Testun llawn:
Thank you for the opportunity to comment on the proposed alternative sites consultation for the future growth of Warwick District. Warwickshire Wildlife Trust has reviewed the alternative options, with regards to the potential ecological and environmental implications, and would like to make the following comments:
Ecological Data Provision
The Trust would like to outline the necessity of using up-to-date ecological and environmental information, to inform strategic site selection from the outset. Whilst the purpose of this consultation paper is to aid the site selection process for the sustainable growth of Warwick District; questions are raised as to how truly sustainable growth can be delivered, when there is inadequate supporting ecological information to indicate the environmental benefits or constraints of each growth option. This is problematic in two ways:
Primarily, the presence of designated wildlife sites and/or protected species has the capacity to shape the development and influence the overall developable area of the strategic site. Identifying the ecological assets of each growth option will therefore be essential to convey confidence that the strategic site can deliver the required development during the decision making process.
Secondly: the Local Authority will need to demonstrate that decisions on strategic site selection are the most appropriate considered against the reasonable alternatives*. This cannot be achieved if the environmental constraints and opportunities of each growth option have not been available to inform which is likely to be the most appropriate alternative from the environmental perspective.
Initial survey work for the original proposed sites has been undertaken by the Habitat Biodiversity Audit (HBA) and was available for comment by the public during the Preferred Option consultation. It is therefore unclear why this information has not been forthcoming for the alternative sites and available for comment within this consultation period. The Trust subsequently advocates that, at the very least, the HBA habitat assessment is extended to include the proposed alternative sites prior to site selection. Furthermore, we contend that this initial assessment is also supported by; a data search of protected species for each site and the additional survey work that has been recommended within the Warwick District Habitat Assessment (such as potential Local Wildlife Site (pLWS) criteria assessments). The Trust would be happy to comment on any data that came forward and would welcome the opportunity to discuss the constraints or opportunities of each site with yourselves or prospective developers.
Habitat Regulations Assessment
It is possible that the future growth of the district may require the need to conduct a Habitat Regulations Assessment (HRA) in accordance with regulation 85 of the Conservation (Natural Habitats & c.) Regulations (Amended 2007). The need for this assessment is to ensure that any proposed growth strategy will not have a detrimental impact on a Natura 2000 site (i.e SAC, SPA or Ramsar site). Whist the nearest European site is situated in Nuneaton and Bedworth Borough, the future growth of Warwick District may have implications on European sites stretching much further, through increases in tourism, water abstraction or through the increased production of carbon emissions. To evaluate if Warwick District needs to undertake a full HRA, the Trust advises that a HRA scoping assessment is undertaken. This will outline if any aspects of the Core Strategy are likely to impact on European sites and therefore require a full HRA. As the HRA should ideally be an essential aspect of the evidence base to inform spatial growth, it is strongly recommended that the assessment is undertaken at the first possible opportunity, encompassing all original and alterative strategic sites, to ensure that the desired growth options do not impact on a European site.
Green Infrastructure
All development parcels must take into consideration the need to have sufficient space to not only accommodate grey infrastructure, but also to allow sufficient provision for the necessary buffering of existing biodiversity assets and make a contribution towards green infrastructure (GI). Within the larger sustainable urban extensions, the Trust recommends that green infrastructure provision should make up at least 40% of the developable area in line with government best practice**, however this will largely depend on the ecological assets of each site and their connectivity to wider GI objectives.
The Trust advises Warwick District to take a strategic approach to GI provision within each of the development parcels. Opportunities for biodiversity enhancement through habitat buffering, restoration and creation, in line with LBAP objectives, should be seized wherever possible, but these should also be considered in unison with the social and economic requirements of the site. For example, biodiversity enhancements may be linked to SUDS or public open space or contribute to flood alleviation. This multifunctional use of GI will best be informed through the production of the GI strategy, which should be a key consideration in the site selection process.
Site Specific
Whist it is difficult to provide meaningful comments on the alternative sites until further ecological environmental data is available, the Trust would like to provide our initial thoughts on the some of the obvious constraints and opportunities, each development parcel presents.
Site 2 - Land at Campion School/ South of Sydenham
The site forms an extension to the original site known as South of Sydenham. Once again the bulk of the site consists of amenity grassland; however the entire eastern boundary is demarcated by Whitnash Brook. The brook is Local Nature Reserve managed by Warwickshire Wildlife Trust and is a potential Local Wildlife Site (pLWS). It forms an essential wildlife corridor through a largely agricultural environment and will therefore form an important node or corridor within any GI strategy. Given its status as an LNR, it makes a contribution to the availability of public open space within the locality. Therefore, if this site is selected, an assessment will be required to assess the potential implications of increased recreational pressure on the brook corridor.
Given the biodiversity and amenity importance of the brook, it will be essential to not only to sufficiently buffer the brook, but also to ensure that adequate connectivity to the wider environment is maintained, to preserve its long-term integrity. Furthermore, as there is a strong presumption against the loss or fragmentation of a pLWS, it is likely that the railway cutting pLWS along the western boundary will also create further access issues to the west. Further information and assessment must be forthcoming for this site before it can be seen as a sustainable growth option. Until evidence can demonstrate that development can be undertaken without a significant effect on the integrity or the connectivity of the 2 pLWS, then the Trust would like to strongly advise against the use of this site as potential growth option.