Q-I1: Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on.

The Sustainability Appraisal follows conventional guidelines and may need to be modified to reflect the issues identified in V3-2

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1. The Plan and Sustainability Appraisal use the term Mitigate as a solution to lessen the impact of particular effects. In a number of cases, this term seems to have been used without a solution in mind, and in the TTG’s view, in several cases mitigation would not be possible, or would be economically unviable. 2. The Accessibility Study doesn't consider interconnectivity between settlements or to major conurbations, eg for work. It is therefore flawed. Accessing the majority of employment will require travel outside of the settlement, therefore connectivity of the various transport modes (eg.transport hubs, delivery hubs), and future transport enhancements within the proposed timescale of 2050 should be considered, as well as more local active travel. 3. Locating settlements such that they have access to public transported is supported. However, the analysis in the Local Plan and Sustainability Assessment, of positioning new settlements on existing rail corridors, or near existing bus stops, and using these as a comparator of sites in a Plan that extends to 2050 is considered to be flawed, as it takes no account of the routes served by the rail corridor, the potential to re-route or add additional bus routes, or desired travel patterns. 4. The accessibility scoring doesn't apply any weighting to the answers, it is only a tick or cross.

The following comments are made in respect of the Sustainability Appraisal (SA) for Long Itchington. The Small Settlement Location (SSLs) for Long Itchington includes Rosconn Strategic Land's interest off Collingham Lane. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village. It is clear that certain parts of Long Itchington are more sensitive than others. For example, land to the west is more constrained by flood plain. Assessing the settlement edge as a whole does not allow for any distinction to be made between different areas for growth. It is difficult therefore to draw conclusions as to the appropriateness of the settlement to accommodate growth from this exercise alone. It is clear from Table 5.1 that the only major adverse impacts identified for Long Itchington relate to landscape sensitivity and agricultural land classification. With respect to landscape sensitivity, the SA notes that impacts can be avoided by matching development types with areas with capacity for change. The Rosconn Strategic Land site lies within one such area, as it is the least sensitive part of the settlement within parcel ‘LI01’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). LI01 adjoins parcel LI03 to the north where the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). Furthermore, mitigation can be incorporated within the site to enhance the existing strong landscaped and hedgerow boundaries to the south and north east. This will further reinforce the site’s visual containment, and its clear alignment with the existing built up area. On the basis of the above, it is clear that landscape sensitivity to accommodate change should not be an overriding factor to future growth at Long Itchington. With the 2012 Landscape Sensitivity Assessment helpfully showing the areas of lower sensitivity, including an area of land which includes this site. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon the development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Long Itchington and that it is considered as a suitable location for growth, with a good range of facilities available. The Councils will also be mindful that this is only one piece of evidence at a strategic level, and the HELAA and other evidence will need to inform the selection of allocations in due course.

again admirable proposals, but additional development will entensify use of existing services eg health, we need to make sure all our health facilities are improved to take on any increased population such as doctors, dentists, clinics and hospitals etc

all measures are highly subjective which, perhaps, they need to be at this scale.

The commuity of Wootton Wawen would want a Major Positive Impact without compromising the village feel or overwhlem the current older housing conurbation within the village. At a recent meeting of the village community the vote indicated that the village could look to the buidlig of up to 50-100 houses on small sites.

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We believe the sustainability appraisal should be more transparent for the sites under consideration in order that members of the public can easily determine how individual sites are being viewed in the draft plan.

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The sustainability appraisal does not seem to have taken account of the inadequacy of existing infrastructure. For example, existing schools do not have capacity for the current demand.

I am repeating the same text for every question in protest at the unbelievably long-winded process you force on anyone wanting to make a comment. My comment is: As a Kenilworth resident I want to register my dismay at the amount of land that has been earmarked for new housing development. Kenilworth's major asset (the castle) is at risk of losing the various country walks on land adjacent to it. Please try to keep the green fields around the back and towards Chase Lane untouched. The infrastructure of the town is already under pressure - specifically I am concerned about medical facilities, water pressure and extra traffic (Kenilworth's station will be a long walk away from these proposed sites and there very few trains so increased car journeys are inevitable). I am appalled at how difficult it has been to make my point of view (as summarised above). The process is unnecessarily long-winded and impenetrable.

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These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development. The recent Covid pandemic has brought home to us the importance of countryside walking in our own locality. We have a public right of way across fields opposite our home in Leicester Lane, and have become increasingly aware of how much more this footpath has been used by ordinary members of the public for recreation and refreshment, especially at times of lockdown and post lockdown recovery. In the past, this was most frequently used by dog walkers who parked their cars nearby and took their dogs for walks up the footpath. However, these last three years have seen an increase in use by families simply wishing to avoid the urban environment and its concomitant noise pollution and enjoy a small 'escape' into the countryside. Biodiversity here is of particular importance. Since lockdown in March 2020, we have identified the following species of wild flowers growing growing along JUST THIS ONE footpath, namely: snowdrop bindweed crocus daffodil lady's smock celandine white camption stitchwort groundsel wild carrot bugle bluebell cuckoo pint dandelion red campion jack by the hedge forget me not dead nettle daisy red clover white clover vetch goosegrass mouse ear buttercup silverweed green alkanet sow thistle herb robert speedwell deadly nightshade herb bennett cow parsley red poppy ragwort hawkbit coltsfoot burdock In addition to these, there have been flowering and fruiting trees and bushes, namely blackthorn (sloes) crab apple (fruit) bramble (blackberries) dog rose (rosehips) elder (elderberries) These are both food for the local bird populations, and also often gathered by walkers for home made products. Furthermore, we have seen red admiral butterflies, orange tips, speckled woods, and tortoiseshell butterflies. We have also seen buzzards and great spotted woodpeckers, and heard green woodpeckers whilst on our walks across THIS ONE FOOTPATH. In these days of increasing problems with people's mental health and with access to the countryside and all it has to offer being increasingly restricted, we cannot stress strongly enough the important of such public rights of way and the benefits to our community.

Although we support the intention of this sustainability appraisal, the implementation has too many issues to be used with confidence. The methodology used in the Sustainability Assessment (SA) is not sufficiently clear for the reader to understand the process by which locations are assessed using the SA/SEA approach. There are several parts to the methodology: 1). Selection of 13 SA Objectives which are scored at each location; 2) Assessment of each SA Objective based on a SA Framework (SA vol. 3 Appendix A pages 538-541 pdf pp.580-583) which includes Decision-making criteria – a set of questions – and Indicators used to answer the questions for each SA Objective; 3) Scoring for each SA Objective (and sub-objectives) based on Explanations (assessment of Indicators) using a six category scoring system (SA vol.2 Table 2.1 page 410 pdf p.452) represented by Impact Symbols (--,-,+/-,0,+,++); 4) Evaluation of the performance of different options based on the scoring for SA Objectives, sometimes tabulated, averaged or shown graphically through the use of rose diagrams (e.g. Kenilworth SA vol. 2, 4.5 page 458, pdf p 500). It may be challenging to identify quantitative Indicators for all the SA Objectives but some Indicators are statements of intention or policy rather than factual information For example, SA1 Climate Change is described through six Decision-making criteria that include the question: “Will the option ensure that sustainable construction principles are integrated into developments including energy efficient building design?” To which, one of the Indicators is listed as “Implementation of adaptive techniques in building design e.g. passive heating/cooling”. This criterion and indicator can’t be addressed in 2022-24 as they depend on future policy. Or, the Decision-making criterion question “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. Some questions are unclear. For example, SA13 Economy, one of the Decision-making criterion questions is “Will the option provide or improve sustainable access to a range of employment opportunities?” It is not clear what this means: how could it be answered on the basis of locations for housing alone, and what is the appropriate Indicator? It is not clear how the Explanations are arrived at. We might expect to see these based on answers to the Decision-making criteria using the stated Indicators. For Kenilworth North, the Explanation for the scoring of SA1 Climate (SA vol 3. B.5.1 page 565 pdf p.607) only uses one of the stated Indicators (carbon emissions), as in “Large scale residential-led development is likely to result in an increase in GHG emissions. Development in this Broad Location could deliver up to 2,000 dwellings and therefore could increase carbon emissions in the District by more than 1% and result in a major negative impact.” Why are the other stated Indicators not included – and in any case this is contradictory given that one of the Indicators acknowledges future houses (up to 2050) are likely to be low energy/zero carbon. The apparent inconsistencies above potentially undermine the value of the SA methodology. It is not clear how the Impact Symbols are translated into SA Objective Performance scores on the rose diagrams. The rose diagrams are scored 0 to 5 which suggests they map on to the six impact symbols. But this is not the case. For example, SA1 Climate Change for Kenilworth North (SA vol 3. B.5.1 page 565 pdf p.607) is given an Impact Symbol of (--) (most adverse effect) but is mapped on to a score of 1 in the rose diagram – not 0 (zero) (SA vol. 2, 4.5 page 458, pdf p 500). It is not clear how the Impact Symbols are ‘averaged’ for an SA Objective on a rose diagram when there are sub-objectives with different Impact Symbols. For example, SA6 Pollution for Kenilworth North (SA vol 3. B.5.6 page 568 pdf p.610) has five sub-objectives all scored with the same Impact Symbol (-) yet the rose diagram score is 2.2. Or, SA3 Biodiversity (SA vol 3. B.5.3 page 566 pdf p.608) that has eight sub-objectives (+/-, 0, 0, -,--,-,0,-,) and also with an average score 2.2 (a simple mapping of 0 to 5 to these would give an average score of 14/8 = 1.75). Perhaps the different sub-objectives are weighted differently, though this is not clearly stated, or there is an error in the mapping. These concerns are far from trivial. The underlying methodology to the whole exercise is based on simple scores, many of which are contentious because they depend on intention or policy rather than factual information. As a result, the findings are very sensitive to particular scoring values and provide relatively weak discriminatory power (i.e. many of the rose diagrams look very similar). Yet the scores are used to rank locations (e.g. Best Performing Location) as evidence for the Issues and Options report. Minor errors in the scorings, rose diagrams and ‘averaging’ across objectives could result in quite different findings.

The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development. Argument 1. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Argument 2. The Green Belt around North Leamington is a valued open space. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. It is easily accessible on foot from North Leamington so many people can access the public rights of way across the fields. Use of these footpaths increased markedly during lockdown and these high levels of use continue today. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. Argument 3. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. Recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development. The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs.

The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development.The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The Green Belt around North Leamington is a valued open space. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. It is easily accessible on foot from North Leamington so many people can access the public rights of way across the fields. Use of these footpaths increased markedly during lockdown and these high levels of use continue today. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. Recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development. The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs.

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The assessment of sites within Appendix 3 seems to ignore critical factors when reaching it's conclusions. The development of the proposed locations would clearly lead to coalescence of old milverton and blackdown and the joining of Leamington to Kenilworth. This undermines the critical purpose of Green belt which is to prevent the merging and protect individual character. Furthermore reference to only a minor impact on the recreational experience appears to be entirely at odds with the reality of developing the potential sites with a clear loss of critical and well used recreational space.

I am commenting on locations B.12 Royal Leamington Spa North East (Blackdown) and B.13 Leamington Spa North West (Old Milverton). The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. I think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development. I also note that the appendix was produced by a consultancy based in Cheltenham which suggest to me that no local knowledge of the area has been employed in compiling the appendix.

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Appendix 3 of the Sustainability Appraisal, assessment of sites, concludes development on Old Milverton and Blackdown would not lead to any coalescence of settlements and have only minor negative impact on recreational experience. I consider this to be wrong and ignores the main purpose of designated Green Belt particularly in North Leamington. The assessments of the two proposed development sites in North Leamington are unclear, inaccurate and not referenced in the main consultation, but buried in the 477 page Appendix 3. Both assessments state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would merge Old Milverton and Blackdown into Leamington, and would also bring the outskirts of Leamington and Kenilworth virtually together, which is exactly what the Green Belt is designed to protect against. I don’t agree with the conclusion that development will have only “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths” as the environment will change completely to an urban one. The Green Belt around North Leamington is a valued open space, and easily accessible on foot from North Leamington. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. During Lockdown the use of these footpaths and permissive rights increased hugely, and these high levels of use still continue. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. In addition the analysis ignores that this is some of the highest quality agricultural land around Leamington making an important contribution to sustainability and security of food supply, from what is a rapidly decreasing, and already scarce resource. The NPPF is clear that if agricultural land is required for non-agricultural development, then poorer quality land should be prioritised over higher quality. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. I believe therefore it is a serious inaccuracy to call this a ‘minor negative impact’ and am convinced that urban regeneration/brownfield land must be prioritised, and Green Belt can only be considered as a last resort.

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

Appendix 3 of the Sustainability Appraisal, assessment of sites, concludes development on Old Milverton and Blackdown Green Belt would not lead to any coalescence of settlements and have only minor negative impact on recreational experience. I consider this to be wrong and ignores the main purpose of designated Green Belt particularly in North Leamington. The assessments of the two proposed development sites in North Leamington are unclear, inaccurate and not referenced in the main consultation, but buried in the 477 page Appendix 3. Both assessments state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would merge Old Milverton and Blackdown into Leamington, and would also bring the outskirts of Leamington and Kenilworth virtually together, which is exactly what the Green Belt is designed to protect against. I don’t agree with the conclusion that development will have only “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths” as the environment will change completely to an urban one. The Green Belt around North Leamington is a valued open space, and easily accessible on foot from North Leamington. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. During Lockdown the use of these footpaths and permissive rights increased hugely, and these high levels of use still continue. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. In addition the analysis ignores that this is some of the highest quality agricultural land around Leamington making an important contribution to sustainability and security of food supply, from what is a rapidly decreasing, and already scarce resource. The NPPF is clear that if agricultural land is required for non-agricultural development, then poorer quality land should be prioritised over higher quality. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. I believe therefore it is a serious inaccuracy to call this a ‘minor negative impact’ and am convinced that urban regeneration/brownfield land must be prioritised, and Green Belt can only be considered as a last resort.

The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development.