Issue and Options 2023

S6 – Review of Green Belt boundary • The National Planning Policy Framework, 2021 (Sec 13: Protecting Green Belt land, 137-143.) explains that the Government attaches great importance to Green Belt, adding the essential characteristics of Green Belts are their openness and their permanence. Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. o There is no justification here, and no such exceptional circumstances, where there exist brownfield sites and/or other underutilised housing opportunities within existing settlements. o When (re-)defining Green Belt boundaries, plans should define boundaries clearly, using physical features that are readily recognisable and likely to be permanent. The proposed sites in Kenilworth South have no readily recognisable physical features to outline any change in land classification. o Removing Green Belt land undermines the goal of tackling climate change by removing green field land and with it high quality farmland and biodiversity, and increasing the use of the car and associated emissions (particularly as in Kenilworth, the broad locations do not perform well in terms of public transport, especially Kenilworth South). o It will also undermine the objective of coalescence, particularly in relation to the urban sprawl from Coventry to the North of Kenilworth and Leek Wootton (and onto Warwick) to the South. o Green Belt land in Kenilworth South is UAA, regularly producing barley. A product which saw a national decrease in production by 4.2% during 2022. Green Belt land which has soils rich enough for food production should be protected. • The last four paragraphs of section S6 provide some fine words regarding the future of the Green Belt which we support. However, earlier in the section there is a strong hint that Green Belt land adjacent to existing settlements is inhibiting development which otherwise meets environmental and sustainability targets. This is wrong generally within Kenilworth, given the role that the Green Belt plays here in particular, and especially in relation to Kenilworth South. Release of this land would undermine environmental and sustainability targets in terms of Accessibility (see SA11) and in terms of impacts on biodiversity (see SA3) and landscape and cultural impacts (SA4 & SA5).

Yes

Nothing chosen

Q-S5.2: Do you think new settlements should be part of the overall strategy? • We believe that new settlements offer viable alternatives to the growth of existing settlements and can avoid the coalescence of existing towns and villages with the attendant loss of identity and character. • They can be planned and sited with appropriate infrastructures for optimal sustainable development in future years.

No

Q-S4.2:Comments regarding settlement analysis • The Settlement Design Analysis relies heavily on a series of maps which use different colours to categorise land use and suitability. For those who have defective colour vision (at least 10% of men), these maps are very difficult to interpret. However, the Criteria for assessing edges as shown in Table 5 is reasonable. The criteria listed throughout the Analysis appear well defined and pertinent; it is the interpretation in respect of individual areas which is suspect. • These comments refer specifically to the Kenilworth South area. • Table 6 uses a crude 800 metre circle drawn with a compass as the definition of the 20 minute rule. It is acknowledged that this ignores the actual walking distance using streets and footpaths, which, we would contend, results in a significant understatement of the real walking time in almost all cases. In the case of area 18 (south west of Rounds Hill) the limited direct access to Rounds Hill/John O’Gaunt Road will make any walks much longer. This does not seem to have been taken into account in respect of this specific area. Should this change the category from C to D? • Once again, none of the maps or analysis seems to take into account the existing new developments around Kenilworth. Nor do they show HS2 and its surrounding area. At the very least these should be shown on the density analysis, since the information is contained within the last plan. There seems to be no reason for this exclusion, unless it is to give the impression that Kenilworth is much smaller than it will be.

1. 1. Comments on the methodology / objectives used in the SA • The consultants’ Assessment of Reasonable Alternative Broad Locations – B8 Kenilworth South - attempts to use a form of standard assessment to create a level playing field. However, the methodology is overly complex and often too subjective to allow for meaningful comparison. The combination of i) SA Objectives, and then ii) a set of decision-making criteria and then iii) a non-exhaustive list of indicators, all using a six category scoring system, introduces so many variables into assessing each objective, that the comparison becomes subjective and somewhat obscure. Also, many of the indicators raise questions of future policy rather than permitting assessment now. • For example, the decision-making criteria questions for SA1 Climate Change is “Will the option help to reduce reliance on personal car use? Indicator - Encourage active travel to local services and amenities.” This is not an indicator that can be used to judge the performance of an objective for a location now as it represents a future intention or action. • This complexity is demonstrated by the fact that all six broad locations score the same (++) under SA Objective 1 when in fact (although greenfield sites) they are all give rise to differing levels of carbon emissions. Whilst the document indicates that this level of detail will be assessed as options progress, we believe this is the wrong way around, given the fundamental importance of addressing climate change as part of overall Government policy (not as an afterthought). • More specifically, some of the assumptions appear flawed. For example, throughout the plan there are references to the adoption of 20 minute neighbourhoods. This guidance provides an excellent measure of what should be the target for access to various services, including public transport. We support the adoption of this measure. • However, when it comes to its use, it seems that the consultants’ interpretation has not been rigorous. None of the development areas in Kenilworth South, for example, fall within the 20 minute measure, taken as walking distance by available routes (not as the crow flies). 2. Comments for Kenilworth South against each of the 13 SA objectives listed below. SA1 Climate change • The overall SA objective here is “Reduce the SWLP authorities’ contribution towards the causes of climate change.” However, achievement of this objective is inconsistent with developing previously undeveloped or greenfield land (as the document recognises at 2.4.4 SA Main report). We agree that the SA objective is seriously undermined by the Kenilworth South location but we consider these effects have in fact been understated for two main reasons: • Firstly, the proposed mitigation suggests that this broad location would be a 20 minute neighbourhood (which in principle is a positive concept). However, the Kenilworth South area is outside the 20 minute criteria and such mitigation is therefore not available here. There is no realistic public transport available in Kenilworth South (see comments under SA 11 below). • As a result, residential development in Kenilworth South would both i) significantly increase the use of the personal car for trips into Kenilworth itself, and also for commuting to Leamington/ Warwick to the south and Birmingham/Coventry to the north, increasing carbon emissions, and undermine the sustainable travel goals under this SA objective and ii) in turn increase air pollution from engine use and tyres, dust and so on. These issues are developed further under SA11 (Accessibility) below. • Secondly, Kenilworth South is comprised of Utilised Agricultural Land and supports rich biodiversity. The proposed mitigation to “retain soils and vegetation in these areas…” is therefore entirely misplaced; the proposal would remove and build upon existing rich soils and destroy and displace the rich flora and fauna which mitigates the effects of climate change, rather than creating them. SA2 Flood risk • The consultation identifies some new flood risks, but any increased development will result in more rapid drainage of surface water from the land with increased risk of flooding. In the case of the Kenilworth South area it drains in two directions - west towards Finham Brook and Kenilworth Castle and east towards Cattle Brook and the River Avon, which could adversely affect both. • The increased loading on the combined sewer system within the town is likely to overload the Kenilworth transfer pumping station and increase the frequency of storm overflows discharging into the Finham Brook. Unless the pumping capacity is enlarged before the development, the sewers will be increasingly overloaded. This is particularly, relevant as the government has recently charged all the water companies to reduce or eliminate sewage and storm water overflows in the environment. SA3 Biodiversity, Flora, Fauna and Geodiversity o As part of your vision to create ‘a resilient and net zero carbon South Warwickshire’ which mitigates against climate harms, we cannot conceive of how proposing to remove greenbelt land in Kenilworth South supports this objective. This would do the opposite of “Protect, enhance and manage biodiversity and geodiversity” i.e. the SA3 objective. o We think the adverse impacts for Kenilworth South have been underestimated, partly because of a lack of detail for the area in SA3. However, this does appear to be noted under Landscape SA4 which recognises the “wooded pasture and heath, ancient woodland and mature hedgerow oaks”. This is correct. These fields across Kenilworth South include ancient Oak trees, orchards and hedgerows which support the multitude of birds and wildlife in the area. Local residents who use the multitude of footpaths report regular sightings of an array of wildlife on a daily basis. o Birds such as fieldfares, redwings, woodpeckers, blue tits, great tits, goldfinches, greenfinches, yellowhammers, lapwings, cuckoos, swifts, house martins, owls, song thrushes, sparrowhawks, buzzards, kestrels, robins, sparrows, wrens, chaffinches. There are numerous ponds and other wetlands supporting ducks, moorhens and herons (among other water birds) o Animals such as foxes, badgers, hedgehogs, rabbits, hares (boxing in the fields around mating time), muntjac deer, bats of different types and various other species. o Numerous ancient tree species, an apple orchard (on the south side of Rouncil Lane), and a large bee population in numerous hives along Rouncil Lane. • Removing their habitats would create a devastating impact on the biodiversity of Kenilworth South. Indeed, releasing areas of greenbelt at all over extensions to villages and brownfield sites seems a complete contradiction to mitigating against climate harm. • Furthermore, in Kenilworth South and in particular the Oaks Farm site, there is no man-made boundary up to which any new housing development could be built up to and contained, thus limiting the environmental impact and possibility of further expansion/removal of the greenbelt land in the future. We therefore have serious concerns about this. The greenbelt land also fulfils the function of maintaining separation between Kenilworth, Leek Wootton, Warwick and Beausale and the removal of it would result in a loss of identity, green space, character and nature of the area. SA4 Landscape • The objective is to “protect, enhance and manage the quality and character of landscapes and townscapes.” Development at Kenilworth South would undermine this significantly. We look at 5 different criteria here. 1. As to Coalescence, the risk under this receptor has been underestimated. It is recognised at 4.5.11 of the SA but the impact would not be minor: the risk of coalescence with Leek Wootton is significant, and Beausale and/or Warwick. The Green Belt forms an important role at this location, providing a natural end to Kenilworth and ensuring the nearby villages retain their character. The proposed mitigation (through layout and design to create a robust settlement edge) is nonsensical - any development in the Kenilworth South area would blur the settlement edge and create a bridge between the two areas. We agree with 4.5.12 of the Main Report that “these adverse impacts will be difficult to avoid.” 2. As to Landscape character, the Arden Character area is correctly and aptly described as “a historic landscape with wooded pasture and heath, ancient woodlands and mature hedgerow oaks” and in particular the “remnant deer parks, ancient woodlands and ancient pollard oaks.” The comments under SA3 Biodiversity are repeated here. Development here would therefore be more than ‘discordant’ with this character - it would destroy it and replace ancient landscape with residential dwellings. The negative effects are significantly understated. Moreover, the suggested mitigation does not bear scrutiny i.e. “use of landscape led site design practices…” But this does not mitigate removal of the ancient landscape. Productive open farmland, with biodiverse hedgerows and ancient trees, in an ancient landscape cannot be replaced by vague words. 3. Landscape sensitivity: the area is of historical and landscape significance the negative impact on which has not been assessed in Appendix A. Historically, this was part of the Arden Special Landscape Area and part of Kenilworth “Olde Parke”. There are views from the fields and footpaths at Oaks Farm and Centenary Way bridle path across to Kenilworth Castle. This was described in the 2006 Local Plan as follows: “Located on the top of a hill, this site is inappropriate for a housing development as it will be clearly visible from Kenilworth Castle. It will also dominate the heavily used Centenary Way bridle path running south from Kenilworth Castle as well as destroying over half of the footpath linking Rounds Hill to Rouncil Lane. It consists of Grade 3 agricultural land, being made up of existing parcels of farmland which are separated by hedgerows and trees. The site is located to the north of Rouncil Lane and lies wholly within the Green Belt. Historically, this land was part of the Arden Special Landscape Area. … The land also falls within the site of 'the Olde Parke' to the South West of Kenilworth Castle. (Warwickshire County Council Information record number MWA3228). The site of the 'Olde Parke' which formed part of the deer park belonging to Kenilworth Castle during the Medieval and Post Medieval periods. Earthworks, which may be the bank enclosing the deer park, are still visible. The southern boundary of 'The Old Parke' shown by Sir William Dugdale's 17th century map is probably represented today by Rouncil Lane from near its crossing of the Inchford Brook at SP2670 through SP2869 to about SP2870 where Dugdale shows the boundary bending sharply to the West and the present lane turns to the East .” Thus the 2006 Local Plan totally rejects the suitability of this area for development. What significant changes have occurred to reverse that assessment? 4. Public Rights of Way: the impact on these rights of way would not simply be “minor” in terms of the “recreational experience.” There are numerous footpaths across the Kenilworth South location including Millennium Way which connects Warwick to Kenilworth Castle, as well as other footpaths connecting Rouncil Lane to Rounds Hill and across to the Warwickshire, Leek Wootton, Hatton and further. The negative impact would be seriously adverse on the basis of the i) extent of the recreational use of the footpaths and ii) the quality of historical and ancient landscape character as mentioned above. These footpaths are frequented daily by a multitude of dog walkers, runners, cyclists, ramblers and families, who benefit immensely from the landscape character. Many of these are the residents signing this consultation response who use the footpaths each day, often twice a day. It is also used by Kenilworth School for recreational trips, for Duke of Edinburgh participants and for the Scouts and Guides for whom the footpaths are safe for children to use in summer for independent hikes. This makes the area what it is. Their extensive use of the footpaths significantly contributes to the mental and physical health and wellbeing of the local community and give the opportunity for everyone to gain direct access to the neighbouring countryside. Furthermore, local residents have purposely chosen to live in this peaceful location to reap the benefits of doing so on mental health and wellbeing, which are very far reaching. 5. Finally, we think that the increased level of traffic which would result from development in this area would also have a negative effect on its landscape character; replacing what is a relatively quiet set of roads (Rouncil Lane to Leek Wootton and Beausale) with a large stream of traffic and commuters. This is already a threat from the building scheduled within the current Local Plan. As mentioned above commuting will only increase leading to increased traffic flows on the A452 to Leamington and Balsall Common and the A429 to Coventry. Traffic is already congested at peak times on these roads and the junctions that support / link them, in particular the Thickthorn and Longbridge roundabouts on the A46. Major road infrastructure improvements would be required to address these pressures, further exacerbating the negative climate change impact. SA5 Cultural heritage • In addition to the negative impacts already assessed in the SA (e.g. Wootton Grange Farmhouse), this section is missing various negative impacts. • The National Planning Policy Framework, 2021 (Sec 13: Protecting Green Belt land, 138.) explains that “Green Belt serves … to preserve the setting and special characteristics of historic towns.” See Comments under SA4 concerning the historical landscape character in terms of Kenilworth “Olde Parke” and the Arden landscape character area. • Views from Kenilworth Castle spread across south Kenilworth, currently over Green Belt fields, visible to and enjoyed by the numerous recreational users of the footpaths. Development in this area would negatively affect the setting of Kenilworth Castle and associated cultural heritage of the town. • This would undermine the SWLP’s own vision to create a ‘well designed and beautiful South Warwickshire’, for which protecting and enhancing heritage assets is said to be vitally important. These surely must be protected as part of the cultural heritage of the town, and indeed to ‘enhance access to and public understanding of these assets’ (as stated in your key objectives). SA6 Pollution • We agree that there would be negative impacts on residential occupants from the A46, but also from other traffic impacts and air quality problems associated with the increased traffic along Rouncil Lane and Rounds Hill, as well as the A452 and so on. See references to vehicle pollution in SA1. SA7 Natural resources • The major negative impact here on ALC Grade land is agreed. The mitigation itself is recognised as only partial and unconvincing; we consider that the serious negative impact is absolutely clear. • DEFRA National Statistics, Agricultural Land Use in England at 1 June 2022, states that just over half (55%) of utilised agriculture land (UAA) is croppable. Greenbelt land in Kenilworth South is UAA, productive land, producing a variety of arable crops, predominantly barley, a valuable product which saw a national decrease in production by 4.2% during 2022. Green Belt land which has soils rich enough for food production should be protected. SA8 Waste • In addition to the negative impact from household waste generation, there are other issues here. Foul drainage is already a problem in Rouncil Lane caused by increased use from the Abattoir. Foul smells in the area around the junction of Rounds Hill and Rouncil Lane have been a problem for years The proposed development of the abattoir will only make matters worse and also further housing development will necessitate a substantial increase in sewer drainage facilities. • Cherry Orchard recycling centre is already full and would struggle to cope with the number of houses envisaged. SA9 Housing • The stated objective is “to provide affordable, high quality, environmentally friendly sound housing for all.” • This reads like a mission statement or vision that we can all applaud. As an objective, there are no measurable outcomes, no resources identified or actions required to achieve the objective. The comments made against the other objectives pose the challenge that this housing objective needs to address, as do our comments made on Chapter 6 of the main report. (See page 16) SA10 Health • We do not agree that Kenilworth South performs well against this objective. • Firstly, as a part of your vision to create a ‘healthy, safe and inclusive South Warwickshire’ you have stated that access to public open space for sport and recreation is an important factor, together with ‘healthy places for all sections of the community which contribute to physical and mental wellbeing’. • But health also includes the very real benefit which residents already receive from the Green Belt land. Many people regularly frequent the Kenilworth South area footpaths to keep fit and this has been increasingly evident since lockdown because these paths are safe and protected. • On a regular basis this land is, in addition, used regularly by: o Dog walkers, runners, cyclists, ramblers; o Kenilworth School; o Duke of Edinburgh participants; o Boy Scouts/Girl Guides. • See SA4 above. They significantly contribute to the mental and physical health and wellbeing of the local community and give the opportunity for everyone to gain direct access to the neighbouring countryside. Furthermore, local residents have purposely chosen to live in this peaceful location to reap the benefits of doing so on mental health and wellbeing, which are very far reaching. • Utilising this area for development would undermine the health of existing local residents by disrupting the landscape and these footpaths as well as negatively affecting the wider residents of Kenilworth who use these footpaths already. • Secondly, there is no accessible GP surgery within 20 minutes. The suggested mitigation is very vague and relies on third party action which cannot be assured. There is a national shortage of GPs so it seems highly unlikely that a new GP practice could be established in the neighbourhood. Thus, those neighbourhoods would be well outside the 20 minute rule for access to existing GP practices which are, in any case, under pressure already, without consideration of how they will cope with current expansion of the town. • Thirdly, we consider that if the positive impact in terms of access to hospital treatment is removed, Kenilworth South would not still score highly. We consider that the location of a hospital for secondary health care / emergency treatment only obscures the true rating of access to day-to-day healthcare. • We also agree that the proximity to the A46 will have negative impacts on residential occupants. SA11 Accessibility Accessibility - Bus Stop • None of the Kenilworth South area is within 10 minutes walking distance of existing bus services along Warwick Road. Although Warwickshire County Council is currently subsidising a demand responsive service which technically covers this area, it doesn’t meet the criteria for frequency and its future after the experimental first 2 years cannot be assured. Therefore, it is probable that there will only be bus services along Warwick Road. • Para 4.5.36 notes that Kenilworth South is outside the target distance for bus stops but offers the mitigation that public transport can be improved. Where is the evidence to suggest that this will happen? Commercially operated bus services everywhere are being reduced and Council funding for improvements is under extreme pressure. Evidence would suggest that improvements, although possible, will never be funded. Accessibility - Connectivity • Additional car traffic would seriously impact accessibility for existing and new developments since the road network is already under pressure, before taking into account current expansion of the town. The main north-south artery of Warwick Road is already at capacity in peak times, resulting in residential side roads becoming rat runs, which creates noise and emissions pollution and is a danger to pedestrians and other road users. Very few Kenilworth neighbourhoods have an existing bus service, so connectivity between most neighbourhoods is reliant on private cars, and this is before taking into account current expansion of the town in the existing 2017-2029 plan, which is yet to be realised. • Rouncil Lane and Warwick Road are already bottlenecks at peak times of the day, without adding in any further traffic generated from the planned housing development on the existing Castle Sixth Form site and the Woodcote police headquarters site or any other proposed housing in Kenilworth South as a part of the 2050 plan. Considerations also need to be made to traffic congestion from any new housing in this area along alternate routes including Rounds Hill, John O’Gaunt Road and Fishponds Road in Kenilworth and Rouncil Lane/Woodcote Lane in Leek Wootton. Local campaigns have already been in place about traffic congestion from the Castle Farm development located off Fishponds Road, and the need for traffic calming along these thoroughfares, and that is without the addition of any additional traffic from new housing in the area. SA12 Education Access to Secondary School • The new secondary school is located on the opposite side of Kenilworth and the increase in journeys to/from Kenilworth South would create major traffic issues. Inadequate provision exists for cycling. There is no public transport provision to the already heavily congested road system in the town and there is no public transport provision to the new Kenilworth School site. • Para 4.5.41 identifies that Kenilworth South (as well as North West and West) is located outside the sustainable target distance from a secondary school, which could effectively be mitigated through potential secondary education provision within the BL layout plan. • What does this mean - as it could be interpreted to suggest that you are going to build another new school nearby, which the existing town infrastructure couldn’t support. Primary schools • Primary schools in Kenilworth South (St Johns and Clinton) are generally oversubscribed already year on year, without the additional demand any further housing and young families being added into the existing catchment areas would bring. SA13 Economy • The objective seeks “to ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth.” • The residential area that is currently Kenilworth South has minimal employment land in its area and it is very unclear why the building of houses in this area will attract any employment to an area that is lacking infrastructure to support employment and has poor accessibility to other areas (see comments at SA11). Housing in this area would seem to be wholly dependent on employment being provided in other areas, further increasing the negative climate impact and putting further stress on transport links and accessibility across Kenilworth and beyond. • In our view, the answers to the identified decision making criteria to assess the SA objective are:  Will the option / proposal: o Provide or improve sustainable access to a range of employment opportunities? NO o Protect and create jobs? NO o Encourage business start ups in the plan area? NO o Protect and enhance the vitality and viability of existing employment areas? NO o Protect and enhance the vitality and viability of town centres? NO

Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? • We do not consider that exceptional circumstances exist to justify the release of Green Belt land to expand existing settlement boundaries. Green Belt land in Kenilworth in these broad locations, and particularly in Kenilworth South fulfils important functions in terms of openness / landscape character, coalescence with Coventry to the North, Leek Wootton and onwards to Warwick to the South, and making a significant contribution to the area’s biodiversity and to the recreation and wellbeing of the community. • Brownfield sites and under-utilised existing residential areas (with the potential for higher density housing) should be priorities. We would strongly challenge the basis for releasing areas of Green Belt at all over extensions to villages, brownfield sites and new communities etc, particularly in this area where Green Belt land fulfils this important separation function.