The Richborough Estates Partnership LLP welcome the efforts made by Warwick District Council to respond positively to the Inspector's interim conclusions concerning the level of housing which should be delivered by the Warwick District Local Plan.

Further consideration is given to the appropriateness of the objectively assessed housing need and the proposed housing provision as part of representations submitted by others. Accordingly, as part of these representations no comments are made by Richborough.

The Richborough Estates Partnership LLP support the principle of the spatial strategy with growth principally being focused on the edges of Kenilworth, Warwick and Leamington. As identified in the Sustainability Appraisal Addendum Report (February 2016) these urban areas are amongst the most sustainable locations within the District and are best placed to accommodate growth because of the available services and facilities which can, if required, be upgraded.

Further, the recognition that to accommodate growth at these sustainable urban areas there will be a need to release Green Belt land is fully supported by Richborough. The imperative to deliver the objectively assessed housing need during the plan period provides an exceptional circumstance of the type required by the National Planning Policy Framework to amend Green Belt boundaries at sustainable locations, including at Kenilworth.

Richborough Estates Partnership LLP welcome the conclusion in the Sustainability Addendum Report (February 2016) that the spatial strategy of locating new development in and around the urban areas (including Green Belt releases), in sustainable villages and along transport corridors remains appropriate, particularly because of the increased objectively assessed housing need.

Although non-Green Belt sites are to be preferred, the combination of the housing need and the sustainability of Green Belt locations chosen for release in terms of access to services, employment, education and public transport amount to the exceptional circumstances required by paragraph 83 of the National Planning Policy Framework to review Green Belt boundaries.

The Richborough Estates Partnership LLP support the principle of releasing land from the Green Belt to the east of Warwick Road, Kenilworth (Site H41). The exceptional circumstances required by the National Planning Policy Framework to amend Green Belt boundaries exist because of the level of new homes which need to be delivered at sustainable urban areas during the plan period to meet the Objectively Assessed Housing Need.

The Richborough Estates Partnership LLP welcome the commitment to reviewing the Local Plan if there is a material change in circumstance. It would, however, be more appropriate for MOD17 and MOD18 to be consolidated and simplified.

Further, the criterion concerning up-dated household and population projections should be clarified to make is clear that the Local Plan will be reviewed where:

(f) Updating of the population and household forecasts which indicate that there is potential for a meaningful change to objectively assessed housing need used as the basis for the preparation of this Local Plan.

MOD10 Policy DS11
The Richborough Estates Partnership LLP support the principle of allocating land east of Warwick Road, Kenilworth for housing purposes (Site H41). The allocation's southern boundary is currently defined by a clear and readily recognisable physical feature which, together with the railway and Warwick Road, would provide a suitable Green Belt boundary for the allocation.

Accompanying this representation is a Parameters Plan indicating the potential location of up-to 130 new homes, open space and sustainable drainage features. The site should be formally allocated for 130 dwellings in the Local Plan and a further modification proposed to this effect.

The extent of the proposed housing area is around 3.6 hectares and the green infrastructure extends to circa 2.2 hectares. The potential number of dwellings has full regard to the housing mix contained in the Strategic Housing Market Assessment. The density of development would be up-to 36 dwellings per hectare.

As a matter of principle, the release of the site from the Green Belt satisfies the requirements of the National Planning Policy Framework because it accords with the requirement to promote sustainable patterns of development. As part of the strategic spatial strategy adopted in the Local Plan, Kenilworth is recognised as one of the larger urban areas within Warwick District which possesses a range of local facilities and services. Kenilworth is accessible by non-car modes of travel to higher order facilities and job opportunities available within Warwick, Leamington and Coventry. This accessibility will be materially improved when the new railway station opens.

The allocation is readily accessible to the local facilities and services within Kenilworth. As recorded in the Sustainability Appraisal Addendum Report (February 2016), the site is about 1.6km from Kenilworth town centre and 1.4km from the local shops at Oaks Precinct. There are healthcare facilities within around 1.4km and the new railway station would be circa 1.6km distant. There are existing bus services operating along Warwick Road between Coventry, Kenilworth and Warwick with bus stops being available within 400 metres of the site.

The erection of up-to 130 dwellings on the site does not represent a scale of development that would place unacceptable pressures on local infrastructure whether drainage, highways or utilities. As would be expected for a development of the scale proposed some local reinforcement of infrastructure would be required but such improvements do not represent an insurmountable constraint.

The site is within Flood Zone 1. There is ample scope to provide a sustainable drainage system which would ensure that the risk of flooding downstream is not exacerbated by any housing developed on the site. Two very small areas, adjacent to the southern boundary, are indicated to be susceptible to surface water flooding. However, the Parameters Plan has taken this matter into account by avoiding any built development within these areas.

As evidenced by the historical mapping, the site has been in agricultural use for a significant period of time and the risk of contamination is negligible. This would not be a matter that would preclude residential development. There are no air quality management areas adjacent to the site which would either affect future residents or be materially affected by, for example, the emissions from the vehicles of future residents.

In preparing the Parameters Plan full regard has been had to the issues identified in the Sustainability Appraisal. Assessments have been made of the potential for noise and vibration associated with the Leamington to Coventry railway line. Development has been set back from the railway and this also has the benefit of providing views from the site towards St John's Church. Consideration has been given to the interface with Kenilworth Cricket Club to ensure that there is sufficient setting back of any dwellings to avoid concerns associated with cricket balls breaking the windows, including those of parked vehicles.

Other than the boundary vegetation, there are no features of particular biodiversity interest within the site. Other than a gap created to enable access to the site from Warwick Road, the hedgerows would be retained and augmented. Account has been taken in preparing the Parameters Plan of the local wildlife site associated with the railway. Built development is set back from the railway with a buffer of landscaped greenspace, including swales, to promote biodiversity improvements.

Initial assessments have not identified any heritage assets which would be significantly affected by the site being developed for housing purposes, including the setting of Kenilworth Conservation Area and the Listed Buildings to the east of Warwick Road. Views towards St John's Church would be provided alongside the railway. A review of archaeological records does not indicate a high likelihood of any significant below ground heritage assets being present on the site.

As has been noted, the southern boundary is currently formed by a strong hedgerow which would both visually and physically contain any new homes erected on the allocation. The Parameters Plan indicates that built development could be set back from the site's southern, western and eastern boundaries to provide a soft edge and enable these boundaries to be reinforced with additional landscaping. This is not a case where the release of the site from the Green Belt would materially harm the wider visual amenity, character or appearance of the wider Green Belt.

Although the The Richborough Estates Partnership LLP fully support the principle of allocating land east of Warwick Road, Kenilworth for housing purposes (Site H41) there are detailed objections to Policy DS11 and amendments are suggested.

The first amendment concerns the capacity of the allocation. Richborough note that the Sustainability Appraisal Addendum Report (February 2016) identifies the potential to deliver approximately 125 dwellings rather than the 100 dwellings indicated in Policy DS11. Based upon detailed assessments of the environmental and technical constrains and opportunities associated with the site, together with consideration of the housing mix contained in the Strategic Housing Market Assessment, the site has the capacity to accommodate up-to 130 dwellings. This should be the site's estimated capacity.

The second amendment concerns the infrastructure requirement of providing access to the sports facilities which would form part of the allocation included in Policy DS NEW4 (SP2). By reason of the 2 allocations being separate entities, and subject to varying policy considerations and possessing different traffic implications, it would be appropriate if there was flexibility for either a single or separate accesses from Warwick Road to the housing allocation (Site H41) and the sports facilities (Policy DS NEW4(SP2)). Separate accesses might be more conducive to maximising the flexibility of laying out both the housing scheme and sports facilities rather than a single point of access acting as an artificial constraint.

The following amendment to Policy DS11 is proposed:
Ref Site Number of dwellings (estimated) Area of Emp. Land Infrastructure requirements and other uses
H41 East of Warwick Road, Kenilworth 100
130 0 Provide access to sports facilities allocation (see Policy DS NEW4)

The Richborough Estates Partnership LLP support the changes to Policies Map 5 which provide for:
(a) The allocation of land to the east of Warwick Road, Kenilworth (Site H41) for residential development.
(b) The amendment of the urban area of Kenilworth to include Site H41.
(c) The amendment of the Green Belt to excluded Site H41.