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.

How many dwellings could this site take? This development may require additional Primary School Capacity (new school/s potentially) as there is little or no spare capacity at the local schools. There is some secondary school capacity at present but again it depends on the number and make-up of the proposed dwellings.

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.

Site 4 lies to the North of, but adjacent to the northern fringe of Warwick. Part of the site is a registered park and garden for Guys Cliffe and we understand that if the site were to come forward for development, it would include low density housing and open space.

The plans for the site clearly show that it is bisected by the A46 and that any primary access would be directly from or close to the A46/B4115 Warwick Bypass junction. The A46 would create a physical barrier, which would reduce site permeability meaning that any development north of the A46 could not easily travel southwards without passing through the SRN junction. Given the potential size of the development, the proximity of the SRN and the lack of site permeability, we consider that there is likely to be a significant impact on the A46 and the A46/B4115 junction.

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 4 - Loes Farm, Guy's Cliffe, Warwick
You should ensure that thorough evidence is applied to determine whether the proposal would adversely affect the significance of the designated historic landscape and its setting including key views in and out. The direct and indirect impacts of major new development on the individual components that determine the relative value of Guy's Cliffe in total should be understood.

English Heritage considers that the well preserved areas of ridge and furrow should certainly be regarded as of national importance and preserved as a consequence, see:-
http://www.english-heritage.org.uk/upload/pdf/turning_plough.pdf?1267377944

Nevertheless and without prejudice to the above principle, should a robust assessment of the landscape establish that some form of development may be appropriate there should be an expectation that change will lever an enhancement of the historic environment in accordance with PPS1 1(ix) and PPS5.

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.

Site 4 - Loes Farm, Guy's Cliff, Warwick
This site forms an extension to original site Woodloes Park/ Hintons Nursery. The site consists of a variety of habitat types including plantation woodland with veteran oaks, species rich hedgerows, ponds, scrub and semi-improved grassland which supports yellow-meadow ants and the presence of ridge and furrow. This mosaic of habitats has been highlighted as key to the biodiversity value of the site, and whilst further survey work is required to assess the value of the grassland and woodland, it is likely that there will be significant constraints to the developable area. The Trust supports the conclusion made within the Warwick District Habitat Assessment, which states that the well established ecological features of the southern site are sufficient to make this parcel unfavourable for development. The sections to the north of the site are as yet un-surveyed and will therefore require further assessment to evaluate if this could accommodate sufficient development.

Questionnaire response.

Development of Loes Farm, Hinton's Nursery and North Woodloes would destroy the beautiful approach to the town and the agricultural land. It is a matter of conjecture whether the infrastructure would be able to sustain development. Area has suffered in the past due to development of Woodloes and the A46. Any further traffic would be absolute madness. Covenants restrict development of land. Loss of rare ridge and furrow landscape. Water run off from site would be enormous. Historic woodlands would be vandalised. Loss of jobs at Hinton's Nursery. Suggest development of Guys Cliffe farm as an alternative.

Object to Loes Farm, Warwick. Do not wish The Cottage to be included in this option. Not clear on where the demand for new housing will come from. The land is green belt and not all brownfield sites have been given sufficient consideration. Land is designated registered park and garden and housing would destroy attracitve access to the town. Insufficient infrastructure, particularly roads. Area of biodiversity significance, particularly for birds, wetlands, bats and moths. Loss of historic farm landscape and Hinton's nursery.

The result will be more urban sprawl with the loss of Cubbington village identity. The surrounding roads are already at capacity at certina times of the day.

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.

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.

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