While I have supported the developments proposed at Thickthorn in the Preferred Options document, I do not support any further development alongside the A46 towards Coventry. With the possible development of the Finham site there is a real danger of us ending up with a continuous 'ribbon' of development along the A46 linking Kenilworth and Coventry.

Also, access to and from this site from Glasshouse Lane could be difficult and dangerous, with blind corners in both directions which would be difficult to mitigate against.

This site has a watercourse along the northern boundary. The catchment area is too small for the watercourse to have the flood plain automatically mapped. Therefore should this site come forward it will require a flood risk assessment (FRA) to level 2 standard to clarify the flood plain extent and easement width required for this watercourse.

The site is sensitive in terms of protection requirements for 'Controlled Waters'. It is located on solid geology of the Pennine Upper Coal Measures formation, consisting of bands of alternating mudstone, siltstone and sandstone. The more permeable strata will contain sufficient groundwater to support drinking water abstractions and thus the whole formation is now classified as Principal Aquifer under the new Water Framework Directive typology. There are no drift deposits overlying the solid geology locally and the soils predominantly consist of fine to coarse loamy silts, with intermediate leaching potential. Furthermore, the site is located 1.5 km south westerly from a STW public supply borehole and as said above there is a watercourse bordering the site to the north, with the river Avon some 500 m to the east.

Should this site come forward further site specific investigation will need to confirm the exact geology and soil conditions locally, as well as depth to watertable, ground drainage potentials and any contamination legacy from previous developments. There could be Made Ground across the site or indeed impacts from the adjacent railway line. As part of any planning application for a residential development, we would like to see a site investigation and risk assessment condition to assess risks to controlled waters. Based on those findings, we can then also better advise on future drainage options (e.g. to ground or not). The Environmental Health department at the Council has the remit to protect human health, so they will need to get involved too.

Development should be shared and this area has seen little development.

If suitably landscaped a small development on this scale is unlikely to have a significant impact on existing homes or communities.

Sites 1a; 1b; 2: Support.
Site 3: I do not support the development of purely greenfield land if re-development is available elsewhere.
Site 4: If a greenfield site is to be used, this would appear preferable to others due to it location near a major route.
Site 5: I do not support the development of purely greenfield land if re-development is available elsewhere. In particular, this site does not appear to possess an adequate road network to support the level of development proposed. Any improvements to the road network would further disrupt greenfield land.
Site 6: I would support this location for development, so long as guarantees can be made to residents of Baginton village that investment will be made in local amenities to support an influx of new residents.

Questionnaitr Response:

Sites 1a; 1b; 3; 4; 5; 6:
I have No Objection.

Site 2:
If this land were to be developed it would have an extremely damaging effect on the area.
1.It is a flood plain and there is a reason for it being so.
2. Sewers around Whitnash already have problems they do not need to be exacerbated.
3. Roads around the area are already extremely busy at key times in the day and any Bank holiday. It is not a viable proposition to support an extra 1000 houses with probably two cars per house and more children to ferry to primary schools out of the area as there are not enough suitable places locally.
4. Golf Lane has reach capacity for traffic coming and going at busy times a new school in the position suggested would mean far more traffic coming down Golf Lane and Fieldgate Lane which could not cope.
5. Because of a lack of places for children to play in this area, Fieldgate Lane at the moment attracts children playing as it is reasonably safe being a no through road. Climbing trees and being kids!! We do need places not continually full of traffic we seem to be creating one big housing development without much relief.

Having attended various meetings on the core strategy last year, I wanted to thank you for coming up with the alternative sites. These proposals go a long way towards addressing the very real concerns that so many of us raised about the prime arable land South of Harbury Lane.

The alternative sites distribute the housing around the Warwick-Kenilworth-Leamington area, integrating it into already established communities, with consequently less infrastructure impact. Nor are any of the proposed alternatives (so far as I am aware) prone to flooding in the way that the Harbury Lane South site is.

My final request would be that wherever possible you look to develop brownfield land first. I realise that this requires more effort in terms of ground clearance and decontamination prior to use, but the social benefits are correspondingly greater. Derelict eyesore sites are improved and brought back into productive use and agricultural land can continue in its prime purpose of feeding people with trusted locally-sourced products.

I raise objection to the inclusion of alternative sites in the core strategy:
1a, 1b Kenilworth Wardens Cricket Club & Training Centre Glasshouse Lane, Kenilworth
5 Hurst Farm Burton Green
6 Land at Baginton

My reasons, based on planning principles, are as follows:

1a, 1b Kenilworth Wardens Cricket Club & Training Centre Glasshouse Lane, Kenilworth

Development of this area would result in the loss of a valuable green space buffer for between the A46 and the main development of Kenilworth bounded by Glasshouse Lane. The proposal would place dwellings very close to this busy trunk road with consequential possibilities of noise and other environmental nuisance for the occupiers of dwellings. The proposed development would create an incremental ribbon of an urbanising nature along the line the A46 adding to the scale of existing and proposed housing development. Incremental pressures on infrastructure, particularly road access would be entirely unsatisfactory. An additional point is the loss of recreational playing fields.

5 Hurst Farm Burton Green

I was under the impression that the proposal area was greenbelt designed to segregate and separate developed land in Coventry and Kenilworth. Inclusion of this site in the core strategy would appear to be in direct conflict with a general thrust of the 1947 planning acts. Specifically, this area of agricultural land is valuable in delineating communities, and has a rural feel even close to the principal conurbation of Coventry. It would result in the loss of important green fields and associated ecological benefit, especially noting the wooded areas and habitats which would be lost. The highways infrastructure would be completely inadequate to service such a development and major highway works would be required, which in themselves would be unacceptable by creating an urbanising effect in this area (In fact the roads are currently strained to accommodate rat running at commuting times.)

6 Land at Baginton

The proposal would irreparably harm the character of Baginton which currently retains a distinctive village environment. The sheer scale of the development is entirely inappropriate to this location and loses recreational space for the public. I believe the land is in various ownerships, including Coventry City Council who have indicated their intention not to permit development, and it is therefore difficult to understand how this might be a realistic proposal. As for other alternative sites this is intensive development in the open countryside in direct conflict with national planning policies. Somewhat bizarrely, the area includes the ancient monument of the Roman Lunt fort and there is no doubt also considerable archaeological value in the surrounding areas which might be adversely affected. At the present time the future of Coventry airport is uncertain and it would be particularly unwise to consider developments in this area.

Green belt land in the Thickthorn area has already been identified as suitable for development.

A further allocation in this area would impose severe strains on the local infrastructure. Glasshouse Lane, Crewe Lane, Dalehouse Lane and A46 Stoneleigh and Thickthorn Roundabouts are heavily used now and struggling to meet demand. There are also serious concerns that large scale new development will bring about a re-occurrence of drainage problems that affected Ashow in the past.

There is a lack of public transport in South Eastern Kenilworth as none of the major transport routes run through this area.

I support the development of these sites, in their entirety, for the provision of 500 homes and 7.2ha of employment during the second phase (2016-2021). They bridge between sites K01 at Thickthorn and K17 at Southcrest Farm. Although in the green belt, the joint review describes them as being of low landscape value owing to previous development usage.

In my response to the original consultation I referred to the potential of other sites in the area for use as a retirement village. These additional sites would complement and support that idea.

This training centre, adapted and added to, could become the hub facility for the retirement village.

I remain of the opinion that the need for such large housing development in this area as imposed by Government remains unproven but feel that the following considerations should be imposed on all proposals.
1. No green belt land should be considered until all Brownfield sites have been fully developed. Look at the history of Developers in Coventry where a Brownfield site is started with a large number of homes proposed but once the developer has planning permission the numbers of dwellings are reduced and they move to the next site.
2. Numbers of houses on a site should be restricted to 100 homes to ensure that no single area is 'swamped' by a development and loses its existing identity.
3. Any of these additional proposals are more acceptable than the initial plan to build in excess of 3,500 houses on Kings Hill. Congratulations to a Council that can admit when a proposal is seriously flawed.
4. The main objective for any housing plans should be to encourage local employment and minimise the need to commute. Therefore WDC should consider small developments that are close to existing developments within its own area to meet this need. Sites that are close to Warwick, Leamington and Stratford should take priority for these reasons. Development closer to Coventry would only result in permanently 'joining' the two areas and resulting in the long term of a new Coventry and Warwickshire District Council?
5. The area around Warwick Parkway has never appeared as a consideration yet this has excellent access to a rail and road network. I understand that a reason given was the presence of Great Crested Newts? If this is the reason then King's Hill with its large number of ponds, Badger sets and ancient woodlands should not be under consideration?

I support this development (providing it is not green belt) as it would mean Warwickshire homes for Warwickshire people and not use already inadequate Coventry services. It would maintain the clear boundary between the two distinctly different communities.

I believe that the current plans for any large scale housing development is miss judged. An
alternative would be the development of several sites of smaller numbers with a mix of properties.
The proposal to develop properties of all (mixed) types on a single site is a mistake. Rather it should be possible to develop smaller numbers with a more coherent spread of property types.

We would have no objections to the use of this land for building more homes if the plans included the provision of additional educational facilities (namely primary schools to accommodate the additional children in the 1000 homes). The apparent absence of any such plans is alarming and incredibly short-sighted. As many parents of young children in the Warwick Gates/Whitnash/Heathcote area have recently experienced difficulties in primary school admissions, it would be ludicrous to even contemplate adding a further 1000 new homes into the mix. Any new housing development will inevitably attract young people, newly-married couples, and people wanting to start a family. This has been the story of Warwick Gates over the past ten plus years, and now many of the residents have primary school-aged children, who are expected to somehow be squashed into a few spare places within the existing local schools. This is bad enough, but to potentially increase this problem further would be disastrous to the community.

These seven sites are in addition to the 28 options already considered in developing the Core Strategy. It will be necessary for decision-makers to have a clear protocol for deciding which, if any, of these sites should be approved for development.

CPRE has serious reservations about if and when it will be necessary to provide more housing in Warwick District. We are well aware that the Panel Report on the West Midlands Regional Spatial Strategy has recommended a target figure of 11,000 new dwellings for the period 2006-2026. But the case for this is weak. It is a far higher rate of building than the District has seen in past decades. It meets no obvious need: there is not a high level of natural population growth, nor is significant in-migration forecast.

We are concerned that the housing proposals do not appear to be matched by robust proposals for providing employment; as a result they cannot be sustainable. Similarly there is no clear commitment to providing timely infrastructure of schools, health provision, shops, public transport and open space. The proposed sites now been consulted on

CPRE has serious objections to these proposals advanced by developers.

* All the sites are green-field countryside.
* All except Site 2 are in the West Midlands Green Belt.
* All would destroy valuable features of the environment
* All would destroy plant-life and habitats for animals.
* All would affect public footpaths through the landscape
* All would require new infrastructure
* All would increase traffic on surrounding roads
* All suffer from lack of public transport

In all cases careful consideration will have to be given to flood risk, availability of and access to employment.

This development, with the other planned developments for Kenilworth, could mean there will be up to 1000 new dwellings in Kenilworth. There is little to no spare capacity in the local Primary Schools and WCC would have difficulty in finding additional capacity for secondary school provision in the town.

The Highways Agency (HA) together with Warwickshire County Council (WCC) is currently undertaking an assessment of the implications of the strategic housing and employment allocations proposed in the Council's Core Strategy Preferred Options paper for both the Strategic Road Network (SRN) and the local road network. This work is expected to be completed by June 2010 and will help determing what, if any, measures to mitigate the impact of the proposed development options on the SRN will be requred. This work should also help to inform the development of the Council's Infrastructure Delivery Plan, which will underping the Core Stretegy.

Given the uncertainty about which, if any, of the alternative sites are suitable for development, the HA has been unable to undertake any such detailed assessment of the traffic impacts of these sites at this time but would wish to do so when there is greater clarity. For the purposes of responding to this consultation, we have, therefore, undertaken a qualitative assesment of each of the sites focussing on the potential impacts of each site on the SRN and their suitabilty in terms of sustainability.

Sites 1a & b, which are proposed for housing are located to the East of, but adjacent to the boundary of the built up area of Kenilworth. The A46 runs along the eastern boundary of the sites, however, we understand that access would be from the exisitng local road network, via Glasshouse Lane.

The proximity of these sites to the A46 could make them attractive places to live for people commuting to Coventry, Warwick and Leamington Spa by private car. The closest points of access to the A46 are the Stoneleigh Road Junction and Thickthorn Interchange. Both of these junctions currently suffer from congestion, which is expected to be exacerbated by any traffic generated by these sites. This is of concern particularly to public transport services and other sustainable transport infrastructure will, therefore, be required if this site is brought forward for development.

All six of the proposed alternative sites are considered to have some impact upon the SRN. It is expected that Site 2 would have the least impact, due to the relative distance from the M40, and the number of local services, amenities, and employment sites within the neighbouring areas. The remaining sites would have a more noticeable impact upon the SRN. Site 6 in particular has the potential to severely impact upon some sensitive locations along the A46. As set out above, we would, of course, wish to undertake further detailed assessment of the traffic impacts of the sites on the SRN when there is greater clarity about which, if any, sites are considered to be suitable for development.

Thank you for consulting English Heritage on the suggested additional six strategic sites.
Before any commitment to any strategic site is made there is an expectation that a thorough strategic environmental assessment/sustainability appraisal will have been undertaken and that evidence would have been gathered and applied to demonstrate the relative suitability, capacity, deliverability and consistency with matters such as regional (RSS QE 1, 5 and 6) and national planning policy has been determined. At present whether or not this has occurred is unclear. In this respect we refer you to our previous correspondence of 25 September 2009, our specific comments relating to the evidence base and also to the recently published PPS5 and its associated good practice guide.

Please note that English Heritage considers that this apparent shortcoming is fundamental to the soundness of the Core Strategy.

In addition to this generic maxim please find an initial observation on each site based, unfortunately, on a rather crude desk top consideration.

Site 1 -Kenilworth Wardens Cricket Club and Woodside Training centre
The evident significance of the adjacent Stoneleigh Abbey and designated Glasshouse
Roman settlement and the potential for further archaeology should be carefully considered.
The specific function of the green belt in the separation of settlements and providing a natural setting to historic places should be acknowledged where relevant to all these sites.

Support - if building on this 'alternative site' option results in less housing development in the land to lower Heathcote Farm, south of Harbury Lane, Land at Europa Way, Land at Woodside Farm then we are in favour of this development.

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

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

Object