Secretary of State asked to call in planning applications

Transcription

1 SHAKESPEARE LINE NEWS Issued - 5 November 2018 Secretary of State asked to call in planning applications A RAIL USER GROUP that speaks up for train passengers and communities along its route between Stratford upon Avon, Birmingham and Leamington Spa has asked James Brokenshire MP, Secretary of State for Housing, Communities & Local Government to call in planning applications proposing the development of a 3,100 home Garden Village and associated Relief Road to the south west of Stratford upon Avon. The Shakespeare Line Promotion Group (SLPG) has told Secretary of State Brokenshire that the planning applications seek development at the Long Marston Airfield site without sustainable transport infrastructure and are at variance to the bid made to HM Government by the developer which was endorsed by both the Local Planning Authority (Stratford on Avon District Council) and the Local Transport Authority (Warwickshire County Council). In the letter to the Minister the Secretary of SLPG has said Garden Village status has been conferred upon the development from a submission containing elements that played a significant part. It cannot be acceptable that those same elements have subsequently and consciously been ignored and the development retains its Garden Village status. We request that you exercise your powers and call in both the applications as they contain no proposals for sustainable transport and do not reflect the submission that was presented to your department to attract Garden Village status and associated potential funding. Fraser Pithie added No alternatives, in terms of adequate transport infrastructure have been examined. Consequently, Warwickshire County Council as the Local Transport Authority stating that there is no alternative to a South Western Relief Road, that will have a dreadful impact in terms of visual intrusion and will not address transport needs, is misleading and incorrect.

2 In their objections to the planning applications SLPG refer repeatedly to the need for an Economic Impact Study (EIS) to be carried out as first step to determine if reopening a disused railway line between Honeybourne (Worcester><London Paddington Main Line) and Stratford upon Avon is financially viable. The disused line, closed in 1976 following a derailment, goes through Long Marston where some 6,000 new homes are planned to be built by 2031 and which is adjacent to the proposed so called Garden Village development. If reopened the line could provide a 50 minute direct train service between Long Marston and Birmingham and also, for the first time provide Evesham with direct rail connectivity to and from Birmingham with a journey time of around just one hour. Surveys carried out by SLPG earlier this year with rail users, communities and Stratford upon Avon Town centre businesses indicated support for an EIS from over 90% of those that responded. Notional visitor estimates have suggested that up to 20m additional annual income to the local economy could be possible with greater rail connectivity. In their objection SLPG point to contradictions on the part of Warwickshire County Council referring to the Core Strategy Statement of Common Ground between Warwickshire County Council and Cala Homes dated 16 January 2015, this confirmed that the County Council accepts the reopening of the Greenway to public transport including heavy rail, would increase the modal shift and sustainability of the LMA site. Yet, in the South Western Relief Road (SWRR) Evidence Report, 31st July 2017, SDC & WaCC, erroneously stated that:- Whilst all options to promote sustainable travel should be undertaken, the provision of heavy rail in lieu of a new road will have limited benefit to the existing operation of the highway network within Stratford-upon- Avon. This statement contradicts comments made previously by the Planning Inspector in his Final Report on SDC s Core Strategy, published in June 2016: There can be no question that the railway service would provide a sustainable alternative to the use of the private car for many residents and visitors

3 SLPG say the proposed South Western Relief Road fails to provide sustainable transport infrastructure while causing a severe loss of amenity to the local area by the deleterious effect caused by its significant visual impact. SLPG s objection to SWRR also says that the proposed road ignores comments by the Planning Inspector in his Final Report on Stratford on Avon s District Council s Core Strategy published in June 2016 and moreover contradicts the bid made to HM Government to attain Garden Village status for the Long Marston site which made at least twelve references to environmentally sustainable transport infrastructure, specifically the reinstatement of the railway between Stratford upon Avon and Honeybourne, nothing of which they say is contained within the application. On the Garden Village proposals, the rail user group are equally critical saying Development at Long Marston Airfield without sustainable transport infrastructure that is not proposed by this application is at variance to the bid for Garden Village status submitted to the Department for Communities and Local Government. We are not prepared to fall into the trap of discussing where a relief road should be situated because we do not believe the need for such a road has been demonstrated Fraser Pithie added.

4 Full copies of the objections and letter to the Secretary of State are attached with the that sent this release. ENDS. 5 November 2018 For further information please contact the Secretary of SLPG on Copies of the letter to the Secretary of State for Housing, Communities and Local Government and SLPG letters of objection submitted to the Local Planning Authority are on the following pages.

5 Shakespeare Line Promotion Group 3 November 2018 Rt Hon James Brokenshire MP Secretary of State for Housing, Communities and Local Government 2 Marsham Street LONDON SW1P 4DF (referred via Jeremy Wright QC MP) 166 Windy Arbour Kenilworth Warwickshire CV8 2BH suawoox@icloud.com Conferred Garden Village Status Long Marston, Stratford upon Avon, Warwickshire We refer you to the attached objections made in relation to two planning applications currently submitted to the Local Planning Authority, Stratford on Avon District Council. The planning applications are referenced: 18/01892/OUT Housing development Long Marston Airfield (Garden Village) 18/01883/FUL - South Western Relief Road Stratford upon Avon The applications are linked to one another as the relief road is being proposed as part of transport mitigation arising from the proposed Garden Village development. The purpose of raising this matter with you concerns the previous granting by your department of Garden Village status on proposed major housing development at Long Marston. The submission, which was jointly endorsed by Stratford on Avon District Council and Warwickshire County Council, mentioned some twelve times the potential reopening of the railway line between Stratford upon Avon and Honeybourne which could directly serve the new Garden Village development. We supported the application for Garden Village status not least because the potential for sustainable transport existed and the developer had previously offered up to 17m towards a rail reopening scheme. A status has been conferred upon the development from a submission containing elements that played a significant part. It cannot be acceptable that those same elements have subsequently and consciously been ignored and the development retains its Garden Village status. We request that you exercise your powers and call in both the applications listed above as they contain no proposals for sustainable transport and do not reflect the submission that was presented to your department to attract Garden Village status and associated potential funding. Fraser Pithie Secretary Encl.

6 Shakespeare Line Promotion Group 3 November 2018 Robert Weeks Head of Planning & Housing Stratford on Avon District Council Elizabeth House Church Street STRATFORD UPON AVON Warwickshire CV37 6HX 166 Windy Arbour Kenilworth Warwickshire CV8 2BH suawoox@icloud.com Planning Application 18/01883/FUL South Western Relief Road OBJECTION We, being the Shakespeare Line Promotion Group (SLPG), are the recognised and constituted Rail User Group for the railway routes and train services between Stratford upon Avon, Birmingham, Leamington Spa and London. The planning application 18/01883/FUL seeks permission for: Construction of a south western relief road to Stratford-upon-Avon extending between the A3400 Shipston Road near Orchard Hill Farm and the Luddington Road/B439 Evesham Road. The proposed road incorporates: a bridge structure over the River Avon and Stratford Greenway and associated viaduct approaches and embankments. We OBJECT to the above referenced planning application being: The proposed relief road fails to provide sustainable transport infrastructure while causing a severe loss of amenity to the local area by the deleterious effect caused by its significant visual impact. The proposed road ignores comments by the Planning Inspector in his Final Report on Stratford on Avon s District Council s Core Strategy published in June 2016 and moreover contradicts the bid made to HM Government to attain Garden Village status for the Long Marston site which made at least twelve references to environmentally sustainable transport infrastructure, specifically the reinstatement of the railway between Stratford upon Avon and Honeybourne, nothing of which is contained within the application. Associated with existing new development and further proposed development, as detailed in Planning Application 18/01892OUT, we believe the road will have significant deleterious effects upon the general amenity of Stratford upon Avon and the existing villages of Long Marston, Welford on Avon, Luddington, Clifford Chambers, Pebworth, Honeybourne and Mickleton. This will be compounded by a severe deterioration in the environment caused by visual intrusion arising from a SWWR and intolerable motor vehicle traffic volumes on rural road systems over a considerable radius leading to a deterioration in safety and the environment.

7 2 We cite the following grounds for this objection as follows. Planning & Policy Environment & Sustainability Technical Planning & Policy Garden Village Bid & Status The developer, Cala s Planning Statement - Long Marston Airfield Garden Village, June 2018, states: Neither the re-opening of the railway nor the transport hub are part of the development for which this outline application seeks planning permission for. The current application is not in accordance with the Cala/Stratford DC, Long Marston Airfield Garden Village Expression of Interest (EOI), 2016, which formed the basis of the Government s approval of Garden Village status in January The EOI contained twelve positive references to the benefits reinstatement of the rail link, including a private contribution of up to 17m from the developer. However, due to pressure from Warwickshire County Council, this offer has now been withdrawn with the funding reallocated towards a proposed South West Relief Road (SWRR). This amounts to a flagrant departure from the terms and proposal that were compiled and presented to HM Government when seeking Garden Village status for the Long Marston Airfield site and this development. Consequently, we will be requesting the Secretary of State to call this application, and the application for the Garden Village development, in to reconsider the granting of Garden Village status upon the Long Marston development and the associated SWWR. This application fails to deliver the sustainable and environmentally sound infrastructure required to meet existing transport requirements or service new and increased demand arising from the development of the Garden Village at Long Marston. Local Planning Authority - Stratford on Avon District Council The Core Strategy of Stratford on Avon District Council (SDC) is the planning policy document adopted by the Secretary of State for Communities and Local Government. The adopted strategy only safeguards a route for a potential SWRR.

8 3 Stratford District Council s Citizens' Panel Special Strategic Review - November 2016, Final Results, showed that reinstatement of the Rail Link to Cotswold Line, south of Stratford rail link had a score above 2, this result therefore made rail reinstatement one of the Council s priorities At the Stratford Examination in January 2015, Cala Homes stated that they were prepared to provide 17m towards reinstatement of the Stratford-Honeybourne railway as well as 450,000 towards a GRIP 4 business case study. At the Examination, January 2016, it was confirmed that their 17m rail contribution, was included in the draft S106, Heads of Terms Agreement. This is no longer included or forms part of the application. In his final report the Planning Inspector stated: it is acknowledged that the Promoter of LMA sees the reinstatement of the railway as a positive benefit for its scheme, its offer to fund the GRIP 4 study should be embraced as a positive step forward towards reinstatement. Despite the comments from the Planning Inspector and the subsequent indication of priority from the Citizens Panel the Local Planning Authority and Local Transport Authority have remained indifferent to investigating and evaluating the alternative that could be provided by reopening the railway line. This is demonstrated by the decision and failure to include provision, suggested by the Planning Inspector in his Final Report on SDC s Core Strategy, that the offer of private funding be included by appropriate reference in the Infrastructure Delivery Plan that underpins the Core Strategy. Local Transport Authority Warwickshire County Council In Policy PTPR4 of its Local Transport Plan, Warwickshire County Council state; The County Council will consider supporting a proposal for reopening the line if it is promoted by the DfT, the rail industry or a third party provided the local benefits outweigh any local environmental disbenefits. Discussions with Cala Homes in 2014, confirmed that their transport priority for the Long Marston Airfield development, was a 53m contribution towards reinstatement of the railway, in view on the strong connectivity with Birmingham, with smaller highway interventions.

9 4 The Core Strategy Statement of Common Ground between Warwickshire County Council (WaCC) and Cala Homes dated 16 January 2015, confirmed that the County Council accepts the reopening of the Greenway to public transport including heavy rail, would increase the modal shift and sustainability of the LMA site. (ref HD.34). In February 2016 Great Western Railway Ltd launched the North Cotswold Line Vision. Within this vision was the potential aim to reopen the railway between Honeybourne and Stratford upon Avon and provide passenger services. The Stratford Area Transport Strategy (SATS) consultation jointly carried out by WaCC & SDC clearly demonstrated that of the 910 people who responded to the consultation some 231 respondents supported rail expansion with 7 expressing opposition. This means that over one quarter (26%) specifically commented on railways and of those 97% stated they want a greater priority given to examining the potential for reopening the railway between Stratford upon Avon and Honeybourne. The Planning Inspector in his final report on SDC s Core Strategy, stated: Warwickshire County Council, as Transport Authority, acknowledged at the resumed Hearing that it has no experience of reinstating railway lines, distinct from reopening stations along an existing railway line. Whilst its reservations are understandable at this stage, reinstatement of this missing section of line holds the key to reinvigorating the Shakespeare Line and would further the Local Transport Plan vision for its Passenger Rail Strategy. There is an opportunity to re-appraise the contribution that rail reinstatement could make as part of the Transport Strategy for Stratford-upon-Avon that is currently underway. It would appear to provide a long-term solution to the town s traffic congestion. The Planning Inspector could not have made things any clearer when he added: There can be no question that the railway service would provide a sustainable alternative to the use of the private car for many residents and Visitors. Among other things reinstatement would contribute to improved network resilience. It is acknowledged that the Promoter of LMA sees the reinstatement of the railway as a positive benefit for its scheme, its offer to fund the GRIP 4 study should be embraced as a positive step forward towards reinstatement.

10 5 SLPG conducted an online Rail User Survey and separate Stratford upon Avon Town Centre Business Survey in February/March In total there were 884 respondents. 93% said they want local authorities to carry out an Economic Impact Study into the reopening of the railway line between Honeybourne and Stratford upon Avon which could facilitate a 45- minute train journey between Long Marston and Birmingham as well as enabling direct Stratford upon Avon, Oxford, Heathrow Airport and London Paddington train services via a 12-mile shorter route. The County Council, as Local Transport Authority, accepted in the Statement of Common Ground dated 16 January 2015, that a railway would increase modal shift and sustainability of the LMA site. The County Council endorsed the Garden Village bid to HM Government promoted rail reopening as a potential key element. Since GV status was conferred upon the LMA site no reference or action has been pursued concerning the rail reopening by the Local Transport Authority. Yet, the South Western Relief Road (SWRR) Evidence Report, 31st July 2017, SDC & WaCC, erroneously stated that:- Whilst all options to promote sustainable travel should be undertaken, the provision of heavy rail in lieu of a new road will have limited benefit to the existing operation of the highway network within Stratford-upon- Avon. This statement is very misleading as reinstating the railway has never been presented as an alternative to highway interventions, but an essential part of a overall sustainable transport package to serve not only Long Marston but also the Stratford upon Avon district. The statement also contradicts the Planning Inspector who stated in his Final Report on SDC s Core Strategy: There can be no question that the railway service would provide a sustainable alternative to the use of the private car for many residents and visitors Stratford on Avon District Council applied to the Coventry and Warwickshire Local Enterprise Partnership (CWLEP) by submitting an Expression of Interest to CWLEP Board that sought to attract funding for investigation/surveys into the potential for reopening the railway line. CWLEP rejected this application on the advice of Warwickshire County Council who subsequently refused under Freedom of Information to provide the nature of advice given to CWLEP that frustrated SDC s EOI.

11 6 Although the preceding paragraphs go into some detail concerning the potential railway reopening this is relevant because it sets out a series of events, decisions and statements that demonstrate at every stage any attempt to obtain a study or further information that would enable wider and full consideration of the potential viability of reopening the railway has been thwarted by the Local Transport Authority. The situation is compounded further by Warwickshire County Council as Local Transport Authority stating erroneously that there is no alternative to the construction of South Western Relief Road. Such a statement is simply not credible as other alternatives not been investigated, including the reopening of the railway and the offer of private funding by the developer. The County Council has chosen to ignore alternatives and offers in the case of the potential railway reopening and have repeatedly frustrated any consideration of them Planning Inspectorate At the Examination in Public of the Core Strategy in January 2015, Cala Homes stated that they were prepared to provide 17m towards reinstatement of the Stratford-Honeybourne railway as well as 450,000 towards a GRIP 4 business case study. At the Examination, in Public in January 2016, it was confirmed that their 17m rail contribution, was included in the draft S106, Heads of Terms Agreement. The final report of the Planning Inspector on the SDC Core Strategy (June 2016), in addition to the quotes already set out earlier in this objection letter, also stated: In this broader context it is appropriate to focus back on the policy. The ninth bullet-point under What is to be Delivered requires frequent public transport services between Stratfordupon-Avon and Honeybourne Station, and so the policy hook to justify the financial contribution that is offered is there. The main concern is therefore one of timing. The GRIP 4 study needs to proceed as soon as possible because that is the trigger for the rail industry to get involved and, if a lead body is identified, that would allow it to be identified in the Infrastructure Delivery Plan which, in turn, would ensure that the contribution offered would meet the tests in paragraph 204 of the Framework. Whilst there is a GRIP 5 stage it appears to be a detailed design phase and the consensus at the Hearing was that GRIP 4 was the appropriate trigger point. It is in prospect that a Section 106, associated with a second phase of Long Marston Airfield development, could be structured in this way, but there is a concern that the Council might simply not seek any such contribution. Realistically this is the only chance for the line to be reinstated and without this significant contribution being secured from the private sector it might never happen.

12 7 To date, nothing from the Planning Inspector s Final Report on SDC s Core Strategy has been pursued or actioned by either the Local Planning Authority or Local Transport Authority in respect of any of the elements concerning potential alternative transport solutions to the proposed Garden Village development and the need arising from it which is the basis being used to justify this application for a SWWR. Environment & Sustainability Stratford-upon-Avon District lies within the Birmingham Housing Market Area, within which 38% of all morning peak journeys into Birmingham City Centre are now made by rail. Network Rail forecast that this will grow by 49% by 2023 and 114% by (Network Rail West Midlands & Chiltern Route Study 2016). An EIS, as a first step and pre-appraisal of potential reinstatement of the Stratford-Long Marston railway line is imperative. Without an alternative, effective, faster and sustainable form of public transport the SWRR will attract and accommodate new and longer trips by car feeding into the already congested A46 corridor and Junction 15 of the M40 at Longbridge, Warwick. Bus services are declining nationally at 4% per annum. Traffic congestion affects the reliability of bus services and without alternative transport infrastructure the level of such congestion will increase and at times potentially reach intolerable levels with pollution from vehicle emissions. The information on Bus Services in the applicants Transport statement 5.6, is inaccurate and misleading. The statement refers to non-existent services and services from Long Marston are incorrectly stated as serving Stratford railway station. Stratford upon Avon Railway station does not have 320 parking spaces as stated. It has 70 spaces for use by rail passengers. Honeybourne does not have an hourly rail service to London as stated and the railway station car park is oversubscribed before the end of the morning peak. This depresses usage. The rural roads between Long Marston and Honeybourne station are not fit to service large volumes of vehicular traffic which would also pass through Pebworth village, a Conservation Area. Bus services do not cater for medium or longer distance commuter journeys north of Stratford to Birmingham, Worcester, Oxford or London, which only the rail service can deliver. e.g. A bus journey from Stratford-Moreton-in-Marsh takes 1hr 22mins. A rail journey via Long Marston Airfield would take 22 minutes.

13 8 Buses from Long Marston would have to use the existing congested highway network into Stratford, and timekeeping is likely to deteriorate with increased car journeys, congestion and length of journey time. Bus services do not therefore offer any incentives to car drivers to achieve modal change. The applicant states that they are Providing realistic alternatives to the car. They are not. The wider Long Marston area including the adjacent parts in Worcestershire and Gloucestershire, have a committed population of 23,000. It is evident that the cumulative impact of this total and traffic generation, have not been taken into account, nor the provision of meaningful transport alternatives that will achieve modal change. The railway has never been presented as an alternative to highway interventions but is an essential part of a sustainable transport package to serve not only Long Marston but also Stratford upon Avon. The diagram below shows how rail could deliver significant local, regional and national rail connectivity if the railway between Stratford upon Avon and Honeybourne was reinstated.

14 9 The applicants Environment Statement (Transport) states that:- The M40 can also be accessed via the A46, which provides a direct route to destinations such as Birmingham, Oxford and London. (5.3.2) This statement admits that the SWRR will encourage long distance commuting, it totally at odds with the Stratford Area Transport Strategies objective, to reduce high car dependency. The Long Marston hinterland which includes South Warwickshire, East Worcestershire and North Gloucestershire has a committed population growth of nearly 23,000 people by 2030/1 while Stratford will grow to 36,000. Roads alone cannot deal with this level of growth and it is unrealistic to assume walking, cycling or bus services will attract high levels of usage. Technical The SWRR bridge over the Greenway does not provide sufficient clearance to meet Network Rail s current standards. An earlier report by Amec Foster Wheeler for Cala, does not address this and demonstrates that they have not used the most up to date data or even consulted Network Rail, as a basic requirement. This error is repeated in the SWRR Environmental Impact Assessment Scoping Report, Lichfields, for Cala Management, March 2017, which includes inaccurate information on bridge clearance over the Greenway and refers to British Railways Board standards, para 4.6.6:- The Structure over the Stratford Greenway will provide minimum clearance of 5.7m. This is based on historic data from the British Railways Board, which required minimum height of 4.78m above rail level for electrified lines. Network Rail have confirmed that formerly, bridge designs used standard GE-RT8025 Issue 1 (October 2001), however this was superseded, as of the 7th March 2015, with a new standard GE-RT1210, which is much more onerous and has mandatory compliance from 7th March The standard takes account of the EU Interoperability Directive and is enshrined in UK law through the Interoperability Regulations.

15 10 Summarised, Interoperability is a European initiative designed to improve the competitive position of the rail sector so that it can compete more effectively with other forms of transport. Routes subject to electrification projects are required to comply with the Energy Technical Standard for Interoperability. This affects structures over the electrified railway by the withdrawal of a former UK dispensation for electrical clearances which allowed a distance of no less than 2.75m from platform height to any live part of the electrification infrastructure, including the raised pantograph of an electric train. In turn this means the soffit height of a bridge near a station platform would need to be 5.6m or greater: and the standard mandates a free-running wire height which also pushed soffit height of structures distant from station platforms to well above 5m. In summary, the legislation has recently changed in 2015 and a higher soffit height than assumed will apply. Summary SLPG are no longer campaigning for the outright reopening of the Stratford-Honeybourne railway line but neither do we accept the proposal being dismissed or continually relegated to the bottom of priorities. SLPG s online surveys carried out earlier this year demonstrate the overwhelming support from both the general public and Stratford upon Avon town centre businesses for a full Economic Impact Study to be carried out to determine the feasibility of reopening the railway. The mandate such a level of support for an EIS represents is founded from the need to confirm a notional 20m additional annual growth from improved rail connectivity and crucially the need to deliver connectivity between home (Long Marston and Stratford upon Avon) and employment (Birmingham and the West Midlands). To date no comprehensive EIS into the potential reopening of the railway has been completed that includes all relevant elements, including visitors. An EIS would enable, once and for all, a decision to be made about the viability and desirability of expanding the local and regional rail network it would also potentially assist the economic case for the further investment required on the Cotswold main railway line which would enable the two remaining sections of single track to be redoubled, increasing local and regional rail connectivity with much greater capacity.

16 11 Until an EIS is carried out on the potential reopening of the railway between Stratford upon Avon and Honeybourne, no alternatives, in terms of adequate transport infrastructure have been examined. Consequently, the Local Transport Authority stating that there is no alternative to the SWWR is misleading and incorrect. Development at Long Marston Airfield without sustainable transport infrastructure that is not proposed by this application is at variance to the bid for Garden Village status submitted to the Department for Communities and Local Government. We not prepared to fall into the trap of discussing where a relief road should be situated because we do not believe the need for such a road has been demonstrated. The application for a proposed relief road is presented as a fait accompli as result primarily of the Local Transport Authority ignoring the need to properly consider transport alternatives and the need for balanced set of transport infrastructure measures. The Local Planning Authority have compounded the situation by their indifference of the Planning Inspector s Final Report on the Core Strategy and the subsequent omission from its Infrastructure Delivery Plan of any reference to the railway scheme and potential significant third party funding. The impact and scale of environmental harm arising from a South Western Relief Road that will be experienced by existing properties and affect new development will be intolerable. The case for such a road is not made and therefore the proposal is avoidable. We believe this renders the application in its current form wholly unacceptable. For the reasons set out above the proposals contained in 18/01883/FUL should lead to the application being REFUSED. Fraser Pithie Secretary

17 Shakespeare Line Promotion Group 3 November 2018 Robert Weeks Head of Planning & Housing Stratford on Avon District Council Elizabeth House Church Street STRATFORD UPON AVON Warwickshire CV37 6HX 166 Windy Arbour Kenilworth Warwickshire CV8 2BH suawoox@icloud.com Planning Aoplication 18/01892/OUT Long Marston Garden Village OBJECTION We, being the Shakespeare Line Promotion Group (SLPG), are the recognised and constituted Rail User Group for the railway routes and train services between Stratford upon Avon, Birmingham, Leamington Spa and London. The planning application OUT18/01892 seeks outline permission for the development of 3,100 homes, 5.7 hectares of Business Park, further mixed use areas together with two primary schools and a secondary school. We hereby wish to OBJECT to the above referenced planning application being: The scale of the development is not adequately supported or serviced by sustainable transport infrastructure. Further the application ignores the comments of the Planning Inspector in his Final Report on Stratford on Avon s District Council s Core Strategy and moreover contradicts the bid made to HM Government to attain Garden Village status for the Long Marston site which made at least twelve references to environmentally sustainable transport infrastructure but nothing of which is contained within the application. The proposed development on this brownfield site is presented without any objective and comprehensive appraisal of transport infrastructure and therefore draws strong objection. Consequently, the impact of the development will have significant deleterious effects upon the general amenity of Stratford upon Avon, the existing villages of Long Marston, Welford on Avon, Pebworth, Honeybourne and Mickleton. This will be compounded by a severe deterioration in the environment caused by intolerable motor vehicle traffic volumes on rural road systems over a considerable radius leading to a deterioration in safety and the environment.

18 2 We cite the following grounds for this objection as follows. Planning & Policy Environment & Sustainability Planning & Policy National Planning Policy Framework The application fails to address important concepts in the National Planning Policy Framework (NPPF) 2012, such as:- reducing the need to travel; balancing the transport system in favour of sustainable travel; giving people a choice in travel; reducing green gas emissions. Garden Village Bid & Status The developer, Cala s Planning Statement - Long Marston Airfield Garden Village, June 2018, states: Neither the re-opening of the railway nor the transport hub are part of the development for which this outline application seeks planning permission for. The current application is not in accordance with the Cala/Stratford DC, Long Marston Airfield Garden Village Expression of Interest (EOI), 2016, which formed the basis of the Government s approval of Garden Village status in January The EOI contained twelve positive references to the benefits reinstatement of the rail link, including a private contribution of up to 17m from the developer. However, due to pressure from Warwickshire County Council, this offer has now been withdrawn with the funding reallocated towards a proposed South West Relief Road (SWRR). This amounts to a flagrant departure from the terms and proposal that were compiled and presented to HM Government when seeking Garden Village status for the Long Marston Airfield site and this development. Consequently, we will be requesting the Secretary of State to call this application, and the application for the SWRR in to reconsider the granting of Garden Village status upon this development and the associated road. The application and proposals contained within it fail to deliver the sustainable and environmentally sound infrastructure required to qualify for Garden Village status.

19 3 Local Transport Authority Warwickshire County Council In Policy PTPR4 of its Local Transport Plan, Warwickshire County Council state; The County Council will consider supporting a proposal for reopening the line if it is promoted by the DfT, the rail industry or a third party provided the local benefits outweigh any local environmental disbenefits. Discussions with Cala Homes in 2014, confirmed that their transport priority for the Long Marston Airfield development, was a 53m contribution towards reinstatement of the railway, in view on the strong connectivity with Birmingham, with smaller highway interventions. The Core Strategy Statement of Common Ground between Warwickshire County Council (WaCC) and Cala Homes dated 16 January 2015, confirmed that the County Council accepts the reopening of the Greenway to public transport including heavy rail, would increase the modal shift and sustainability of the LMA site. (ref HD.34). In February 2016 Great Western Railway Ltd launched the North Cotswold Line Vision. Within this vision was the potential aim to reopen the railway between Honeybourne and Stratford upon Avon and provide passenger services. The Stratford Area Transport Strategy (SATS) consultation jointly carried out by WaCC & SDC clearly demonstrated that of the 910 people who responded to the consultation some 231 respondents supported rail expansion with 7 expressing opposition. This means that over one quarter (26%) specifically commented on railways and of those 97% stated they want a greater priority given to examining the potential for reopening the railway between Stratford upon Avon and Honeybourne. SLPG conducted an online Rail User Survey and separate Stratford upon Avon Town Centre Business Survey in February/March In total there were 884 respondents. 93% said they want local authorities to carry out an Economic Impact Study into the reopening of the railway line between Honeybourne and Stratford upon Avon which could facilitate a 45-minute train journey between Long Marston and Birmingham as well as enabling direct Stratford upon Avon, Oxford, Heathrow Airport and London Paddington train services via a 12-mile shorter route.

20 4 The County Council, as Local Transport Authority, accepted in the Statement of Common Ground dated 16 January 2015, that a railway would increase modal shift and sustainability of the LMA site. The County Council endorsed the Garden Village bid to HM Government promoted rail reopening as a potential key element. Since GV status was conferred upon the LMA site no reference or action has been pursued concerning the rail reopening by the Local Transport Authority. Yet, the South Western Relief Road (SWRR) Evidence Report, 31st July 2017, SDC & WaCC, erroneously stated that:- Whilst all options to promote sustainable travel should be undertaken, the provision of heavy rail in lieu of a new road will have limited benefit to the existing operation of the highway network within Stratford-upon- Avon. This statement contradicts the comments made previously by the Planning Inspector in his Final Report on SDC s Core Strategy, published in June 2016: There can be no question that the railway service would provide a sustainable alternative to the use of the private car for many residents and visitors Stratford on Avon District Council applied to the Coventry and Warwickshire Local Enterprise Partnership (CWLEP) by submitting an Expression of Interest to CWLEP Board that sought to attract funding for investigation/surveys into the potential for reopening the railway line. CWLEP rejected this application on the advice of Warwickshire County Council who subsequently refused under Freedom of Information to provide the nature of advice given to CWLEP that frustrated SDC s EOI. Although the preceding paragraphs go into some detail concerning the potential railway reopening this is relevant because it sets out a series of events, decisions and statements that demonstrate at every stage any attempt to obtain a study or further information that would enable wider and full consideration of the potential viability of reopening the railway has been thwarted by the Local Transport Authority.

21 5 The situation has been compounded further by the County Council stating erroneously that there is no alternative to the construction of South Western Relief Road. Such a statement is simply not credible as no other alternatives have been investigated, including the reopening of the railway and the offer of private funding by the developer which the County Council has chosen to ignore. Local Planning Authority Stratford on Avon District Council The Core Strategy of Stratford on Avon District Council (SDC) is the planning policy document adopted by the Secretary of State for Communities and Local Government. The adopted strategy only safeguards a route for a potential SWRR. The final report of the Planning Inspector on the SDC Core Strategy (June 2016) stated: Warwickshire County Council, as Transport Authority, acknowledged at the resumed Hearing that it has no experience of reinstating railway lines, distinct from reopening stations along an existing railway line. Whilst its reservations are understandable at this stage, reinstatement of this missing section of line holds the key to reinvigorating the Shakespeare Line and would further the Local Transport Plan vision for its Passenger Rail Strategy. There is an opportunity to re-appraise the contribution that rail reinstatement could make as part of the Transport Strategy for Stratford-upon-Avon that is currently underway. It would appear to provide a long-term solution to the town s traffic congestion. In this broader context it is appropriate to focus back on the policy. The ninth bullet-point under What is to be Delivered requires frequent public transport services between Stratfordupon-Avon and Honeybourne Station, and so the policy hook to justify the financial contribution that is offered is there. The main concern is therefore one of timing. The GRIP 4 study needs to proceed as soon as possible because that is the trigger for the rail industry to get involved and, if a lead body is identified, that would allow it to be identified in the Infrastructure Delivery Plan which, in turn, would ensure that the contribution offered would meet the tests in paragraph 204 of the Framework. Whilst there is a GRIP 5 stage it appears to be a detailed design phase and the consensus at the Hearing was that GRIP 4 was the appropriate trigger point. It is in prospect that a Section 106, associated with a second phase of Long Marston Airfield development, could be structured in this way, but there is a concern that the Council might simply not seek any such contribution. Realistically this is the only chance for the line to be reinstated and without this significant contribution being secured from the private sector it might never happen.

22 6 There can be no question that the railway service would provide a sustainable alternative to the use of the private car for many residents and Visitors. Among other things reinstatement would contribute to improved network resilience. It is acknowledged that the Promoter of LMA sees the reinstatement of the railway as a positive benefit for its scheme, its offer to fund the GRIP 4 study should be embraced as a positive step forward towards reinstatement. Stratford District Council s Citizens' Panel Special Strategic Review - November 2016, Final Results, showed that reinstatement of the Rail Link to Cotswold Line, south of Stratford rail link had a score above 2, this result therefore made rail reinstatement one of the Council s priorities At the Stratford Examination in January 2015, Cala Homes stated that they were prepared to provide 17m towards reinstatement of the Stratford-Honeybourne railway as well as 450,000 towards a GRIP 4 business case study. At the Examination, January 2016, it was confirmed that their 17m rail contribution, was included in the draft S106, Heads of Terms Agreement. This is no longer included or forms part of the application. Despite the comments from the Planning Inspector and the subsequent indication of priority from the Citizens Panel the Local Planning Authority and Local Transport Authority have remained indifferent to investigating and evaluating the alternative that could be provided by reopening the railway line. Environment & Sustainability Stratford-upon-Avon District lies within the Birmingham Housing Market Area, within which 38% of all morning peak journeys into Birmingham City Centre are now made by rail. Network Rail forecast that this will grow by 49% by 2023 and 114% by (Network Rail West Midlands & Chiltern Route Study 2016). An EIS, as a first step and pre-appraisal of potential reinstatement of the Stratford-Long Marston railway line is imperative. Without an alternative, effective, faster and sustainable form of public transport the SWRR will attract and accommodate new and longer trips by car feeding into the already congested A46 corridor and Junction 15 of the M40 at Longbridge, Warwick.

23 7 The wider Long Marston area including the adjacent parts in Worcestershire and Gloucestershire, have a committed population of 23,000. It is evident that the cumulative impact of this total and traffic generation, have not been taken into account, nor the provision of meaningful transport alternatives that will achieve modal change. The railway has never been presented as an alternative to highway interventions but is an essential part of a sustainable transport package to serve not only Long Marston but also Stratford upon Avon. The diagram below shows how rail could deliver significant local, regional and national rail connectivity if the railway between Stratford upon Avon and Honeybourne was reinstated. The applicants Environment Statement (Transport) states that:- The M40 can also be accessed via the A46, which provides a direct route to destinations such as Birmingham, Oxford and London. (5.3.2) This statement admits that the SWRR will encourage long distance commuting, consequently it is totally at odds with the Stratford Area Transport Strategies objective, to reduce high car dependency.

24 8 The Long Marston hinterland which includes South Warwickshire, East Worcestershire and North Gloucestershire has a committed population growth of nearly 23,000 people by 2030/1 while Stratford will grow to 36,000. Roads alone cannot deal with this level of growth and it is unrealistic to assume walking, cycling or bus services will attract high levels of usage. Bus services are declining nationally at 4% per annum. Traffic congestion affects the reliability of bus services and without alternative transport infrastructure the level of such congestion will increase and at times potentially reach intolerable levels with pollution from vehicle emissions. The information on Bus Services in the applicants Transport statement 5.6, is inaccurate and misleading. The statement refers to non-existent services and services from Long Marston are incorrectly stated as serving Stratford railway station. Stratford upon Avon Railway station does not have 320 parking spaces as stated. It has 70 spaces for use by rail passengers. Honeybourne does not have an hourly rail service to London as stated and the railway station car park is oversubscribed before the end of the morning peak. This depresses usage. The rural roads between Long Marston and Honeybourne station are not fit to service large volumes of vehicular traffic which would also pass through Pebworth village, a Conservation Area. Bus services do not cater for medium or longer distance commuter journeys north of Stratford to Birmingham, Worcester, Oxford or London, which only the rail service can deliver. e.g. A bus journey from Stratford-Moreton-in-Marsh takes 1hr 22mins. A rail journey via Long Marston Airfield would take 22 minutes. Buses from Long Marston would have to use the existing congested highway network into Stratford, and timekeeping is likely to deteriorate with increased car journeys, congestion and length of journey time. Bus services do not therefore offer any incentives to car drivers to achieve modal change. The applicant states that they are Providing realistic alternatives to the car. They are not. Summary SLPG are no longer campaigning for the outright reopening of the Stratford-Honeybourne railway line but neither do we accept the proposal being dismissed or continually relegated to the bottom of priorities.

25 9 SLPG s online surveys carried out earlier this year demonstrate the overwhelming support from both the general public and Stratford upon Avon town centre businesses for a full Economic Impact Study to be carried out to determine the feasibility of reopening the railway. The mandate such a level of support for an EIS represents is founded from the need to confirm a notional 20m additional annual growth from improved rail connectivity and crucially the need to deliver connectivity between home (Long Marston and Stratford upon Avon) and employment (Birmingham and the West Midlands). To date no comprehensive EIS into the potential reopening of the railway has been completed that includes all relevant elements, including visitors. An EIS would enable, once and for all, a decision to be made about the viability and desirability of expanding the local and regional rail network it would also potentially assist the economic case for the further investment required on the Cotswold main railway line which would enable the two remaining sections of single track to be redoubled, increasing local and regional rail connectivity with much greater capacity. Until an EIS is carried out on the potential reopening of the railway between Stratford upon Avon and Honeybourne, no alternatives, in terms of adequate transport infrastructure have been examined. Consequently, the Local Transport Authority stating that there is no alternative to the SWWR is misleading and incorrect and going ahead with the development of the Garden Village development at Long Marston is not environmentally sustainable. Development at Long Marston Airfield without sustainable transport infrastructure that is not proposed by this application is at variance to the bid for Garden Village status submitted to the Department for Communities and Local Government. The impact and scale of environmental harm that will be experienced by existing properties and affect new development will be intolerable, is avoidable and renders this application in its current form wholly unacceptable. For the reasons set out above the proposals contained in 18/01892/OUT should lead to the application being REFUSED. Fraser Pithie Secretary