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.

Baginton airport may still be considered as a potential life line to the industry sector within the West Midlands. Although there is still the potential for over development of both the airport and the surrounding area. A small development of properties supporting the infrastructure of the airport should be possible. It is with bitter experience that we have seen a large increase in through traffic and high speed driving within the local road network leading to the airport, and sufficient control needs to be in place to in order to police this aspect.

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.

No surplus capacity here at Primary or Secondary School phases. Does part of this refer to the South of Finham development from Coventry overspill? This will have implications already made on the existing proposal.

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.

This site compromises approximately 97ha of land at Baginton. The site is located to the west of Coventry Airport and is bounded to the North by the A45 and to the west by the A46. We understand that if this site were to come forward for development it would compromise a mix of uses including residential, employment, airport uses and leisure.

The site lies within close proximity to three key SRN junctions: A45/A46 Toll Bar End; A45/A4114 Stivichall Interchange; and, Stoneleigh Road. As set out above, both the Stivichall Interchange and the Stonleigh Road junction and their links currently suffer from congestion. Additionally, the Toll Bar End roundabout is currently the subject of a HA improvement scheme aimed at reducing congestion at the junction.

We are concerned that the additional traffic generated by this site could adversely impact on the operation of both the Stivichall Interchange and the Stoneleigh Road junction and their links. We are also concerned that additional traffic passing through the Toll Bar End junction could potentially offset the capacity improvements brought about by the improvement scheme.

There are currently limited public transport services within the vicinity of the site, and the closest amenities and local services are located north of the A46 in southern Coventry. If the District Council were to consider this site suitable for development, the HA would expect to see it supported by a comprehensive package of public transport and other sustainable transport measures aimed at reducing private vehicle trips.

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 6 - Land at Baginton
This substantial area of proposed development includes designated and undesignated historic assets of great significance. Before any principle is established a specific historic environment assessment must be undertaken to fully understand the landscapes special historic interest, the locations of particular historic significance and sensitivity and the areas subsequent capacity to accommodate change and where this might take place and what form it might take.

It is important to understand the value of the historic landscape as a whole, its setting and integrity and not just the individual cultural highlights.

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 6 - Land at Baginton
The Trust believes that this proposal is at present too large to draw any meaningful conclusions at this time. Some assessment of the site has been undertaken in the northern boundaries during the original site assessments; however, further habitat assessment and protected species data will be required to gain a comprehensive view of the ecological and environmental constraints of this parcel.

At this stage the Trust would like to outline the River Sowe as being of primary concern. A sufficient buffer for this pLWS and essential wildlife corridor will be necessary and would likely influence development to the west. The sections of woodland and semi improved grasslands should also be assessed for their biodiversity value and be retained wherever possible.

Given the size of the parcel it is likely that GI improvements will need to be incorporated throughout. This should take advantage of the Sowe corridor as an optimal starting point and then consider adjacent GI objectives and opportunities within Warwick District, Rugby Borough and Coventry City alike. Once further ecological information is available, Warwickshire Wildlife Trust would welcome the chance to discuss these constraints and opportunities with the Local Authority further.

Questionnaire response.

Support for land at Baginton. Lenco Investments promoting land south of Baginton which could be delivered in isolation as an addition to alternative provision elsewhere or as part of a wider development area. Little weight should be given to the locational guidance within the RSS Panel Report as there was no discussion of alternative sites to Finham.

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.

Support this site as suitable for development.

Development infringes the Kenilworth Gap from Coventry.

This land should not even be considered for development by Warwick or Coventry Councils until such time as their brownfield sites are at full capacity - as determined by objective, verifiable appraisal - then the Baginton site offers an excellent eventual opportunity for housing or possibly mixed-use development.

The real viability and attractiveness of this site will be determined by the future operations of Coventry Airport. Few will wish to live near a site that is a working cargo airport, particularly if this airport manages to renegotiate a licence for unrestricted night-flying operations.

I hope WDC will monitor the financial fortunes of Coventry Airport and will apply pressure if it becomes apparent that Coventry Airport has no financially viable future. Coventry Airport remaining in operation would effectively deny Baginton becoming a good site for WDC's future housing provision and would make WDC's drive towards high quality farmland and extremely attractive and much-cherished sites like King's Hill more likely. I'd like to remind you that -among other objections - 3700+ people signed a petition against development of King's Hill.

A failure to fully seize the far-less damaging option of development of Baginton because of airport noise from Coventry Airport, possibly through the night, would be a tragedy.

Much of the site is brownfield, of poor agricultural quality, little-visited by walkers and cyclists, and has excellent road links to the A45, and the A46. Development of the King's Hill (south Coventry) site would cause immense problems to an already overburdened road network and to local, barely-existent amenities.


A great deal has been made of the sub- Baginton Airport sand and gravel reserves and the possible restriction or even prohibition this offers on construction. The relatively shallow quarrying necessary should offer no such serious restriction, and would also generate large amounts of money for Coventry / Warwick Councils, and substantial employment in their removal. The developers proposing building on the site say that a rolling programme of house and other construction on the site would be possible, even with large gravel extraction.

Some Coventry local councillors have suggested that the site would become the 'biggest landfill site in Europe' if quarrying went ahead. Unless there were plans to raise an artificial hill for enclosing the landfill at this site, then gravel and sand extraction would create holes far too shallow to be seriously considered for landfill.

Much or all of the gravel extraction and construction traffic for the site could be routed along Rowley Road and straight on to the A45 / A46 and away from Baginton village.


There is no ancient woodland and few other areas of great ecological or archaelogical sensitivity that would be damaged by development of the site. There are wetland areas which should be avoided for ecological protection and flooding avoidance and here are the Lunt Fort and Baginton Castle, but these are a relatively minor part of the whole site, and their avoidance would still leave a considerable area.

5


6
The RSS has enjoined Coventry and Warwick Councils to work together in cross-border communication to return sites such as King's Hill for housing. Could I ask that the same spirit of cross-border co-operation is applied to monitoring the viability of Coventry Airport, and in deciding whether keeping it open is providing the best deal for the people of south and east Coventry, many of whom are threatened with vast WDC or other housing developments that the Baginton site could accommodate, but which would not be so attractive to would-be homeowners with the presence of the airport and its night-flying operation.

7
Insufficient consideration and and no satisfactory explanation has been provided by WDC as to why sites such as Warwick Parkway have been considered for WDC 2010 - 2026 housing provision. One possible reason I have heard advanced is that this site has considerable numbers of great crested newts whose translocation would incur considerable expense for developers and possibly for the council. The same situation obtains in King's Hill, where there are many ponds with very great numbers of great crested newts, among much other wildlife.

8
There are few, if any, ponds, and far fewer ancient hedgerows in the areas of the Baginton site where development would be most sensible i.e. away from the marshy areas on the river floodplain. Less money required in filling them in than in the King's Hill site, and less money required for wildlife harm mitigation.

9
Overall, developmment of the Baginton site - even with gravel and sand extraction - could be done with far less in-your-face intrusion for the people of Baginton than for those affected by the King's Hill site. The noise, disturbance and building-time and subsequent traffic levels for the people of Finham would be pretty-well nightmarish. Come and have a look at what we have to deal with already, most especially at rush hours - you're welcome.

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.

Objection

Represents landowners of the site who feel it is the right location to deliver a comprehensive and sustainable mixed use scheme of 3,500 dwellings. There will be enough land to also provide:
Protection around the village of Baginton.
Protection/enhancement of Scheduled Ancient Monuments
Considerable areas of open space, including open space interspersed throughout the development.
Additional open space for the airport safety zone and within the noise contours.
Sufficient land to facilitate highways improvements.
The scheme would also provide affordable housing and offers considerable scope for not only providing good access to the highway network but also to enhance airport access and improve traffic flows for existing local traffic.
It would address environmental issues such as the 'cleaning-up' of the Rock farm site which is believed to be contaminated and waste and emissions.

Object

Support and Objection

Object

Object

Object

Object