Our priorities relate to the canal corridor and land and development within and immediately adjacent to the corridor. With any type of development British Waterways would require development to not adversely affect the integrity of the waterway structure, quality of the water, result in unauthorised discharges and run off or encroachment, detrimentally affect the landscape, heritage, ecological quality and character of the waterways, prevent the waterways potential for being fully unlocked or discourage the use of the waterway network. The waterways can be used as tools in place making and place shaping, and contribute to the creation of sustainable communities. British Waterways would seek for any development to relate appropriately to the waterway and optimise the benefits such a location can generate for all parts of the community.

Site 1A&1B. This site extends the envelope of development of Kenilworth and removes a green lung and recreational area close to the conurbation.

Site 2. This site appears to provide many advantages being close to an area of employment, transportation, schools and Play areas while not significantly increasing the town envelope.

Site 3 No comments

Site 4 This site would significantly effect the remaining pleasant approach to Warwick town from the north, while the proposal to extend beyond the A45 Bye Pass should not be entertained..

Site 5 We can see no advantages to the development of this site since it requires full infrastructure developments to avoid another commutor area.

Site 6 This site though partially developped, provides some open areas to the neighbouring conerbation and would encroach on the flood plains .

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.

Sites 1a & 1b - Kenilworth Wardens Cricket Club and Woodside Training Centre, Kenilworth
This site forms the northern tip of the original site known as the Land at Thickthorn, Kenilworth. The site appears to consist predominantly of amenity grassland which is of negligible value for biodiversity, however this is counterbalanced by the presence of Glasshouse ancient woodland and spinney pLWS which extends through the centre of the parcel and extends down the south western boundary. As with the parcel to the south, the presence of an ancient woodland of high biodiversity value, such as Thickthorn and glasshouse wood, are significant constraints to the potential development of this parcel, given the need for substantial buffer zones of at least 50 metres. The species rich hedgerows are also likely to be essential to retain connectivity between the woodlands, for which their retention would result in the further reduction of the developable area. In addition, the south of this parcel appears to have restricted access, requiring the breach and fragmentation of part of the woodland to accommodate entry points. The Trust do not see this as a plausible solution to this issue. In turn, as recommended within the Warwick District Habitat Assessment, it is unlikely that this parcel would be a suitable candidate for a sustainable growth option.

Development infringes the Kenilworth Gap from Coventry.

Object

With the opening of the new rail link and station this would be appropriate.

Support

The Alternative Sites Paper does not comment on the need for these new sites to be subject to a sustainability appraisal and therefore would not appear to follow the procedures set out in PPS12 and its companion documents.

Sites 1a and 1b - This site is not compatible with the Districts preferred spatial strategy for growth which focuses on Warwick / Leamington and Whitnash. In the absense of an SA it is unclear what the ecological impact would be.

Site 2 - Without an SA the full impact of developing this site is unknown. It would however, be contrary to sustainability objectives 6 (housing), 3 (natural environment) and 16 (flooding).

Site 3 - This site is contrary to the spatial strategy which directs major growth to the urban areas of Warwick / Leamington and Whitnash. All previous development proposals surrounding Cubbington have ben previously rejected by the Council.

Site 4 - This site is contrary to the spatial strategy which directs major growth to the urban areas of Warwick / Leamington and Whitnash.

Site 5 and 6 - Both are large areas of West Midlands Green Belt which maintains separation between towns and villages.

Site 1a - is in active use as an important sports facility for the town of Kenilworth. Its loss would be detrimental to the local community and contrary to national planning guidance. Development on the site would also be unacceptably prominent causing harm to the openness of the Green Belt.

1b - contains an attractive building set in substantial and well maintained grounds currently in use for training / employment . Intensifying development on the site would be harmful to the character and appearance of the locality.

2 - This would be unacceptable as it is a very large parcel of land which would inevitably be at the loss of other more preferable sites currently proposed for development. It is less sustainable than other sites proposed in the Preferred Options Draft and Alternative Sites paper. Parts of the site suffer from flooding and are prominent from a landscape perspective.

3 - Supports the development of this site as it can occur without adverse visual impact or harm to the wider openness of the Green Belt. It is a sustainable location already well served by public transport and in close proximity to a wide range of local services and facilities.
The land is currently owned jointly by the King Henry VIII Endowed Trust and Sir Thomas White's Charity who are also involved in the promotion of land at Europa Way. We are instructed to inform the Council that the allocation and development of land at Europa Way must take precedence over land at Cubbington. If the Council feels it is unnecessary to allocate the land now it shoulsd still be removed from the green belt to allow for future housing needs to be met.

Site 4 - Land beyond the Warwick By-Pass is wholly inappropriate for development to meet the needs of Warwick and Leamington. It is poorly related to the main urban area and harmful to the wider Green Belt and countryside objectives. Development would involve a major encroachment into the open countryside and significantly harm the openness of the green belt.

Site 5 - Development would be wholly inappropriate as the land is poorly related to the existing urban areas and thus would be entirely unsustainable. Development would be harmful in landscape and result in a major encroachment into the Green Belt.

Site 6 - The land is wholly inappropriate for residential development. The area identified contains a huge number of valuable existing uses which need to be retained, together with the attractive village of Baginton. Residential development on any part of the site would not meet the needs of Warwick or Leamington and would be likely to result in unacceptable levels of commuting. It would be unacceptably harmful in landscape terms and detrimental to the openness of the Green Belt.

Supports development to the east of Kenilworth in general but have submitted comments at previous consultation stages identifying Clients land as suitable and available for
development and highlighting concerns regarding the deliverability and capacity of the land at Thickthorn. These included:
- the loss of sports pitches unless land can be identified
- the high level of constraints of the site, including listed buildings, ancient woodland, noise and traffic generation; and the potential need for a new primary school.
As an alternative Southcrest Farm is deliverable and developable without having any significant adverse
Southcrest Farm can help provide
such flexibility.
The sites have not been subject to a sustainability appraisal or appraised through the SHLAA process therefore to allocate the sites without carrying out a full appraisal would render the Core Strategy unsound in accordance with PPS12. There is also concern that as site 1a is currently in use as a Cricket pitch and development would result in the loss of this that it does not pass the test of being deliverable. Site 1a also raises similar issues to those identified in our original representations regarding land at Thickthorn, namely:
- noise impacts from the A46;
- impact on established landscape and associated ecology; and
- highway access.
Neither site 1a or 1b either on their own or in combination are of sufficient size to be counted as strategic sites and do not therefore warrant being identified at this Core Strategy stage.

Site 5 is a highly sustainable location for growth to meet the Coventry overspill which the RSS panel report states should be in the vicinity of Gibbet Hill / Finham. The joint green belt study identified the site as one of the least constrained parcels of green belt around Coventry. Development of a strategic scale has the opportunity to address issues of infrastructure and security and the University of Warwick has planning permission for development on University land up to the north-eastern boundary of the site. Only part of the area has been assessed through the SHLAA so this should be updated to consider all of the site.

Objection

Site 1a and 1b - Whilst the emerging RSS does not form part of the Development Plan, it is a clear indication of the direction of travel in meeting the growth agenda. Within the emerging RSS, it is Warwick and Leamington Spa which are identified as a Settlement of Significant Development (SSD) and this designation does not include Kenilworth. We have previously set out in our representations that the previously considered Preferred Option for Kenilworth is of excessive size in relation to the role of Kenilworth in the region. We do not consider that a need can be demonstrated for a second site in Kenilworth given that the emphasis should be on meeting local needs only.

Site 3 - The development of this site would result in the gap between Cubbington and Lillington being completely eroded and the merging of these settlements. The site is located within the open Green Belt and we consider that this site fulfils an important role in maintaining openness between the two areas, in accordance with PPG2.
Furthermore, the site appears to have access only on to a small point at Offchurch Road which is insufficient to serve a site of this site, particularly given the small scale nature of this site and the relatively small length of site frontage in this area. It may be that there are secondary points of access through some existing roads in Lillington however we would query the ability of these roads to accommodate a development of 1,000 plus dwellings.

Site 4 - This site submission appears to be based purely on land ownership as oppose to consideration of a suitable development site. The parcels north of the Warwick by-pass are illogical development sites, extending development beyond a clearly established development boundary in this area. Furthermore, the adopted Local Plan Proposals Map shows over half of the land to the south of the bypass as forming part of a historic park / garden which should therefore be protected from development.

Object

1a - For the purpose of clarification, this site has been promoted on behalf of the Kenilworth Wardens Cricket Club, separately from land identified as site 1b below (Woodside Training Centre). The previous submission
in September 2009, made clear that, having regard to the location of the site adjacent to the Preferred Option allocation at Thickthorn, it is the intention of the club to seek to safeguard the setting of the Club in the context of the form and character of surrounding land uses, and/or enable the Club to secure an alternative
ground which is of appropriate size to accommodate its requirements.

2 - There is already a substantial Preferred Option allocation for Warwick/Leamington, and in accordance with the Preferred Option, housing should be distributed across the District. Areas such as Kenilworth where
development, on deliverable sites, can help bring forward new employment/investment and support the new railway station and contribute to a more even distribution of economic growth across the District.

3 - There is already a substantial Preferred Option allocation for Warwick/Leamington, and in accordance with
the Preferred Option, housing should be distributed across the District. Areas such as Kenilworth where
development, on deliverable sites, can help bring forward new employment/investment and support the new
railway station and contribute to a more even distribution of economic growth across the District.

Object

Support and Objection

Object

Object

Object

Object

Object

Object

Comment

I object to this development because:

- the loss of the facility if the Wardens Cricket Ground for youth and recreational activities
- Over- development of eastern Kenilworth
- Over burdening existing infrastructure re services, schools, medical facilities, traffic
- Disruption to Kenilworth during construction work (we have already had years of onconvenienece with new gas mains and sewers being laid).

Support in part. It is on the edge of a currently developed area. The area nearby suffers with drainage issues so development may resolve this.

There is already a severe flooding problem in Cubbington -any major development in the vicinity would surely exacerbate the problem

More should be done to incorporate brown field or previously developed land before building on greenfield. Development should be dispersed through the district rather than burdening the infrastructure in one place.
Supports development at Kenilworth Wardens and Woodside Training Centre as this is a sensible extension to the site at Thickthorn upon previously developed land.

Objects to development south of sydenham but considers that development north of the bridleway to to Radford Semele would be acceptable.
Objects to development at Glebe Farm, Cubbington but considers that development of the north western corner adjacent to Cubbington would be acceptable.
Objects to the development of Loes Farm but considers that a small development next to the Saxon Mill.
Objects to the development of Hurst Farm, Burton Green but a small extension to the University of Warwick would be acceptable.
Objects to development of the land around Baginton airport but considers that development of the large brown field site south of the airport would be acceptable.

The willingness of parties to sell land for material gain should not determine the outcome of planning applications. This area is in the fragile green belt, set up to maintain open areas of countryside and it should remain so. It is a wildlife haven with birdsong at dawn chorus. The wood is a delight with many drifts of wild flowers.
No doubt the cricket club will then be looking for land to change from agricultural use to leisure. Where will it all end?
There is also a mobile phone mast situated on this land away from housing. Will people willingly purchase houses surrounding it?

Representations from Bishop's Tachbrook Parish Council including responses to the alternative sites and in addition a revised alternative option in response to the Warwick District Preferred Options. Full details of the Parish Council's Revised Alternative Option can be read in the paper version that WDC Planning hold at Council Offices. It may also be found on Bishop's Tachbrook's website:
http://www.bishopstachbrook.com/PDF's/100408_BishTachPC_CSPrefOpt_AltOpt[1].pdf

Site 1 and 1b

Part of the site is Green Belt and potential grade 3 farmland whilst the other part is an existing mixed use development comprising business and recreational use. The site falls within the Arden Parklands and there is strong mature tree corridor to Glasshouse Lane with internal hedgerows visible which currently defines the urban edge. The eastern site is bounded by the A46 so there will need to be a substantial landscape buffer between the development and the road. The development will remove a local amenity - i.e. the sports.

Site 2

Part of the site is located on grade 2 and 3 farmland. The development would fall within Dunsmore Plateau Fringe. There is a strong vegetation corridor along the railway line, which currently defines the urban edge. There is good vegetation cover to the eastern boundary and good internal hedged field boundaries. A landscape buffer will be necessary between the proposed development and the railway and wetland corridors and farmland to the east and south.

Site 3

This site is on Green Belt and Grade 3 farmland with a small fragment of Grade 2 farmland affected on the southern boundary. The development would fall within Dunsmore Plateau Farmlands and Plateau Fringe. Although Lillington and Cubbington are already physically connected the proposed site is on higher ground that the surrounding area so there will be visual impact issues, particularly with the scale of development proposed. A landscape buffer would be needed to both break up the scale and screen the development from the school and its playing fields and from the adjacent farm and its associated buildings.

Site 4

Green Belt, Grade 3 farmland. The development would fall within the Arden Parklands. At present the village of Leek Wootton has a separate identity, this is reinforced by the 'green wedge' of farmland mature trees between the village and the built edge of Warwick. Development of this land will have an adverse impact upon this identity and the village will become a continuation of the urban edge of Warwick. There will be high adverse visual impact from main roads, neighbouring properties and public footpaths. Some of the development is proposed on higher ground, this will widen the potential visual envelope.

Site 5

Hurst Farm is within the Green Belt and Arden Parklands. The proposed site abuts farmland on the majority of its boundaries. This development would take out Grade 2 farmland, some with field ponds. There may be potential ussues regarding the proximity to the flood zone. Roughknowles Wood is on higher ground so there will be potential visual issues on land adjacent to the woodland. the site is is close proximity to Kenilworth and Gibbet Hill.

Site 6

Green Belt and potential flood zone issues. Dunsmore Parklands. Development on this scale would destroy the identity of the village of Baginton. The village would merge with Finham, the urban edge of Coventry. The development area appears to take in the Conservation Area, Lunt Roman Fort, the golf course, garden nurseries, sewage works and landfill?