Urgent – Please object to this planning application next to Bunsons Wood in Keresley by Sunday evening 8 May 2022. Bullet points below.
between Fivefield Road and Bennetts Road
send your response to
Planning@coventry.gov.uk and email@example.com
On the website, the council show Saturday as the deadline but they have confirmed they will accept comments received up to Monday morning first thing.
Some suggestions below
Objection to OUT/2022/0712 –
Homes between Bennetts Rd and Fivefield Rd, Richborough Estates
I wish to object to this development on the following grounds
- There is grave doubt about the population forecasts for Coventry, and any need for this housing. On the precautionary principle it would be reckless to make decisions now, on bad data, ahead of the census, which will very shortly resolve the matter.
- The Ancient Woodlands are insufficiently protected. A 30m buffer is inadequate. The Woodland Trust recommends at least 50m and preferably 100m. A narrow buffer will enable fly tipping, littering, and cats and dogs disturbing wildlife.
- the Transport modelling systematically underestimates future traffic. Major sources of traffic growth are omitted. Local junctions are currently over capacity and likely to get worse even with mitigation, if the true scale of traffic growth is assessed.
- [your own personal reasons – how important open countryside is to you for recreation, exercise, your dog, mental health, historic setting of Coventry, the last best unspoiled piece of Warwickshire Ancient Arden landscape (CCC’s own words in 1995).
Lack of need: The Precautionary Principle
There is abundant evidence that the population forecasts for Coventry are wrong. On the Precautionary Principle, which is law in the UK under the Aarhus convention, it would be reckless to make planning decisions on the basis of highly questionable figures, when authoritative data from the latest census, will be published in just a month or two – ONS have promised results by “early summer”.
The sole reason which the inspector gave for removing land from greenbelt was alleged exceptional population growth. Coventry Council is well aware of expert evidence, previously submitted, that the claimed extraordinary growth has not happened. As such, there is no reason for building unneeded homes on land which Coventry Council described as the bests remaining piece of unspoiled landscape in Warwickshire (in the 1995 Coventry Arden Design Guidelines, which remain in effect).
In May 2021 a lengthy investigation from the Office of Statistics Regulation (the official regulator of government statistics) cast considerable doubt over the ONS population forecasts for Coventry, finding “the population estimates for some cities such as Coventry, did seem to be inconsistent with, and potentially higher than, local evidence would suggest. This also appeared to be the case in a number of smaller cities with large student populations.”
Coventry Council responded, in May 2021 that the findings were “not definitive”. While the findings did not give a precise number for the current population of Coventry, this does not remove the regulator’s strong doubts about the improbability of the existing ONS population figures. They wrote “it is disappointing to hear that our findings are not being considered sufficiently within the council discussions. While it may not feel like it, I would echo Ed’s sentiment that our report was one of our more hard hitting pieces…… we are convinced that there is an issue with Coventry’s figures and that local sources of data are clearly inconsistent with the ONS figures” – email of Elise Baseley, Statistics Regulator, OSR, 2 June 2021
The regulators first draft of their report, obtained through FOI, was even stronger – “fixes have not done enough to address the overestimation of these groups in some areas. This has led to an over reliance on insufficiently robust data to inform local planning decisions such as the need to build additional schools and housing.”
- The plans call for Fivefield Road to be blocked, but no detail is given on where this will occur, nor the mechanism for the closure. Residents who rely on this popular rural connection, should be given the opportunity to comment on the full details of the matter before reserved matters are considered.
- The Traffic modelling systematically underestimates future traffic
- Traffic on the Tamworth Road and Bennetts Road is already bad, with long queues in the mornings. The cumulative effect of the SUE, including this development, will make it worse. Even with mitigation, the Hub study still shows traffic over 100% capacity at some junctions.
- The baseline Automatic Traffic Counts in the HUB study for this development (the latest iteration of the traffic modelling ) were done in June July 2021, when traffic was suppressed by covid and people working from home – around 10% below previous levels1. If the baseline is too low, then all future forecasts of growth, using Tempro and NTEM, will also be too low. The traffic modelling needs to be redone, with traffic counts from a normal time.
- The modelling failed to include major sources of traffic:
- the new HS2 station, which will have 7,500 parking spaces, 100,000 new jobs, and 4,000 new homes – in 2014, Coventry Council complained in a petition to Parliament about the damaging effect of HS2 traffic on Coventry roads2.
- Passenger growth at the airport – forecast to more than double, from 11m/year to 27m/yr. DfT TAG M4 guidance on traffic modelling requires airports to be included in the modelling, in addition to the use of NTEM and TEMPRO.
“Adjusting NTEM data to take account of surface transport for air passengers”
7.3.9 “Surface travel demand for airports should be considered for all schemes, but where there is no major airport within or near to the study area, it may be sufficient to assume that such travel is minimal and make a case to the Department for not analysing it explicitly.”3
- A new corridor from the A45 to the M6.
Highways England anticipated that the Keresley link road could open up a whole new traffic profile
“In summary, Highways England has recommended that consideration should be given to other planned growth including Local Plan allocated development (with the Eastern Green SUE being the most prominent), as well as the inclusion of the proposed Keresley SUE Link Road. The introduction of this would provide a new corridor for traffic to the west of the city and could potentially affect the strategic traffic profile for the whole of Coventry.”
The traffic impacts need to be re-evaluated. The traffic studies use invalid and misleading standards:, the 1993 IEMA guidance. Relying on it, the studies ignore impacts less than 30% . This is misleading. The report itself states that this rule is not applicable to matters of highways “capacity” or “operation”. Current guidance in both Northern Ireland and Scotland states that a 5% impact is significant and on busy roads, even a 1% change can be significant.
“3.18. It should be noted that the Department of Environment suggests in Planning Policy Note 13 (DOE 1988) that increases of traffic of 5% are likely to be considered as significant by the Dept of Transport. The context of such a statement relates to the operational and capacity criteria of a highway and not its environmental impacts. It is suggested that the criteria set out in these paragraphs are more relevant to assessment of the environmental impacts and hence the higher thresholds are more relevant” [from the 1993 IEMA guidance]
It is not assured that the Keresley Link Road will ever be built in full. Highways England has expressed doubts. “the purpose of the additional modelling is to ensure that, from an SRN perspective, we are not committing to a position that relies upon on a final stage of a Link Road scheme that may not come forward but had been demonstrated to be necessary in traffic terms.”4
If this came to pass, traffic skirting the north west of Coventry, could end up rat running through the streets of Keresley and Holbrooks to get to Junction 3, M6
Forecast Traffic at the junction of Exhall Rd and Bennetts Rd, without mitigation – way over capacity
from the HUB Transport Assessment for OUT/2022/0712 Richborough Estates.
Traffic Forecast, Bennetts Rd Exhall Rd [J2], with mitigation – still over 100%, with no spare capacity, More than 0.85 ratio of flow to capacity (RFC) is considered undesirable by traffic engineers. Coventry Council, in their Connecting Coventry paper of 2017, point to the chaos on Coventry Roads caused by regular closures of the M6 – having recognised such events, there is a mandatory need for reserve capacity on the roads, not to run them at 100% of normal capacity.
Provide greater resilience to the motorway and trunk road network: when problems occur on the M6 the A45 and other routes around Coventry are frequently brought to a standstill and this undermines the attraction of the city as a place in which to invest;. [from Connecting Coventry Jan 2017]
The TA did not consider large new developments at Hospital Lane and School Lane which are likely to feed traffic into Exhall Rd, especially if the Keresley Link Rd is not completed as far as Prologis Park. In so far as the TA systematically underestimates future traffic, the future situation is very likely to be worse than forecast even with mitigation.
3 TAG UNIT M4 Forecasting and Uncertainty May 2019
4 Highways England to CCC 4 Jul 2019 [our doc 20]