I have no objection to the development of this area but the proposed entrance to the development from Common Lane is not a practicable suggestion. Entry and exit into the development will create chaos for all of the residents in Common Lane, Highland & Inchbrook roads particularly in the morning rush hour. The current proposals will make it virtually impossible for residents of Woodland Highland and Inchbrook roads to exit or enter into Common lane. I use the exit from Highland road on a daily basis and in the morning rush hour the traffic is currently backed up from the Coventry Road to the Railway bridge daily. Similarly there is a daily back up from Highland Road to Dalehouse Lane already. 90 houses will add an extra minimum of 100 vehicles daily using this single track entry/exit. Common Lane is a bus route for the local buses

Reasons for Objection

The Kenilworth Society considers that the designation of this site as an "Allocated Housing Site" is unsound because:

a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. It was not included in the Revised Development Strategy published for public consultation by Warwick District Council in June 2013. This is a sensitive site, and one that will be difficult to develop. The Crackley Triangle is part of the narrow greenfield gap between Kenilworth and Coventry. Therefore it is important that members of the community are given the opportunity to influence this part of the Local Plan

b) The sustainability appraisal of this site is inadequate. The report on Site No. H07 contains factual errors. Pages 41 and 42 of Appendix V of the SA/SEA state that the site is in the green belt. In fact the land is greenfield but not green belt. Page 42 also states that "the site is within 0.2 miles to the nearest school (Park Hill Junior School)", which is incorrect. Park Hill School is 0.57 miles from the Common Lane end of the Crackley Triangle.

Such elementary errors call into question the credibility of the Sustainability Appraisal. It is further undermined by the absence of any reference to the High Speed Rail line. As Local Plan Policies Map No. 1 (District Wide) shows, HS2's track runs through the greenfield gap between Coventry and Kenilworth, and there is additional "safeguarded land" at Crackley for diversions to watercourses. The new railway and associated works will impair undeveloped character of the Crackley gap and weaken its effectiveness as green barrier between two urban communities. The Sustainability Appraisal Report does not address this issue despite noting that site H07 is within an area of high landscape value where development would extend the built-up area of Kenilworth. In our view the omission of HS2 invalidates the recommendations on page 41 of Appendix V that "strong environmental policies are developed to protect and encourage enhancement of the natural environment and include provision for green infrastructure/ green space to extend the local habitats to create further wildlife corridors." These aims are unlikely to be achievable if the Crackley Triangle is developed and HS2 goes ahead (and we have to assume that it will as the major political parties are committed to it). The prospect of HS2 makes the Crackley Triangle even more important as a green buffer between developed areas, and the Local Plan should retain it as such.

The Kenilworth Civic Society is concerned about the practical implementation of Local Plan policies at Site H07, even though there is a current planning application for housing on the site. (W/14/0618) There are a number of obstacles to the successful development of this land, namely:-
* Very difficult access via the Common Lane bridge over the Kenilworth/Berkswell Greenway and Leamington to Coventry railway line. It will be very expensive for developers to create a satisfactory vehicular access at this point.
* Previous suggestions by the developers of three way traffic lights and that the consequent platooning of traffic are considered a negative impact upon the Common Lane throughway, and impact on all the neighbouring residential areas.
* Drainage issues. In recent years the Crackley area of Kenilworth has suffered from surface water and foul sewer drainage problems, as residents of Crackley Cottages and Arborfield Close can confirm. The "Flood Risk Assessment & Drainage Strategy" carried out by Halcrow for Planning Application W/14/0618 says "STWL has inferred (sic) that there is a lack of capacity in the local public foul sewerage system and potential flooding..." See paragraph 4.2.2 Sewers. This problem, together with surface water run-off, can be overcome by new drainage schemes, but the capital and maintenance costs will be considerable. With regard to ongoing costs, paragraph 7.5.3 of Hacrow's report says "The attenuation basin and any other upstream sustainable drainage systems within the development will be maintained by a private management company....the piped surface water network serving the development will also be privately maintained."
* Blight from HS2. The construction of HS2 will cause enormous and lengthy disruption to the Crackley area during a significant proportion of the Local Plan period, reducing the appeal of Site H07's dwellings to potential buyers. The site is only 250m from the HS2 proposed route.

Because of the costs of development and the blight created by HS2, it is questionable whether site H07 will provide the number of affordable dwellings required by Policy H2 "Affordable Housing". It is even possible that the site will be unprofitable and therefore unviable, thanks the construction of HS2, lower than expected population projections for Warwick District and the allocation of housing sites elsewhere.

The Crackley Residents' Association considers that the designation of this site as an "Allocated Housing Site" is unsound because the Local Planning Authority has not involved the community in the preparation of this part of the Plan. It was not included in the Revised Development Strategy published for public consultation by Warwick District Council in June 2013. This is a sensitive site, especially to our members and other local residents, and one that will be difficult to develop. The Crackley Triangle is part of the narrow greenfield gap between Kenilworth and Coventry. Therefore it is important that members of the community are given the opportunity to influence this part of the Local Plan

The Crackley Residents' Association also questions the credibility of the Sustainability Appraisal. This is particularly undermined by the absence of any reference to the High Speed Rail line (HS2). As Local Plan Policies Map No. 1 (District Wide) shows, HS2's track runs through the greenfield gap between Coventry and Kenilworth, and there is additional "safeguarded land" at Crackley for diversions to watercourses. The new railway and associated works will impair the undeveloped character of the Crackley gap and weaken its effectiveness as green barrier between two urban communities. The Sustainability Appraisal Report does not address this issue despite noting that site H07 is within an area of high landscape value where development would extend the built-up area of Kenilworth. In our view the omission of HS2 invalidates the recommendations on page 41 of Appendix V that "strong environmental policies are developed to protect and encourage enhancement of the natural environment and include provision for green infrastructure/ green space to extend the local habitats to create further wildlife corridors." These aims are unlikely to be achievable if the Crackley Triangle is developed and HS2 goes ahead. The prospect of HS2 makes the Crackley Triangle even more important as a green buffer between developed areas, and the Local Plan should retain it as such.

The Crackley Residents' Association is concerned about the practical implementation of Local Plan policies at Site H07, even though there is a current planning application for housing on the site (W/14/0618). There are a number of obstacles to the successful development of this land, namely:-
* Very difficult access via the Common Lane bridge over the Kenilworth/Berkswell Greenway and Leamington to Coventry railway line. It will be very expensive for developers to create a satisfactory vehicular access at this point. Local residents' are also very concerned about the potential increased traffic on the already very busy Common Lane.
* Drainage issues. In recent years the Crackley area of Kenilworth has suffered from surface water and foul sewer drainage problems. Our members at Crackley Cottages can confirm this. The "Flood Risk Assessment & Drainage Strategy" carried out by Halcrow for Planning Application W/14/0618 says "STWL has inferred (sic) that there is a lack of capacity in the local public foul sewerage system and potential flooding..." See paragraph 4.2.2 Sewers. This problem, together with surface water run-off, can be overcome by new drainage schemes, but the capital and maintenance costs will be considerable.
* Blight from HS2. The construction of HS2 will cause enormous and lengthy disruption to the Crackley area during a significant proportion of the Local Plan period, reducing the appeal of Site H07's dwellings to potential buyers

Because of the costs of development and the blight created by HS2, it is questionable whether site H07 will provide the number of affordable dwellings required by Policy H2 "Affordable Housing". It is even possible that the site will be unprofitable and therefore unviable, thanks the construction of HS2, lower than expected population projections for Warwick District and the allocation of housing sites elsewhere.

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.