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.

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.

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.

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.

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.

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 Evidence Base.
Page 20 of PPS12 states that the Core Strategy must be justified and goes on to say that the document must be founded on a 'robust and credible evidence base'. To be robust and credible, the information must be up-to-date and this may be tested when the Core Strategy comes to the examination in public stage.
A detailed appraisal of all options in respect of the natural and historic environment needs to be undertaken in order to provide a robust evidence base for decision-making.
Natural England welcomed the Warwick District Habitat Assessment carried out by the HBA project as part of the evidence base for the initial tranche of sites in the core strategy preferred options consultation. However, the same level of detail has not been available in full for the alternative sites proposed for the current consultation in order to enable a full appraisal of each option. We recommend that the HBA habitat assessment is extended to include all the proposed alternative sites. In addition to this we recommend that species, geological and landscape data should be screened from existing Warwickshire Local Record Centre data to complement the habitat data and the additional survey work that has been recommended within the Warwick District Habitat Assessment, such as potential Local Wildlife/Geological Site criteria assessments are undertaken prior to site selection.
Notwithstanding the points above, in terms of proximity to statutorily protected sites our initial comments are to note that Loes Farm, Guy's Cliffe is within 1km of Guy's Cliffe geological SSSI and Land at Baginton is about 2Km from Ryton and Brandon Gravel pits SSSI. Any possible indirect impacts should be evaluated.

Habitat Regulations Assessment (HRA)
As stated in our response to the core strategy preferred options consultation on the 24th September 2009, it is strongly recommended that Warwick District Council produce a screening report as soon as feasible regarding the possible requirement undertake a Habitats Regulations Assessment (HRA) of the draft core strategy. This is a requirement of regulation 85 of the Conservation (Natural Habitats &c.) (Amendment) Regulations (2007) which applies to the preparation of land use plans. The purpose of the assessment is to consider if the Core Strategy is likely to cause any significant adverse effects on the nature conservation interests of statutorily designated European protected sites in the vicinity of the District, alone and/or in-combination. Natural England will be happy to advise on how this screening should be undertaken. We attach a report detailing possible threats to the conservation objectives of SAC/SPAs in the West Midlands that may be of assistance.

Despite not being local experts of these sites and having mainly only the limited information provided, we do feel that we can use our Coventry experiences to offer views which may be of use.

1. The 6 submitted SHLAA Sites.
As far as the 3,500 proposed King's Hill Coventry's 'over-spill' is concerned, this could all be better accommodated within any of these 6 SHLAA sites with new residents benefiting from an improved viability compared with that possible from the King's Hill site. We have used your judgement classifications of 'Support' and 'Comment' to signify our view that although Site 5 and Site 6 would be better than King's Hill, they are less suitable as they are further away from the established housing in WDC. (As stated earlier, we do not believe that this overspill is required but our comments could also apply to WDC's own housing quota.)

Sites 1a & 1b, Kenilworth. Support.
Capable* of some 600 dwellings with road access onto Glasshouse Lane and close to established community. Woodside has some fine old trees which deserve appropriate consideration. (* Housing capacity taken as area in hectares x30).

Site 2, Campion School/South of Sydenham. Support.
Capable of some1550 units, limited by railway line and apparent watercourse to east and thus currently separated from established community but could probably have road access onto roundabout by hypermarket and bridges at Church Lane and Fieldgate Lane with a possible link to Chesterton Drive. The prospect of a new school seems attractive. This site seems to offer considerable potential and with some investment would be suitable for use.

Site 3, Glebe Farm, Cubbington. Support.
Capable of some 1,600 units and would fit into an existing established community and infra structure but would result in a loss of the open space view to existing residents and require improved access. Paths should be retained. Needs to seek views from existing residents but could be made to work.

Site 4,Loes Farm, Guy's Cliff, Warwick. Support.
Capable of some 1,290 units. Close to established Warwick and it's infra- structure. Some existing road access but A46 Underpass may have to be enlarged to take traffic. Cannot derive detail from printed map but there may be an inherent water drainage problem which probably has received attention. Otherwise it seems a good site but Warwick Parkway seems better.

Site 5, Hurst Farm South, Burton Green. Comment.
Capable of some 3,000 units. Close to the Coventry border but separate from an established WDC community. Physically close for Warwick University and is close to a recently enhanced road system. It is thought to be in the Green Belt and part of a buffer zone around Coventry. The views of the local residents should be considered.
However, it would seem ideal for accommodation requirements for Warwick University students in that the university has its own infra structure and would not need to have to introduce the wider range needs expected of a mixed community. Its use would restrict the sprawl of the university and allow more of the existing housing in the area to return to community use.

Site 6. Apparently capable of some 11,900 new housing units. Comment.
This is a very general site submission in that it covers a large area and FRA is more aware of the nature of the land and its characteristics, hence the term 'apparently capable' above. The actual new housing capacity is expected to be considerably less. Nevertheless, Site 6 does have much to recommend it for housing development both for the 3,500 unit Coventry over-spill along the WDC border (it is much more suitable than King's Hill) and WDC's own new housing allocation.
There are good road links including the A45 and A46 and links to M6, M69 & M1.
It may have an operating airport. There is an established community at Baginton with a Village Hall, children's equipped play area and church, etc. There are employment possibilities close to the proposed site and Coventry is relatively nearby. There would need to be an enlarged infra structure but new housing would be joining an established community rather than being alone on King's Hill.
There are aspects of the mapped area which must be respected and preserved; these include the Lunt Fort and Baggots Castle. There are areas which are regularly flooded and drainage may present problems.
The uncertainty regarding the airport and the mineral deposits relatively just underneath it should not be a deterrent to development. Mineral extraction has occurred some 40 years ago to the east of the site and the land stabilised such as to be suitable for building. Attention could be directed towards these areas but if such action is not opted for, then at least the experienced gained could be applied in the form of a rolling programme of low depth mineral extraction being planned and the recovered land being stabilised and returned for building purposes. The other advantage of using such land is that there are fewer relics to retain.
The Baginton proposal has much to recommend it but effective consultation with the local residents will produce the best result.


2. As far as general approaches are concerned, it would seem better to put new housing within or close to established WDC communities, preferably using Brown field sites and limiting the size of each development say to 25 dwelling units so as to aid assimilation. Advantage should be taken of the existing infra-structure including transport and employment.


3. Potentially there would seem to be more such sites and while it is more complicated to plan for these smaller developments, they do seem to offer more chance of a better outcome. The large site developments may be easier to organise and supposedly result in a lower unit price but they do little for community spirit.


4. One site which does seem to be ideal for development and yet has not been raised is that around Warwick Parkway with its excellent transport links and its closeness to Warwick itself.

5. WDC may wish to consider meeting its housing requirements and local needs by also encouraging some initiatives in its smaller communities or perhaps even starting a new town.

Object