Objection 7: Strategic Transport Assessment is Invalid in respect of Lodge Farm
VECTOS was commissioned by Rugby Borough Council/Warwickshire County Council to provide a statutory Strategic Transport Assesment to support the Local Plan and also the inclusion of Lodge Farm Village (DS10) proposal. This assesment is insufficient, invalid, and limited. As such the Lodge Farm sustainability assesment is invalid, the proposal cannot be said to be sustainable, and the Local Plan is unsound.
The reasons are below:
- The STM traffic model developed by VECTOS does not properly include Lodge Farm and does not consider impacts at Daventry and along the A45 through Flore Hill to the south, where traffic is already known to cause issues. This is not an acceptable approach, given the scale and proximity of the site to Daventry. As a result, the model is not fit for purpose as it currently stands.
- The trip-end data used to support the trip distribution for Lodge Farm is invalid and is based on 2011 Census data that is already at significant variance with the situation on the ground. The model outputs, such as they are, are unreliable and cannot be used to assess the impacts of the site with any degree of confidence.
- Due to time constraints imposed on VECTOS by RBC, the Lodge Farm site is included only as an afterthought in their appraisal, by way of a limited Sensitivity Test. This is not appropriate for such a major allocation and the model should have been extended, re-calibrated and then the entire Local Plan analysis re-run to determine cumulative impacts across the whole of the network.
- The Duncurch Crossroads represents a serious impediment to development to the south of Rugby and this is fully recognised by VECTOS, who advises that any increase in traffic at this location would be ‘highly undesirable’. Given they also acknowledge that ‘there is limited capacity in this area to provide additional improvements’ their ‘recommended approach is to complete the A45/M45 to A426 section of the South West Link Road (SWLR) ‘at the earliest possible opportunity’ and in the interim, locate housing away from the south-west of the district altogether.
- The recommended VECTOS approach has not been followed by RBC, who instead seek to promote the delivery of Lodge Farm at an earlier date, through it would appear an interim improvement of the Dunchurch Crossroads. This interim improvement has not been identified, modelled, costed or its impacts on the existing Listed Buildings, Statues and Monuments assessed, which are all major omissions for what is a significant allocation within the Local Plan. Moreover, the severe consequences of routing additional traffic through an area with existing and severe Air Quality issues have not been considered.
Objection 6: Impact on housing market and delivery of land supply
Impact on housing market and delivery of land supply
Rugby Council are proposing 12,700 homes to the south west or south east of the town – can this sub-housing market area cope with this significant level of housing over the next 20 years? No evidence exists in the Local Plan that this issue has been thought of or impact assessed. It is clear from the housing trajectory that the sites are slow at delivering housing due to a lack in demand. (example Rugby Mast site only has 3 developers and is assessed to deliver much less than it's 6000 home capacity over the plan period.)
Housing numbers in the Plan increasing from 558 in 2017-18 to 1,314 & 1,122 in 2020-21 & 2021-22 respectively. All reliant on the SW Rugby SUE coming forward. The Housing Background Paper calls this target ‘aspirational’.
If these homes aren’t delivered the Borough will not have a 5 year supply of housing within at least the first 5 years of the Plan.
Objection 4: The Sustainability Assessment for DS10 Lodge Farm Village lacks evidence and was built after the decision was made
The Sustainability Assessment for DS10 Lodge Farm Village lacks evidence and was built after the decision was made
The NPPF requires the evidence base and sustainability assessment of the sites to be available as part of the Council’s decision making process.
Lodge Farm was substituted for Walsgrave in the beginning part of 2016, when at the time no sustainability appraisal was available.
Delivering a sustainability appraisal, after making the decision to include Lodge Farm as a preferred option, begs the question as to whether the evidence was made to fit the decision, especially when so much of the evidence base is missing:
1. lack of information on ecology
2. Lack of evidence on highways deliverability
3. No conclusive transport assessment
4. No phase 1 ecology assessment
5. No utilities assessment e.g. sewer capacity/treatment
6. No landscape assessment
7. No detail on heritage or archaeology information
8. No site investigation information
9. No agricultural land classification report
10. No flood risk assessment
11. Lack of evolved master plan/development framework
Objection 5: DS10 Lodge Farm Village is not a suitable location
DS10 Lodge Farm Village is not a suitable location
Fundamentally it is in an unsustainable location where travel will be predominantly by private car with very little public transport use. Contrary to the principles of a ‘garden village’;
The site is remote with no relationship to the Rugby or Coventry main urban areas;
In terms of landscape character, due to the flat nature of the site the proposed development would result in a major impact on the open character of the area. The development would be unable to mitigate the impacts within the short to medium term;
The site has no previous use or merit to set it apart from other locations;
The site lacks definition, and would be open to infill and expansion.
Objection 3: The Lodge Farm Village (DS10) Proposal does not adequately meet Rugby's obligations to meet Coventry's Housing Need
The Lodge Farm Village (DS10) Proposal does not adequately meet Rugby's obligations to meet Coventry's Housing Need
RBC has committed in a MOU to deliver 2800 homes within the plan period to meet Coventry’s housing need;
Removing the Walsgrave site and introducing Lodge Farm as a direct replacement, delivering 825 homes within the plan period, 15 miles away from Coventry, and on the South Side of Rugby means the Borough will fail in it’s obligations under the MOU;
In a recent example Warwick District Council submitted their Local Plan to examination, failing to directly deal with their obligation to provide for Coventry’s overspill. As a result the examination was paused and the plan sent back to Warwick Council, causing at least 1 year delay in the adoption of the plan. As a direct result Warwick allocated green belt sites near Coventry at King’s Hill and Westwood Heath.
The local plan is unsound as it does not directly deal with the Council’s obligations under the MOU with Coventry, unless it re-allocates the Walsgrave site and removes Lodge Farm.