GAYDON PARISH COUNCIL

Clerk to the Council: Corinne Hill, Gaydon Fields Farm, Gaydon, Warwickshire CV35 0HF

01926 641220

Email: parishclerk86@btinternet.com

23^rd November 2015

Response to:

The Agricultural Land Classification Study Aug’15.

The Retail Addendum Note Sept’15.

The Design and Access Statement Oct’15.

The ES Addendum Vol 1 and 2 Oct’15.

Opening Overview and Responses.

It is clear from a preliminary examination of the documents that there have essentially been very few fundamental changes to plans that have been submitted in the past and that are still being reviewed by the Inspector Mr Peter Drew. GPC still considers this very premature with statistics being presented to justify plans and direct decisions that technically are still to be made.

The development at GLH may meet SDC’s need for housing but in the opinion of Gaydon Parish Council (GPC) fails all other measures of success simply because of the lack of ambition to create a free flowing, attractive environment to live and work in. GPC has, right from the start, based its opposition to the scheme primarily on the lack of effective transport infrastructure plans. It categorically doesn’t believe that these have been addressed – indeed it strongly believes that through the careful selection of measures and use of statistics that all infrastructure needs have been explained away and swept away through idealised language and theoretical ideals.

This lack of ambition and investment in infrastructure to create a sustainable community seems to emerge from the documents as named above. Within the Retail Addendum Note, it quickly becomes apparent that what is planned doesn’t cater for existing local populations and those slightly further afield: the second biggest town in the Stratford Area with just minimal local retail services. Minimal provision for Health, minimal provision for whole sectors of the community (with no on site secondary schooling) and minimal improvements to traffic infrastructure compensated by the odd bus and a travel plan that aims to reduce expected increases in traffic by 5%.

Such lack of vision and ambition contained in the ES Addendum and Design and Access Statement does not support the sales pitch and statements that aim to communicate sustainability.

Specific Responses to each document:

Agricultural Land Classification Study Aug’15. – No comments to make.

Retail Addendum Note Sept’15. - We note the lack of ambition as already articulated.

Design and Access Statement Oct’15 –

GPC notes the discrepancy between concept maps, that indicate green corridors that link the ancient woodlands and the wider countryside, and the reality of what is planned or actually exists on for example Pg24: roads with space for parking within the 3m wide surrounds and a few trees (presumably standard saplings) planted on sometimes both sides of the road. Parking areas, cycle ways and paved footpaths are hardly green corridors for wildlife. It is unfortunate that the M40 acts as a barrier no matter how many green lines are drawn across the site.

We note footpaths through the ancient woodland of Gaydon Coppice and an insufficient border between it and future proposed developments. Clearly this is likely to be threatened as an ancient habitat and is very likely to be seriously degraded very quickly. This doesn’t match the green credentials.

The removal of ‘scrub’ on Pg17 probably is the greatest indication of how little the green environment is actually valued. GPC refers to them as hedgerows and in themselves act as green corridors. Retained trees with TPOs are not green corridors in isolation.

GPC notes the potential allotments on Pg20 as another green box is ticked – but credit can’t be taken for these – they are not in this part of the development.

Again concepts and plans seem incompatible with reality. We note on Page 5: ‘It is unfortunate that the existing Lighthorne Heath turns its back onto the Banbury Road (B4100). Facts on the ground don’t match but as we discover later in the ES Addendum Section 16, this is convenient when mitigating against visual impact. Site access restrictions resulting from large scale development onto an already heavily congested B4100 will result – and integration can be easily spoken about but have little chance of being achieved if reality is not matched by desire or existing layouts.

The B4100 is in reality a motorway relief road (much used recently) and a major access route from the NW for commuters who cannot realistically access the M40 by virtue of their places of residence. Such large scale development compromises further the clearly communicated economic expansion ambitions of JLR and success of AML.

The economic significance of the B4100 as a through route therefore doesn’t sit well with the illustrated concepts of close LH and GLH integration with pedestrian crossings. Reality again frustrates concept.

Responses regarding the ‘village centre’ layout:

Right from the start, there is an acknowledgement that whatever is planned is unlikely to be built. SDC will need to hold the developer to account to ensure that this does not happen here if it is to get the go ahead.

The Village Square: with a retirement home at the entrance followed by a walk to the small health centre, it becomes clear that this is not for LH. Lorries will have to access a supermarket set right into the development – a logic that GPC finds difficult to understand.

This is a poor option.

The Parade Concept: More organic in flow but not good for traffic flow. Is the lack of detail and indicator of how little this option is believed in? Access to the school is poor: a 3 form entry school will generate a huge amount of traffic at peak times as parents then head off to work – ideal for JLR?

Marginally, the preferred option.

The High Street Model: less parking close to the B4100 and parking for the school is again very poor.

GPC questions why the primary school is so close to this retail centre knowing that in reality much traffic will be generated at peak times no matter how many travel plans are adopted.

GPC again notes that no Secondary School has been included. GPC again argues that such an omission would ultimately adversely affect the social sustainability of the GLH project; as well as miss out on a golden opportunity alleviate the pressure on Southam College: with an adjustment of catchment areas. The rest of the modified CS should also be considered.

Response with regard to Parking and the Illustrative Block Layout:

The design principles are clearly laid out but where there are no viable alternatives GPC would urge planners to consider additional provision for parking if this is to be a desirable place to live. GPC notes the 5 yr Travel Plan with its lack of ambition, that results from the relative isolation of this development, and the reliance on the private car that will inevitably result from the lack of guaranteed alternatives: no rail, major centres not accessible by cycle or foot and bus provision that can’t be guaranteed over the life time of even the CS. We note that services are currently being withdrawn in the area, as Oxfordshire CC cut subsidies to buses.

Not all, if any, will work at JLR and so it is very reasonable to suggest that more than one car is very likely to be needed by couples and more than this for families with older children.

If the school and shops are to be located together, more spaces should be seriously considered.

Potentially, due to the proximity to JLR/AML some properties will be rented out to contract staff and graduate engineers; this can mean multiple occupancy; with the additional cars that come with it. These vehicles, hypothetically, would not be required for the commute, so would be ever present.

Parking for 40 DPH: provision for parking looks inadequate.

Parking for 35 DPH: Clearer layout seems apparent even if arranged as courts rather than streets. Individual houses in such arrangements are notoriously difficult to find and likely therefore to generate additional traffic movement.

Parking for 30/20 DPH: No problems with parking area immediately apparent as the potential to park on and in garden spaces.

Parking for 25 DPH: Parking clearly catered for but more reference to the clearance of scrub and the inevitable consequences on wild life and green credentials.

We note that the references to green credentials and preserving wildlife as in the SPD seem to have largely disappeared.

The Sports Pavilion: GPC again questions its accessibility. It is also not clear who would manage this or maintain it. Though GPC welcomes such provision of badminton, bowling and playing pitches, the above issues need addressing.

There is a lot of talk about communication and about sustainability. It is clear the agency MADE has been taken note of but, the Design and Access Statement is not a document that has inspired GPC with confidence that even these stated aspects will be developed and become reality. Too often concepts seem to an exaggeration of the planned reality. Such details such as governance don’t even get a mention.

Response to ES Addendum Vol 1 and 2 Oct’15.

Sections 2 – 5 (3.1 – 6.1) – No changes – see previous comments

Section 7

(7.2) It is clear to GPC that this remains a developer initiated and lead plan that has been embraced by SDC.

(7.3) The working partnership between SDC and the developers is clearly close. WCC needs to be a critical friend to this arrangement to ensure that the true costs of this development at GLH are properly assessed and that resulting infrastructure costs are borne by the developer and not WCC in the long term.

Section 8

GPC accepts that in the event of development, other sites for retail expansion are not the priority. Indeed GPC believes that there seems to be a fundamental lack of ambition to even cater for existing communities let alone minimise the need for all residents to go further afield for all but everyday essentials.

Section 9 (Transport, Accessibility and Movement)

(9.1) Executive Summary:

We note that there is no acknowledgement of any local concerns or suggestions. This has been from the start the main concern of GPC.

It seems incredulous to read in the summary that 3000 houses and a massive development of the 100ha will lead to no major impact on an area that already has major traffic delay at peak times due to the success of JLR. GPC would remind the developers that improvements to J12 were not planned for their benefit but for the safety and wellbeing of employees of JLR up to a capacity of 12650. Currently JLR employs over 10000 and has significant ambitions for development of the current site without taking into account the 100ha. GPC believes that it is short sighted for SDC to believe such summary assessments and risk an economic impact on an industry that it so treasures.

We note that modelling seems to miss out Gaydon and the increase of housing that has been applied for or is currently in the pipeline. We note that other developments including the 90 for Temple Herdewyke, the 500 extra in Southam (as proposed in the emerging CS), the extras that are being pushed for in Bishops Itchington and the general 8% growth in other service villages are also conveniently absent.

We note that in the absence of a secondary school being included in the development, resulting traffic at peak times is not reflected or taken account of in the modelling.

And yet, we note that we can apply for traffic calming: ‘The aspiration in policy … of the emerging Local plan is to secure traffic management measures in the expanded and existing villages (for instance Gaydon) … are also capable of being supported through the application proposals.

It would appear that on one hand there is no assessed impact and on the other an acknowledgement that there are legitimate concerns.

Within this summary, GPC notes again, as previously, that this development does not meet all transport needs as stated: all accesses going to the B4100 clearly demonstrates this. Much is made of sustainable Park and Ride Schemes but there are no guarantees as noted by the withdrawal of bus services to Banbury as Oxfordshire CC cuts funding.

Comments with regard to specific reports within the ES Addendum.

1.2 Scope agreed with WCC but not including all CS commitments – very selective at the start – no 100ha, no additional 1000 houses.

2.3 Plenty of talk about improving links to the development – where are the links with no road bridge over the motorway from GLH?

2.4 ‘Interesting rooflines’? The photographic images and models look very flat. This whole section is filled with flowery language unnecessarily used to sell this project. There is an unpalatable exaggeration of benefits as developers try to sell – including those green benefits.

2.6 Double accounting seems to be a feature – a roundabout to the North and allotments – but this is not for the 2000 houses but for the additional 1000. It would seem a good idea if this was to have been the start of a bypass of the development so as to direct traffic off the B4100 but sadly this is not the plan – just for another access road.

2.7 The claims are ridiculous. GPC urges that bus traffic be taken into account and the additional use of the private car resulting from the need for secondary provision whether on or off the site.

2.9 Poorly written and not able to resolve the fact that traffic will be still congested by turning to both the right and the left on to the B4100. As this is the only main road in the current plans, this will affect both new GLH residents and those of Lighthorne Heath.

2.13 Buses referred to are not sustainable without massive grants (and not guaranteed as already stated and illustrated) and so this whole development is wholly reliant on the private car. This contravenes NPPF Para 32 that opportunities for sustainable transport modes have to be taken up depending on the nature and location of the site. In the absence of alternative sustainable transport options being effectively planned for this isolated development area, there will need to be major investment in the infrastructure. GPC believes that it is short sighted not to recognise this at this relatively early stage when securing a funded blue print. It will be too late later when the houses are already built and WCC ends up footing the bill.

GPC believes that anything less is not sustainable or conducive to building an attractive asset to South Warwickshire and that it will unacceptably impact a prestigious major employer. GPC believes that a bypass or at the minimum an alternative access point needs to be built across the M40 to stop reliance on the B4100 alone.

3.3 Para 35 may well be part of the planned onsite/local structure but the site is too isolated for this to suggest that it will have serious links further afield.

3.5 Para 37 talks about minimising journey lengths for education: this can only be achieved with on-site secondary provision. Anything less will generate 4 to 5 forms of entry that will need transporting: lots of cars and buses heading through Gaydon towards gridlock in the narrow roads of Kineton. This is more free transport for WCC to fund in a time when they are doing everything to cut costs.

3.7 The words would have GPC believe that carbon emissions are to be reduced when the reality is that the Travel plan is low on ambition and impossible to implement where there is no hard evidence of sustainable traffic provision being figured into the hard infrastructure. The Travel Plan cannot mitigate against the overall environmental impact of GLH. To make it sound as if it will, further compromises the trust in this environmental assessment.

3.20 GPC believes that with the selective use of statistics, anything can be proved. WCC needs to accept that theoretical modelling and best case scenarios are not a sound basis for measuring the capacity. The extra capacity of infrastructure that is needed with the development of GLH needs to be planned for now as reassessments towards the end of the CS are too late. What is assessed as OK for developers is not OK for GPC and shouldn’t be for SDC or WCC.

3.36 There seems to be a huge discrepancy (even at this early stage) in the vision for a green infrastructure with no links now evident between the ancient woodlands and the plans. This equates to further evidence of a total lack of ambition. GPC notes that the green network seems to predominantly consist of roads with trees planted between parking bays.

3.37 The assessment statements points out that: ‘The new community will integrate and embrace existing housing at Lighthorne Heath’: fine words. However GPC would like to also point out that in the Design and Access Statement it helpfully states, “It is unfortunate that the existing Lighthorne Heath turns its back to the Banbury road” (B4100). This is another case of an assessment not reflecting the actual reality.

3.38 Such JLR proposals on such a landmass are likely to generate many more thousands of cars at peak times and seem not to be fully factored in at 3.20. We also note that these may be open to the public – surely more journeys being generated. GPC believes that this potential growth needs to be fully reflected in assessments if they are to be believable and the basis to plan for new infrastructure.

GPC maintains that a new secondary school is needed to both minimise journeys and maximise the potential for social sustainability.

3.46 It is noted that: “The rural setting of Gaydon will be preserved by the provision of an enhanced area of open space to its North with connectivity.” Already in reality the rural setting has been compromised by the excessive lighting of the new road and the mitigating ‘green triangle’ of land, which County Cllr. Chris Williams was unable to guarantee the preservation of, stating that it was to be sold back to the original landowner. No covenants were mentioned then or in this assessment. We also note that JLR has purchased a significant amount of land south of their site.

GPC has no confidence that this statement holds any water and suspects that this is nothing more than just a pleasant sounding acknowledgement of the actual impact on Gaydon as a rural village.

3.48 GPC wishes to state that there is no direct access or connection to the current secondary school provision.

3.53 & 5.34 The new road was not built for the proposed GLH development but to relieve the congestion and assessed dangers currently experienced up to a capacity of 12650 employees.

The B4100 connection to the North West toward the Harwood’s House Roundabout with the Fosse way needs significant works and widening to relieve current capacity issues, let alone the undoubted impact of a further 3000 houses and large scale expansion of JLR and AML. Any casual observer or commuter is well aware of the current issues and so assessments are clearly inaccurate – theoretical capacity and reality are again clearly not reflected in the assessed conclusions. The B4100/A452 towards Warwick/Leamington Spa should also be given more priority.

GPC also has proposed the need for relief of the B4100 from the development with a crossing over the M40 and thereby opening up access to and from the development to the East.

4.2 Gaydon is not part of the Kineton Ward: its current ward is not reflected in the modelling and assessments and should be.

GPC does however note that 1.2% go by train – as the train station in Kineton has been closed for some time, it suggests that this must equate to another addition to those travelling by car as they travel to stations much further afield. With just 4.2% sharing journeys, the 10% improvement suggested by the Travel Plan is put into perspective – a 0.42% reduction of current figures! Even with this reduction, 75% will be travelling on a daily basis by car in Kineton ward with a reasonably sized village centre with real services including a secondary school. Gaydon’s current ward has none of these!

4.3 If this statement is to be included as a valid assessment, proof needs to be given: houses currently on the market in Gaydon are not immediately snapped up by employees of JLR/AML.

4.12 GPC restates the fact that the ongoing road improvements from J12 are to ensure the health and safety and economic viability of JLR and AML.

4.14 Not all JLR/AML employees are in a position to use the M40 and J12 anyway – especially those living to the Southwest of the site and those living in the Rugby, Leamington and Southam areas. This statement is based on the testament of employees to the Chair of GPC in his own work capacity.

4.20 Buses cannot be relied on as cuts are already announced in services as already outlined in the past few weeks. Such data for assessment purposes will give a far rosier picture than the reality actually is.

4.21 & 5.33 Kineton struggles to accommodate the 16 buses that are currently used to ferry secondary pupils in this rural setting – another 9 or 10 of them is simply not a realistic proposition when GLH generates 4 to 5 extra forms of entry. A new on site secondary school is required.

4.22 With no rail station being included into the plans or any others in the locality – any assessments will need to count them as car traffic to add any sense of realism.

5.10 It seems that gateway features are considered good for slowing the already congested situation on the B4100. GPC would like to draw attention to the fact that such moves by GPC to have them on the entry points of Gaydon have not been warmly embraced by Cllr. Chris Williams at the most recent Parish Council meeting.

5.30 GPC disputes this and has said right from the start that a new school is needed for the reasons stated. Additional benefits, with a strategic review of catchment areas, include the relief of the currently oversubscribed Southam College especially knowing that Southam features heavily in the emerging CS. WCC, through Nigel Minns, has acknowledged that a new school is needed in the South of the County.

A brand new settlement is highly likely to attract younger families if the examples of other new towns are to be recognised such as Stevenage in its time: all the more reason to reassess the impact of development of GLH.

5.38 Welcomed by GPC.

6.5 This comprehensively illustrates that walking and cycling are non-starters beyond the extent of the GLH development with the exception of Lighthorne Heath itself. GLH is not well connected to either Kineton or Bishops Itchington, let alone a major town. It is not even that well connected to Gaydon simply because of distance in terms of walking or cycling for provisions. It is not realistically close enough for the primary school children to walk or cycle – even with adventurous parents.

The site is simply not geographically well connected: restricted by the M40 on one side and JLR and AML on the other: fine words again but cannot be assessed as being based on reality.

6.8 GPC would point out that there must be serious health and safety concerns for those who might be encouraged to cycle from Temple Herdewyke to GLH and back again: the road is a 60mph route.

6.10 Gaydon has just one pub with the other being turned to residential use with a further 17 properties being included. Assessments need to be based on accurate information if they are to be believed.

6.13 This section illustrates the isolation of the site and the need for car usage for major leisure (including swimming), recreation and shopping. Sustainability is again questioned.

6.16 – 6.19 It is incredulous to suggest in this assessment that mitigating measures for the 3000 houses will reduce traffic. GPC consistently has argued that as there are no realistic alternatives to the private car, that there will be an impact on levels of traffic and that the traffic that is generated along the B4100 will have an economic impact on the industries that adopted this location to avoid being hemmed in.

6.21 – 6.22 Any assessments need to recognise the real risks of social exclusion on a site that is poorly connected and surrounded by motorway, industry and green desert. Over compensation when trying to build a new community needs to be acknowledged. It is not building an integrated development: even Lighthorne Heath “turns its back on it.”

Saying something is integrated doesn’t make it happen.

6.27 The assessment of rail links is of no relevance as far as this development is concerned: there are no links to assess that are being planned for GLH.

7.0 – 7.14 This amounts to no more than a statement of intent with a marginal impact on the inevitable growth of traffic that this development will spawn. Even if it were to be believed, it seems that it is only to last 5 years anyway! All assessments need to dismiss any reference to this plan: a plan that is in itself not sustainable.

8.4 GPC notes that some local roads are included in this section but again notes that others are not including the rather busy single track roads such as Knightcote Bottoms, and Pimple Lane from Gaydon to Northend.

8.10 JLR is growing on an annual basis – something that SDC amongst others are keen to promote. The impact of growth into the extra 100ha as identified in the emerging CS need to be taken into account. As JLR has not been willing to say what it intends to do with land it would seem eminently sensible to plan for the worst case scenario when planning the sustainability of GLH, the surrounding area, and its infrastructure.

8.21 Is it really assumed that such a high proportion will work at JLR/AML or within the local services? GPC believes that it is not wise to assume anything.

8.24 Again there seems to be a reliance on an assumption that all children will go to the new school. From the professional experience of the chair of GPC, parental choice is well exercised in South Warwickshire. Children from Gaydon currently and historically have gone to a full range of schools and not always to the official catchment school. Schools are big generators of traffic.

8.28 & 8.40 This is another case of selective use of figures – all planned growth as identified in the emerging CS plan need to be taken into account from the start and ensure that the whole period of the CS is included. Already in this area there are proposed developments that will take numbers of houses beyond the 8% figure for service villages: including Bishops Itchington, Gaydon and Temple Herdewyke.

8.51 A 5% reduction because of this much promoted Travel Plan and the conversion of so many commuters and pupils to take up cycling along busy, narrow country lanes.

9.0 – 9.16 When comparing figures for 2000 houses and the later models it would appear that there is a negligible impact of building a further 1000 houses and developing 100ha by JLR. It is a wonder that existing communities are not fighting for this development to be included in their own parish plans!

These figures are simply unbelievable for an area that is already known for its traffic congestion from all directions.

10.5 An acknowledgement that there is some impact on local roads: as roads are currently congested or unproven in peak times this must be viewed as a big negative especially as with the further expansion of JLR there will not be capacity of even improved roads. (The new road already caters for over 10000 employees – not including those of AML – and has a design capacity of 12650.)

10.8 Assessments need to be based on all data – GPC notes that the proposed expansion of Wellesbourne is not included.

Roads may have certain theoretical capacities but do the junctions? It seems very short-sighted to base decisions on theories when the rest of the world operates in a reality of mixed weather conditions, accidents, break downs and slow moving tractors. If in theory roads are hitting 80 – 90% capacity in this idealised world, where all development is not taken into account, GPC would argue that alternative routes need to be included

10.10 – 10.11 GPC does not think that these assessments are realistic and that alternatives as suggested already should be included into the calculations at this early stage. Without them there will be a severe risk of congestion and delay and a cost to WCC in years to come. Developers are clearly going to skew data that claims that investment in infrastructure is not needed: WCC is too afraid to acknowledge this.

11.1 Again limited data. District Cllr Chris Kettle has already requested a full South Warwickshire Traffic Review (GPC Nov’15 mins)

11.5 – 11.7 It needs to be acknowledged that cars queue (and have done for some time now) on the B4100 from Banbury and the Kineton Road through Gaydon on route to JLR and Leamington/Warwick.

11.8 GPC is requesting a survey of roads through Gaydon (especially the Kineton and Church Road) – it seems to have been missed out in this assessment.

11.10 The Harwood House Junction has already been raised as has that on the B4100. Traffic emanating from GLH will need to cross the flow of traffic moving South (or add to it). An alternative route to the East needs serious consideration.

11.11 Employment land is part of the emerging CS and so needs including at this stage of the assessment and not later: joined up thinking as opposed to piecemeal needs to be adopted.

With regard to employment land consistency needs to be applied when assessments are being carried out. GPC points out the following taken from the ‘Examination in public’ 15^th Jan ’15 with regard to Industrial Development in Redditch: ‘A B road is not part of the strategic network.’ On these grounds such development couldn’t go ahead. GPC would argue that a reclassification of the B4100 is therefore required with associated improvements as part of the strategic assessment and review before any remaining elements of the CS are adopted – including GLH.

11.13 GPC believes that there will be an impact that does need addressing contrary to 11.14 especially as the whole picture has not been factored in.

12.0 GPC questions whether the figures include the planned growth and other developments consistent with the 8% minimum growth.

12.4 & 12.8 GPC detects confusion between Lighthorne and Lighthorne Heath.

12.10 Where does the data come from as the project is not yet completed – another theoretical extrapolation?

12.11 Secondary School traffic is clearly not included into this model. If provision is to be directed to Kineton, 4 to 5 forms worth of pupils will generate significant traffic during the morning peak hours. It is noted that the survey fails to include peak traffic from 7-8am: the Chair of GPC has to now leave Gaydon before 7am to avoid lengthy queues to cross the motorway.

There is acknowledgement that 8-9 vehicle extra per minute will be generated – 480 to 540 per hour. On top of current congestion this must surely count as a major detrimental impact by anyone’s assessment especially when the 100ha of employment land, the 8% growth of service villages and 1000 additional houses are factored in.

12.12 This should include an assessment of the Kineton Road in Gaydon as requested in the Traffic Regulation Order Response of Oct’15.

12.14 -12.15 The ‘slight increase’ in Kineton doesn’t seem to get reflected on the Kineton Road in Gaydon: strange as this is the same road! Is the assessment perhaps of the Stratford Road?

Though it is accepted that some of the traffic will move in the opposite direction to that of JLR and AML at peak times it must be equally accepted that the section of B4100 through Lighthorne Heath will be severely impacted as much traffic will want to cross this road or as they travel south towards the M40 and J12. An alternative access road to the M40 and the South is therefore very much required. Again GPC argues for an access point from GLH over the M40.

12.21 Need to take into account the current and planned expansion of towns and surrounding villages.

13.0 Refinement Model Test –

13.3 An acknowledgement that there may be more houses in the future.

13.11 Actually 40mph – model is again proven as being inaccurate.

13.17 The Kineton Road no longer seems to feature.

13.19 Is this really a suggestion that it is beneficial to have 3000 houses and extra employment in terms of traffic being potentially reduced, a suggestion that there will be a big impact but not as bad as it could be or simply a problem with the modelling?

13.22 Impacts are unknown: another assumption based on theoretical modelling and unproven in reality.

13.24 This suggests that improvements are to be required.

13.25 Growth of employment will have an impact as has been seen with the growth of JLR in recent years. JLR has adopted this site to avoid being restricted – the very thing threatened by GLH. Assumptions that there won’t be an impact should be quickly disregarded: JLR ambitions should not be disregarded.

13.26 This is quite simply wrong – especially if JLR is to expand.

13.27 and 13.29 This ignores west bound traffic on the B4451/Kineton Road. GPC has also in the past suggested a bypass for Gaydon in the medium to long term if all aspects of the emerging CS are implemented.

13.28 and 13.30 Acknowledges more traffic but not the additional congestion – that already exists – poor assessments.

13.32 London and Birmingham commuters are ignored in this modelling. Note that numbers of residents of local villages currently do this commute. GPC argues that it is likely that at least some future residents will be drawn here and then commute to these main centres. They need to be factored in.

13.36 Anyone who travels to J9 on the M40 will be fully aware of the congestion at this junction and Bicester is still rapidly expanding: more evidence of a flawed model.

D15001

Acknowledges heavy use of B4100 northbound – and yet no impact on Harwood’s?!

Acknowledges traffic to Southam along the unimproved B4451 and therefore justifies an additional M40 crossing to relieve the B4100 southbound.

Acknowledges the impact on the B4100 – this can be mitigated against as illustrated.

Further Refinements

The reviews as being proposed in 2020 and 2031 are too late then. SDC and WCC needs to assume worst case scenarios and insist on mitigating measures at this early stage before land is built on, before permissions are granted and promises of finances evaporate and before problems arise. It is after all more cost effective and less disruptive to build new infrastructure at the start than remodel and expand infrastructure that is creaking.

6.0 There is in this model some acknowledgement of local building but Gaydon is likely to exceed its 8% planned expansion with at least 46 houses built or in the pipeline. There is a substantial development at Temple Herdewyke being planned and other developments for Kineton on top of those. The impacts of development in Warwick, Leamington, Bishops Itchington, Harbury and Southam need to be fully included too.

7.1 / 7.2 The 2001 census is out of date.

8.1 / 8.2 Had the employment land been of a more diverse nature as in the original CS, it might have been reasonable to suggest 9% would work in the vicinity. It is not though and so modelling based on this presumption is dangerous as are the assumptions that people will shop and conduct personal business locally. It may help with the figures but the lack of retail and services diversity in this remote site suggests that many more journeys will be generated – the modelling is again found to be inadequate.

8.9 / 8.10 The 659 secondary school aged children will generate a combination of car and bus traffic – all direct as previously described and not mitigated for. The figures for walking and cycling quite unbelievable unless provision is to be now included on site. The assessment appears to have identified an alternative mode of transport: GPC are intrigued to know what ‘other’ might actually mean?

9.1 It is never safe to assume that all children will attend on site provision or that it might not attract from off site. This is not taken into account in traffic assessments – at peak times!

11.1 Is this really a suggestion that the current disruption being caused by the new link road is to be looked forward to again in the future with localised widening of the B4100 and a further re-designing of J12?

Again GPC reiterates its belief that assessments that look for minimum impact are fundamentally flawed and will prove costly to WCC in the long run. Surely if a developer is so keen to develop it should ultimately factor in all the costs from the start.

Section 10 – Not changed but perhaps should be amended to reflect inaccurate figures supplied by car manufacturers. A long term, independent air quality study is required.

Section 11 – Noise. It is noted that noise is still above 55db for parts of the development. Acknowledged that along the B4100 and M40, noise is still above what may be described as desirable even if within the limits.

Section 12 - Flooding.

3.51 Anecdotal evidence – or actual?

4.82 Frequency of maintenance needs to be applied to all – proposed and existing communities. This needs to be covenanted or legislated for to guarantee.

5.3 GPC believes that the Lighthorne sewage works are actually Lighthorne Heath.

Section 13 – Ground Conditions – unchanged.

Section 14 – Built Heritage Statement – no GPC comment: except to say that that no account is taken of the Grade 2 Beacon Tower on the Burton Dassett Hills.

It also seems a shame not to celebrate a last fragment of RAF Gaydon in 4.13. Most developments like to celebrate remaining historical fragments and make something of it.

Section 15 – Ecology.

1.1.4 Over exaggerated claims with regard to green corridor credentials and retaining greenery/hedges. The Design and Access Statement seemed keen to remove scrub.

Section 16 – Landscape and Visual Impact

No reference to The Beacon Tower (Grade 2)

No references to the light pollution.

Conclusion

GPC finds much of this assessment to be lacking credibility as it consistently plays down and underestimates the impact of GLH in its entirety by not including all aspects. Too often the rhetoric and sales come up against uncomfortable realities. What is deemed as insignificant by Brookbanks is not shared by GPC: expressing traffic data (for example) by the minute doesn’t make the problem smaller.

GPC maintains that the very sustainability of GLH is put at risk by the lack of ambition in the services that it anticipates and in the minimal transport infrastructure improvements that are proposed. This is because it wholly relies on the link road built to improve the safety of JLR employees and the economic efficiency of this national asset.

GPC has made clear suggestions on how impacts with regard to transport and social sustainability may be mitigated.