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 5 - Hurst Farm South, Burton Green
This site is located directly to the south of the original site known as Westwood Heath. Whilst the site consists predominantly of agricultural land, it is situated in the centre of four semi natural and plantation ancient woodlands. Three of these woodlands are also county important Local Wildlife Sites (LWS). The fourth to the south, known as Rough Knowles Wood is a pLWS. Whilst the woodlands are fragmented to a certain extent, it appears that they are well connected by a framework of hedgerows. These hedgerows will have an important role in preserving the connectivity and integrity of these ancient woodlands and therefore will need to be retained or at least replaced within any development proposal.

The proposed area is large (99.9 hectares), however a significant proportion of the area will be needed to enable the provision of sufficient buffers (50 metres) and connective green links between the woodlands. This will make significant constraints of the developable area. Furthermore, a watercourse runs throughout the site which will ideally need to be buffered and will provide further constraints to the development. A full habitat assessment and a data search will therefore be required to enable a full indication of the constraints to this development parcel. However, given the potential impact of the proposed development on the connectivity of the ancient woodlands, the Trust would most likely advise against the selection of this development parcel.

Questionnaire response.

Gordon Brown's target for 3 million new homes between 2007 and 2013, equalling 230,000 pa has not been met over the past two years by in excess of 200,000, if we assume 4 people to each house where are these homeless 800,000 people hiding? Construction is the 2nd biggest GDP contributor and that is why GB was supporting it to try and keep his so called unparalleled and sustained period of stable growth myth going. If we continue to try to build are way out of a recession we are just squeezing the tooth paste tube since eventually there will be such an excess of housing stock that domestic construction will grind to a complete stop. We already have the highest housing density and the highest levels of home ownership of any European country by far.
It is time planners and councillors considered their actions in the wider context, this may mean that we need a different calibre of individual in these positions but so be it.
As for longevity, so many of the aging population live alone in isolation in properties far bigger than they need, why not come up with attractive and innovative solutions which encourage them to co-habit and support each other, releasing funds for them and housing stock for the rest of us.
Finally, social fragmentation, the erosion of the extended family and consumerism have led to immense under utilisation of capacity within the domestic housing market, with many more rooms in houses than are actually occupied. If we want to live longer, increase our population and consume more then something has to give. The earth has finite resources so if we want to take more with one hand we need to compromise on the other.

Centro have no land interests in any of the proposed alternative sites, however we would like to draw you to the attention to the proposed High Speed Rail Line. Proposed Alternative Site 5 ‐ Hurst Farm South, Burton Green may be affected by the route.

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.

I oppose development at Hurst farm and Baginton because

1) this is building on green belt and Greenfield land - national policy PPG2, requires that greenbelt should be used for building only in exceptional circumstances. In the broader Coventry area (which this is in) , no exceptional circumstances have been shown. Quite the reverse. There is ample brownfield land (as demonstrated in the Coventry SHLAA) to accommodate natural growth in the area for the plan period (if you estimate Coventry's natural growth at 12-1300) then there is demonstrated capacity for up to 22,000 homes on brownfield land. Removal from the greenbelt is not justified.
2) Adequate alternatives - building on available brownfield land, or on the failing Coventry Airport site, has not been adequately considered nor have reasons been given as to why they were not selected. In so far as Coventry, Solihull and Warwick have jointly planned for the needs of the region, brownfield sites within Coventry should have been considered if Warwick district council has a need for more homes than it can accommodate on brownfields. These are reasonable alternatives which should have been considered under the SEA directive.
3) National sustainability policy explicitly says that brownfield land should be preferred to Greenfield development.
4) The development will have a very damaging impact on wildlife, amenity, biodiversity. Protected species (badgers, bats, great crested newts, and water voles) will be harmed. Bird species on British Trust for Ornithogy Red conservation status will be damaged. Much loved ground nesting birds, such as skylarks, will be exterminated by swarms of cats and children..
5) A major development on the urban fringe, of a large suburban development will promote commuting, which is contrary to national climate change policy. The only sensible place, to put major developments, is in the city centres, not on the edges of cities. - this is consistent with the 'urban renaissance' policy in the regional spatial strategy. Building more suburbs - so called sustainable urban extensions - is a cynical mis reading of this policy.
6) This will promote urban sprawl and cause Coventry to merge into Kenilworth, Meriden, Balsall Heath and Solihull - reducing the narrow gaps that currently exist.
7) It will damage the prospects for city centre regeneration, by providing suburban homes on the eges.
8) It will damage the identity of a historic town, Kenilworth, with Kenilworth castle in particular facing a tide of development where historic views still remain - from the tower, you will now see a horde of new homes, just a few kilometres away. - not what Inigo Jones or Queen Elizabeth would have seen.
9) The area contains numerous protected historic hedgerows

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

Object

Object to Hurst Farm South, Burton Green

Object

Object

Object

Object

Object

Object

Object

Comment

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.

We would like to register our opposition to the proposed development of housing in the Site 5 i.e. Crackley Lane, Cryfield Lane and Westward Heath area.

Having lived in Crackley since 1957, I was very concerned to learn of the submission from the landowner of Hurst Farm.

I believe any development on this site in particular, would have far reaching consequences, with its close proximity to Burton Green, Warwick University and Crackley Wood. Furthermore, the vital Green Belt between Kenilworth and Coventry would be greatly reduced, and inevitably lead to further developments, making it increasingly likely that Kenilworth would eventually become just a superb of Coventry.

You will already have on record my views on this picturesque countryside and the importance of the vital green buffer between Kenilworth and Coventry through my previous responses, plus my suggestion and vision of a special protected area, which the Green Belt status once had. (I say once had, as it would appear that the Green Belt affords little protection from development, in the wake of this Government's huge and unproven housing demands.)

Now on top of all this pressure on our ever decreasing countryside and Green Belt, we are now faced with the prospect of surely the mother of all threats, with the proposed High Speed 2 railway line, which would effectively 'ram-raid' its way through the beautiful Warwickshire Countryside, including the Crackley gap, that we've fort so long to protect.

I hope Warwick District Council will do all it can to fight our corner, and hopefully, the incoming government will see sense and revise the route (or even cancel this expensive, wasteful and highly destructive project) and avoid the horrendous damage to our towns, villages and countryside.

1: Conurbation
Development of this site would represent a substantial advance in the closure of the 'gap' between Coventry and Kenilworth and further progression towards a 'Linear City' - a potential grisly urban sprawl extending from Nuneaton in the north to Stratford in the south.
Further, the proposal represents the antithesis of the principles set out in the 'Executive Summary' on page 1 of the WDC Core Strategy, June 2009; specifically the requirements ".. to avoid incursion into the West Midlands Green Belt... in order to maintain separation between towns and villages" and "...to protect the most important areas of Green Belt that separates the town (Kenilworth) from the urban area of Coventry to the north." It would also adversely prejudice Warwick University's future expansion opportunities (see p2 'Preferred Options').

2: Loss of Amenity
Development would result in the loss of another green field site/ agricultural land - an amenity and 'buffer' much valued by residents and wildlife.

3: Inadequate Infrastructure
Current peak hour traffic congestion demonstrates the inadequacy of the local road network.
The consultant Engineer's traffic report commissioned by Warwick University in support of its planning application for expansion classifies much of the existing infrastructure as being 'critical'. Further, it considered the 40% expansion of the campus in isolation and without regard to additional traffic attributable to proposed nearby major schemes [doubling the size of Tesco (+5 shop units + 60 flats), Canley regeneration (+3500 houses?), off-campus W.U residences (+1000 units?), Westwood Business Park, additions to science park etc]
CPCA believes that the modest road modifications planned as part of the university expansion are sufficient to sustain growth of the campus to the scale proposed. They will not, as is claimed, effectively "...mitigate the impact of traffic congestion in the area..."
Superimposed on the above is the threat of further huge increase in traffic attributable the possible development at Hurst Farm: it is neither feasible nor acceptable.
If this development was to proceed then inevitably there would be a further large draw of traffic from Stoneleigh/ Gibbet Hill Road and the A45 to the site. Congestion on Gibbet Hill Road/ Stoneleigh Road will force traffic to use Westwood Heath Road, Kirby Corner Road and Sir Henry Parkes Road to access the A45 and the city centre. Extensive peak hour gridlock is readily predictable.

4: Lack of Transparency
CPCA believes that, instead of generalisation and before being invited to comment, residents should have been advised re:
- The probable scale of the development (possibly 3000 houses?)
- The type and scale of employment development envisaged
- The approximate number, probable size and category of house units
- Any limit on height. Number of storeys (the site is adjacent to W.U)
Similarly, whether or not it is intended to preserve character by conserving e.g. Whitefields Coppice and Roughknowles Wood.
Intentions are not known: WDC has a duty to inform - it is not for the public to guess

5: Affordable housing content
Hurst Farm is an edge-of-city site. Coventry C.C's requirement for affordable housing (i.e. housing association, shared equity etc) is 25%; WDC apparently insists on 40% - shortly, we are advised, to be increased to 50%.
A higher proportion of affordable housing in rural districts is to redress a perceived shortage and to enable the lower paid, to continue to live in their locality. We consider the converse appertains to this site, located as it is adjacent to Coventry which, we believe, has a surfeit of such units - but a dearth of 'aspirational' housing.
We detect the intention to play the 'numbers game' with a high % of affordable (small units, low space standards, high density, low specification) housing to achieve government targets whilst the disproportionate effect on traffic/ congestion is conveniently over looked.

6: Purpose
The stated purpose of this development is "...for future housing and employment development to meet the District's long term needs".
We consider the Hurst Farm proposal fails this objective. It does not provide for the District's employment needs; it does not provide affordable housing in rural areas; it is an attempt by WDC to divest a large part of its housing commitment onto Coventry's (we believe disproportionately large and self imposed) numerical obligation.

Warwick University which abuts this site is service by a rural road designed for the horse and cart. The issue of an inadequate infrastructure has never been addressed and despite the consultant's stated concerns the planning authorities approved a 40% expansion of the campus. Disturbingly that application, like those for other major developments in the locality (para 3 above) appear to have been considered each in isolation by the planning authorities, without regard to juxtaposition, adequacy of infrastructure, cumulative effect, or impact. This matter is currently the subject of formal complaint to CCC, WCC and WDC.
Further, we believe that, whilst approving W.U's expansion, WCC and WDC have effectively vetoed associated infrastructure proposals which would have alleviated - including 'Sprint' the planned rapid transit system linking Nuneaton/ Bedworth - Coventry - W.U - Kenilworth - Leamington, similarly park and ride facilities remote from campus and a possible road link with the A46.
An illogical prepossession with numbers appears to have overridden rational consideration of the essentials of demand/ need for employment development/ infrastructure.
CPCA objects to the development of Hurst Farm for the reasons stated.
CPCA requests that this letter is copied to each member of any Council Committee prior to it considering any proposal to develop the Hurst Farm site.

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