In principal Sport England objects to this allocation. I would refer to my comments on Policy DS6.

Reasons for Objection

The Kenilworth Society considers that the
The designation of H09 as a housing site is unsound because:
a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. Kenilworth School, Leyes Lane , was not in the list of housing sites in the "Revised Development Strategy" that was published for public consultation in June 2013.
b) The Sustainability Appraisal of Site H09 is inaccurate and unsatisfactory. Appendix V page 3/87of the SA states that
"...there is only a very low/ low risk of surface water flooding." This is incorrect. The Environment Agency website's map of "Risk of Flooding from Surface Water" shows approximately one third of the site as being at some risk of surface water flooding. Parts of the site are shaded dark blue, indicating that they are exposed to a high risk of flooding. Plans to put dwellings, roads etc on this site would have to address this problem, and also the dangers of acerbating drainage problems offsite. Much of the watercourse (the Millbrook) into which this Kenilworth School site drains is coloured in dark blue on the Environment Agency's map of "Risk of Flooding from Surface Water".

In the opinion of the Kenilworth Society the Sustainability Appraisal's formula for dealing with drainage - "Mitigation is offered to a certain extent by the NPPF which requires that new development should not increase the risk of flooding elsewhere" - is inadequate when applied to sites that pose serious and specific problems.

c) As said in our submission on Site No. ED2, we do not believe there is adequate justification for moving Kenilworth School to Southcrest Farm. We understand that operating on split sites creates problems for Kenilworth School, but the Southcrest Farm is not the only, nor necessarily the best option. The proposed solution appears to be driven by the county Council's desire to raise money from the sale of land for housing rather than the needs of the local community.

see attached

Response of Kenilworth Town Council to the Warwick District Local Plan Consultation
June 2014
General
As the District Council will be aware, the Town Council has drafted and continues to refine a Town Action Plan which makes detailed proposals for the development of the sites proposed in the Local Plan and which the Town Council hoped would be incorporated into the Local Plan. The Local Plan deals with many of our requirements in general terms but we feel that this is not in sufficient detail and would press for the incorporation of the detailed requirements set out in our Action Plan into the Master Plans suggested for each main site.
Subject to this general comment, these responses are delivered on the basis required by the Consultation as to whether the Plan is:
a) Sound
b) Deliverable
c) Sustainable
d) Followed proper process.

Housing Growth (Policy DS6)
Kenilworth Town Council has responded to all of the previous consultations on the Plan on the basis that it must not only provide for the specific needs of Kenilworth itself but also has to bear in mind that the town is part of the District and must reflect the amount of housing necessary across the District. As such the Town Council has appreciated the necessity to accept more development than is needed on a parochial basis as part of the larger community whose benefits we enjoy.
However the recent ONS forecast of population growth has indicated that the actual needs of the District, which we had accepted, may now have been superseded as it indicates a significantly smaller increase in need for the District as a whole. In these circumstances we feel there is a requirement for those figures to be investigated, and if a lesser figure is indicated then this must lead to a re-evaluation of the needs of the District as a whole, including Kenilworth, which saw an increased share in the latest version of the Plan.
As the forecast for Coventry has increased, we are concerned that the pressure may return for over the border development. However the analysis for the previous RSS showed that even with the revised figures there will be spare capacity within the Coventry boundary and therefore any cross-border pressure should be firmly resisted by the District Council. In particular there must be no development for the benefit of Coventry on Green Belt land in Warwick District, when development on Green Belt land in Coventry is not being considered.
The Town Council's view was that the development within the Town at Thickthorn should cease at Rocky Lane and should not include the Crackley Triangle. In the light of the new figures these two areas may need to be revisited.

Crackley Triangle (Policy DS11 Ref H05)
In relation to the Crackley Triangle, it is the Town Council's view that this is a very sensitive area, which although not within the Green Belt, is very much part of the barrier between Coventry and Kenilworth where the Green Belt is extremely narrow. Further, it is likely to be devastated by HS2 and as such the barrier against coalescing with Coventry will become almost meaningless unless further protection is given.
No consultation took place in respect of this area by the District Council in its consultations on the Plan. Whilst the Town Council's views were known as a result of it's draft Action Plan, this area was not referred to in the public consultation, so the public's views have not been ascertained.
Further, we do not believe that this area is deliverable because it has no access (except on to a narrow bridge with a difficult configuration which cannot be widened or straightened) and as such is not really safe or sufficient even for current traffic.
We feel therefore that this area should be revisited as to whether there is need, whether it is deliverable and whether due process has been followed.
Note: There is a current outline planning application for this site to which the Town Council has objected on access and drainage grounds.

Kenilworth School Relocation Site (Policy DS11 Ref ED2)
Whilst the Town Council acknowledges that it was likely that Kenilworth School would find it necessary to relocate onto a larger site because of current numbers, coupled with the increase likely to arise as a result of the new developments within the Town, no formal consultation has taken place upon the proposed move, or the site concerned. The site proposed is within the Green Belt and as such requires very careful consideration including enquiry as to the need for relocation, its siting and the deliverability of this relocation, particularly from a financial stand point.
Kenilworth School Sites in Leyes Lane and Rouncil Lane (Policy DS11 Refs H09 and H12)
The Plan now provides that the possible move of the Kenilworth School makes it's existing sites in Leyes Lane and Rouncil Lane available for development. This however has also not been previously proposed and again no formal consultation has taken place. Whilst the main site in Leyes Lane is within the Town envelope, the Rouncil Lane site falls within the existing Green Belt and therefore again must meet the tests appropriate to sites being taken out of the Green Belt. The Town Council is concerned whether the Plan is sound, having regard to there having been no formal consultation in regard to either sites.

Thickthorn Sites School Provision (Policy DS12)
In relation to the sites at Thickthorn it has always been the Town's contention that a development of this size must provide for a primary school within the development. The object of siting it within the development is to encourage families to walk to the School and thus decrease the use of transport and also promote a healthy life style. The proposal that this new primary school should be on the Southcrest Farm site is completely contrary to this logic and would lead to additional and unnecessary traffic movements, thus making it unsustainable.
It also could result in some of the existing primary schools being closer to the residents of Thickthorn than the one provided by the plan for this development. This would in our view make the Plan in this regard unsustainable in these respects.

Sports Fields (Policy HS4 and HS5)
Whatever the final agreed extent of housing and employment development at Thickthorn, there will be a need for some relocation of the existing sports facilities. Although there have been discussions, we note that no relocated sports sites feature in the Local Plan. Whilst we appreciate that alternative sites need not be identified until the planning permission stage we wonder whether there should have been some indication given here in order to ensure deliverability.

Local Plan Policies Maps (Maps 1 and 5)
We note that the Great Mere of Kenilworth Castle, a nationally Listed II* Historic Park and Garden is not identified on the relevant Policies Maps 1 and 5 although Policy HE4 clearly states that such areas are defined on the Policies map. We have not checked to see whether this serious omission is repeated for any other locations.

Retail Area Map (Map 5a)
We note and approve that the Kenilworth Town Centre Map 5a has been amended to include the Waitrose store within the Retail Area but note that the actual building has not been added to the map and the car park entrance has not been updated. There is also a missing building at the North end of Abbey End where the Almanack and flats are. Although the houses in Harger Court remain outside the Retail area, the houses in Harger Mews have been included together with houses in Bertie Road. We feel the boundary should exclude all these houses unless there is a specific reason to include them. When the map is corrected it would be useful to update the Wilton Court site development as well, although that is not within the Town Centre boundary.