprehensive Development of Strategic Sites.
Only one landowner and one developer - enables the site to come forward without any issues regarding ownership. Vision Statement demonstrates how the land can be comprehensively developed with a potential early start on site.
Crest would work with the Planning Authority and all other interested parties to prepare and submit a planning application as soon as practicably possible following the completion of all of the relevant survey work which is already underway.
See attached
Cefnogi
Proposed Modifications January 2016
ID sylw: 69402
Derbyniwyd: 21/04/2016
Ymatebydd: Environment Agency
We have carefully reviewed the modifications proposed within the document based on the Planning Inspectors Interim Report and we find the it meets the tests of soundness:
We agree that the plan is positively prepared, justified, effective and consistent with national policy with the proposed modifications.
We have the following comments to make:
Modification 15
We support the wording of the proposed modification.
We have carefully reviewed the modifications proposed within the document based on the Planning Inspectors Interim Report and we find the it meets the tests of soundness:
We agree that the plan is positively prepared, justified, effective and consistent with national policy with the proposed modifications.
We have the following comments to make:
Modification 15
We support the wording of the proposed modification. Modification 21 - Section 1.8
The Finham Brook, a designated Main River flows through the King's Hill site H43 near the southern boundary. We would support proposals to create land for open space and this should be linked in to the provision of green and blue infrastructure. Every opportunity should be taken to create additional flood storage to reduce the risk of flooding elsewhere. Ammendments to Policy DS11 Paragraph 2.4.1
We note that sites were assessed for their suitability against the SFRA Level 1. Warwick District Council's SFRA is dated April 2013 and we recommend that it is updated to take into account changes in Policy (NPPF) and the revised climate
change allowances. The Environment Agency updated their guidance on how climate change could affect flood risk to new developments - 'Flood risk assessments: climate change allowances' published on gov.uk on 19th February and came into immediate effect.
The update is based new scientific evidence. The main changes are to the peak river flow allowances. We are currently preparing new guidance which can be appended to the SFRA before the examination of the Local Plan is resumed.
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 69692
Derbyniwyd: 22/04/2016
Ymatebydd: Gleeson Developments
Asiant : Savills (L&P) Ltd
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Policy as currently drafted requires development briefs for Kings Hill and Thickthorn/east of Kenilworth to be broadly compatible with each other in terms of infrastructure and commitment to sustainable growth. This requirement is unjustified and not effective. Each development area will be required to demonstrate sustainable development in isolation and to deliver appropriate infrastructure to mitigate its own impact. The requirement should not extend to consideration of infrastructure requirements on other sites. It is suggested that the wording of Policy DS15 is amended to require to have regard to the development briefs (where they exist) as set out below.
See attached
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 69818
Derbyniwyd: 22/04/2016
Ymatebydd: Coventry and Warwickshire Local Enterprise Partnership (CWLEP)
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Policy requires comprehensive development to be articulated through "either a Development Brief or a Layout and Design statement" This would provide opportunity to plan areas for small scale employment use into the land use framework of some of these development areas.
The proposed table in Modification 14 to Policy DS15 should be further amended to make it clear that the schemes should (where appropriate) contain an explicit employment allocation identified by a specific gross floorspace allocation for employment uses .For example the large proposed schemes at Kings Hill and Westwood Heath would appear suitable to accommodate small scale employment opportunities.
See attached
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 69835
Derbyniwyd: 22/04/2016
Ymatebydd: Bishop's Tachbrook Parish Council
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
2.66 This new paragraph is of concern. Leaving matters to landowners to work closely together to produce the most appropriate overall scheme for the site is unlikely to produce the result anticipated. Multi-headed leadership rarely works. The LPA should take the lead and co-ordinate the parts of the development to an overall masterplan agreed before the detail developer work commences.
2.68 Who judges that the strategic sites are being developed in a comprehensive manner? Left to the developers it will lead them to expect that their schemes will be nodded through, as costs come into consideration.
See attached
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 69852
Derbyniwyd: 22/04/2016
Ymatebydd: Mrs J Mackenzie
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Allocations contrary to NPPF requirement to maintain separation, prevent coalescence
Numbers based on Coventry requirements not approved in local plan, revised before 2017?
No critical examination of claims that land unavailable -areas of Coventry green belt could be developed with less impact
Provision of land to meet Coventry's overspill contrary to NPPF - require sub-regional SA to be valid
How do proposals fit with neighbouring development
No consultation undertaken with parish councils before decisions made
MoU providing additional housing for Combined Authority circumvents democratic process, NPPF
Impact of proposals at Thickthorn and Kings Hill next to over-capacity A46 not considered
See attached
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 69965
Derbyniwyd: 22/04/2016
Ymatebydd: Gallagher Estates
Asiant : Pegasus Group
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Ydi
Dyletswydd i gydweithredu? Heb nodi
Outline planning permission has already been granted on the eastern part of the H46A allocation within the control of Gallagher Estates and not on the land to the west. As such it is considered that additional wording should be added to Policy DS15 which acknowledges that planning permission has been secured on part of H46A and which requires the remainder of the site, which does not have the benefit of planning permission, to come forward in line with this outline approval.
See attached
Gwrthwynebu
Proposed Modifications January 2016
ID sylw: 70300
Derbyniwyd: 23/04/2016
Ymatebydd: Hazel and Robin Fryer
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Most of the modified submission relates to increasing the number of new houses and proposes building a major housing development in the narrow greenbelt between Kenilworth-Stoneleigh and Coventry. This is contrary to the NPPF requirements in Paragraph 80 "To check the unrestricted sprawl of large built-up areas." "To prevent neighbouring towns from merging into one another"; therefore the proposed modified Local Plan is unsound.
see attached