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 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 Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: 1. check the unrestricted sprawl of large built-up areas 2. prevent neighbouring towns merging into one another 3. assist in safeguarding the countryside from encroachment 4. preserve the setting and special character of historic towns 5. 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 fi elds. 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. The assessment of sites at Appendix 3 concludes that development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. I think this is wrong and ignores the main purpose of designated Green Belt, particularly in this location.
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 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. 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.
No answer given
Load of rubbish, should be explained more clearly for the layman to understand the implications. No matter what the local community want the Council, will ignore community comments and wishes if it go against the Council.
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.
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.
[Arguments 1, 2, 3, 9] I live in North Leamington. As such, I am particularly concerned about the conclusion in Appendix 3 that development in Old Milverton and Blackdown would lead to “no coalescence of settlements” and have only “a minor negative impact on recreational experience”. I vehemently disagree with these statements. Development would effectively complete the coalescence of Leamington with Kenilworth, with Kenilworth already as good as part of the greater Coventry conurbation. Even more so, the footpath from the end of Guys Cliffe Avenue is the only footpath to open fields from the top of central Leamington. This opportunity to get into nature is invaluable for residents. This was particularly the case during the COVID lockdown. But since more and more people are working from home, there are more and more people in desperate need for some recreational walks, get fresh air, see continuous green spaces, bird wildlife, ACTUAL nature, not an artificial park that is already massively overcrowded. If you are interested in the wellbeing and health of the residents, this natural space is absolutely essential.
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 interest west of Marton Road, with the north and eastern boundary abutting the built up area boundary. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village and covers the site. 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, this site lies within the least sensitive part of the settlement, within parcel ‘LI02’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). LI02 adjoins parcel LI03 to the east where the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). In landscape terms, the site aligns with the Council’s own decision-making in this part of Long Itchington, with the Bloor Homes scheme at Bishop Drive, where the landscape’s capacity to accommodate change was considered acceptable. Furthermore, as shown on the Development Framework Plan, mitigation can be incorporated within the scheme to enhance the existing strong landscaped and hedgerow boundaries which will further reinforce the site’s visual containment. On the basis of the above, it is clear that landscape sensitivity to accommodate change will not be an overriding factor to future growth at Long Itchington, with the 2012 Landscape Sensitivity Assessment and subsequent Council decision-making showing the areas of lower sensitivity with capacity to change. 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.
The Sustainability Appraisal makes use of the settlement analysis. In both cases, these appear to be exclusively desktop exercises and do not include the changes that developments from the last 8 years have made. In the case of Bishop’s Tachbrook, a significant public green space with an extensive public vantage point has been created adjacent to the summit at Tachbrook Hill Farm, but this is ignored in the connectivity analysis. Similarly the recent developments south of Kenilworth have been ignored from its density analysis. Significant settlements such as Harbury and Bishop’s Itchington– adjacent to the Chiltern railway line, with a significant population, broad facilities and connections – have not been considered. Consequently the sustainability appraisal and the settlements analysis is too out-of-date and incomplete. It needs to be revisited with efforts to be accurate, up-to-date and complete so that sound and clear conclusions may be drawn. In its current state if cannot be relied upon to soundly support directions for growth.
I would like to comment on Volume 3, Appendix B of the Sustainability Appraisal. The analyses of the North Leamington Green Belt (at B68 and B74) are inaccurate and suggest that they have been compiled via a desktop exercise using generic tick box indicators rather than any knowledge of the local area. For example, it states that development would be “unlikely to lead to coalescence of settlements”. This is strange given that any development here would subsume Old Milverton and Blackdown into Leamington and would create significant sprawl from Leamington up towards Kenilworth, which at the same time is sprawling southwards due to the development at Thickthorn and other sites nearby. The first two purposes of Green Belt land are to (i) check the unrestricted sprawl of large built-up areas and (ii) prevent neighbouring towns merging into one another. This is why development on these two sites should not be considered. Another problem with the analysis is that it states there will be “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. This is an extreme understatement because the building of houses on these sites would see the removal of the footpaths and any associated recreational experience. In addition, this analysis assumes that the only important function that this area serves is recreation. However, its primary function is as high quality agricultural land and the need to preserve such parcels of land is acutely important in view of national food security.
Drawing your attention to the Sustainability Report Volume 3 Appendix B in reference to areas of the North Leamington greenbelt (sites B68 and B74) - the arguments here are factually inaccurate and should be reconsidered. The greenbelt here is widely used by many in Leamington for relaxation and recreational purposes, as such developing these sites would certainly not have “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”! Further development of the area would also merge Old Milverton and Blackdown in to Leamington and Kenilworth and blur the boundaries between them; as these areas and the prime greenbelt land represent the current breaks between the two conurbations the statement in this appendix that development would be “unlikely to lead to coalescence of settlements” is mistaken as any additional development would do this. If any conclusions have been drawn from these appendices, which presumably they have from their inclusion, then the conclusions themselves are flawed and should be reconsidered.
Again, a completely inaccessible way of presenting the information. I want to complete this response, I know a great deal about good consultation and yet I'm unable to access this information in a sufficient way to be able to respond. Bishops Tachbrook is not a village that can sustain any more development around it without the infrastructure being overwhelmed and bringing gridlock. It just needs an accident on the M40, or on the Banbury Road and it's absolutely impossible to get anywhere. The new school access road onto Oakley Wood Road effectively jams up that route out of the village every morning. And the right turn from Mallory Road to Banbury Road is deadly, and getting worse as the volume of traffic from the left and right increases.
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 interest east of Manor Farm, Stockton Road, with the site abutting the built up area boundary on its western and southern boundaries. The SSL for Long Itchington covers a large area of land around all sides of the edge of the village and partly overlaps the site. 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, this site lies within the least sensitive part of the settlement, within parcel ‘LI01’ as identified in Stratford District Council’s Landscape Sensitivity Assessment (2012). For Parcel LI01 the landscape sensitivity to housing development is considered ‘Medium’ whereas the rest of the settlement is more sensitive (‘High/Medium’ and ‘High’). This is further explained in the enclosed Landscape Statement (FPCR, October 2020). In landscape terms, the aligns with the Council’s own decision-making in this part of Long Itchington, with the adjoining David Wilson Homes scheme to the south at Keepers Meadow considered to have capacity to accommodate change. Furthermore, as demonstrated in the enclosed Landscape Statement and shown on the Development Framework Plan, mitigation can be incorporated within the scheme to enhance the existing strong landscaped and hedgerow boundaries to the north and the east. This will further reinforce the site’s visual containment and its clear alignment with the existing built up area as part of a sensitively designed scheme where landscape impacts are minimised. On the basis of the above, it is clear that landscape sensitivity to accommodate change will not be an overriding factor to future growth at Long Itchington, with the 2012 Landscape Sensitivity Assessment and subsequent Council decision-making showing the areas of lower sensitivity and with capacity to change. 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.
The following comments are made in respect of the SA for Cubbington, which is identified as one of 22 Small Settlement Locations and a reasonable alternative development location. Land east of Coventry Road, Cubbington (Site 176) is being promoted by Rosconn Strategic Land. The site is immediately adjacent to the built up area of Cubbington and also adjoins land that is currently being developed for 17 new dwellings at the former Waverley Riding School, the permission also includes widening and improvement of the existing vehicular access off Coventry Road. A review of the SWLP Sustainability Appraisal indicates that the Site has been excluded from the Small Sites Location (SSL) area for Cubbington. Rosconn Strategic Land request that the SSL search area for Cubbington is amended to include land east of Coventry Road given its sustainability credentials. The SSL for Cubbington (as with other settlements) covers a large area of land around all sides of the edge of the village. Some edges of the settlement will have more adverse impacts than others due to their different characteristics. 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. However it should be noted that the landscape is changing within the east of Cubbington, with land at the former Waverley Riding School east of Coventry Road, currently under construction for 17 dwellings (Ref: W/18/0554). However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and can be mitigated by sensitive design. Site 176 has the advantage of being contained by built development to the south and east, HS2 to the north and east, and Coventry Road and allotments to the west. In landscape and Green Belt terms, the site is very well contained. Agricultural land classification will be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates that there are no in principle impediments to growth at Cubbington, and this is a suitable location for growth. Cubbington is amongst the best performing settlements in relation to SA Objective 2 (Flood Risk) and SA6: (Pollution) given the lack of constraints, and is therefore one of the best performing SSLs. Notwithstanding the above, 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.
The development of sites in North leamington Appendix 3 at Blackdown (p.B68 location B12)and Old Milverton (p.B74, loc B13) will have a major impact on recreational experience as the footpaths around this area are very well used by hundreds of walkers runners, dog walkers from the local area , this is an area that current residents use to exercise for health and mental well being and can arrive there on foot. Development in these areas would destroy this and also means Leamington encroaches ever more on Kenilworth, building work on this edge of Kenilworth too means it feels like the two towns are merging
The assessment of sites at Apendix 3 concludes that development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact upon recreational experience. I do not agree with this and feel it ignores the main purpose of the designated Green Belt particularly in this location. The 5 purposes of Green Belt land include, prevention of the unrestricted sprawl of large built up areas, prevention neighbouring towns merging into one another, assisting in safeguarding the countryside from encroachment and assisting in urban regeneration by encouraging the recycling of derelict / urban land. The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. The assessments are in a 477 page appendix, (page B68 and B74) and are not reference in the main consultation. Both state that development at these locations would be 'unlikely to lead to coalescence of settlements'. However any development would subsume Old Milverton and Blackdown into Leamington Spa. It would also take the outskirts of Leamington up to the southern edge of Kenilworth. This what the Green Belt is designed to prevent. The Green Belt around North Leamington is a valued open space which is easily accessible on foot from North Leamington. I live on Lamintone Drive and observe the number of people / families who make use of the public footpaths across the field on a daily basis. This area of Green Belt has been a real asset to the local community (particularly during the pandemic) and its loss would I believe have a negative impact upon the health and well-being of the local community, who would have to get in their cars and drive to find open countryside to enjoy. There is a growing body of evidence showing the benefits of 'time in nature' and open green spaces, ('Phosphorescence'- Julia Baird 2021), the loss of the green belt would not in my opinion be 'balanced out' by the provision of small patches of green within housing estates. If these proposed developments were allowed I believe this would have a significant negative impact upon the recreational experience available and our community. The agricultural land in the green belt around North Leamington continues to provide rural employment and undergo diversification of farming techniques. Its continued to use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton. The farmland is high quality 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 and Warwick is to the North and East of Leamington, 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 poorer quality land in preference to that of a higher quality'. It would seem unwise to use high quality farmland for housing when food security is at risk due to the war in Ukraine and climate change. The assessments of the two proposed development sites in the North Leamington in the Sustainability Appraisal assumes that the only important function that this area serves is recreation which is a coincidental benefit of he designated actual function of the Green Belt area. It is unclear to me how building on the Green belt will encourage urban regeneration, prevent urban sprawl, prevent the merging of Leamington Spa with smaller communities of Old Milverton / Blackdown and safeguard the countryside for out community and protect it for the generations to come.
The following comments are made in respect of the Sustainability Appraisal for Hatton Station, which is identified as one of 22 Small Settlement Locations and as a reasonable alternative development location. Land east of Oakdene Crescent also lies within the ‘B1 Hatton Station New Settlement option’ with the site forming part of a wider New Settlement. Rosconn Strategic Land therefore support this New Settlement as an area of growth for South Warwickshire. The Site should therefore be assessed as a part of this New Settlement and also as a standalone scheme that can be brought forward to deliver new homes in this area. The Site promoted by Rosconn Strategic Land is located to the east of existing development on Oakdene Crescent and to the south of the railway line (Site 168). The SSL for Hatton Station (as with other settlements) covers a large area of land. Some parts of the area will have more adverse impacts than others due to their different characteristics. Assessing the area 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 location to accommodate growth from this exercise alone. However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and impacts can be mitigated by sensitive design. Site 168 is a small parcel of land contained by built development and the railway line. Its impacts are therefore negligible. Agricultural land classification will be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates that there are no in principle impediments to growth at Hatton Station, and this is a suitable location for growth given its railway station. 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.
It is said here to be "expected" that housebuilding will cater to the needs of residents (and thereby provide affordable housing, student accommodation and old people's accommodation, etc). On what is this expectation based? It is clear that there is a trade-off between house-building and environmental aims here. Stratford and Warwick Districts are said to require more housing than the national average. This is at least in part due to Birmingham and Coventry not being able to provide their full housing allocations. It would be helpful to provide more information as to why these two areas will not be able to do this. The sustainability evaluation makes clear that the 5th Spatial Growth Option should be rejected. The other spatial options may inform the final plan in their different ways. We lean to 2 as, although its advantages here seem small, we anticipate this might change given changes in national policy, e.g. if government gets round to providing for a big increase in public transport provision and subsidisation to make it affordable (or even free, as in some European cities). Have such potential radical changes been taken into account in the Sustainability Appraisal, and other evaluations? I.e. although at present there may not seem to be that much to choose between the different options, it may be that one is substantially more "net zero ready" than others, should national policy be improved. There is no consideration of the trade-off between creating new settlements and additional building on the outskirts of existing settlements, making this question hard to evaluate from a sustainability perspective. The appraisal says that Flood Zones 2 & 3 have "largely" been avoided. But have potential future flooding patterns been taken into account?
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 . 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. 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.
CPRE has submitted our detailed report on Housing and Employment Need which examines the justification for the level of new housing allocations and new employment land that the Issues & Options consultation is proposing as the basis for the Growth Options. The current draft of the Sustainability Appraisal is of limited value because it is using figures for population growth, new housing and employment land need that our report shows are too high and should be significantly lower. Please refer to CPRE's responses to Consultation Questions E1.1, E1.2, H1.1, H1.2, H4.1, H4.2 and H4.3. Should these requirements be less, as we submit, the SA will need be revised. A further important response we wish to make is here is that the Issues & Options states that the HEDNA 'trend' housing projections are more suitable in delivering housing need objectives than the ONS2014 figures because the HEDNA covers the whole of Warwickshire and Coventry. Any conclusion can only be drawn when it is known whether Coventry in its Local Plan Review will drastically reduce its housing requirement figure in line with the HEDNA. The Issues & Options refers to unmet housing need from Coventry. This risks double-counting; there may be no unmet need requirement from Coventry once its Local Plan Review appears, using data from the 2021 Census. The SA is including assumptions about an unmet need from Coventry which is not substantiated. The report submitted with our consultation responses examines this subject.
The proposed developments to the north of Leamington will entirely incorporate Old Milverton and Blackdown. Further the separation of Leamington and Kenilworth will be greatly reduced. The developments will decrease the openness of the countryside to the north of Leamington. They are also almost entirely on good agricultural land which will reduce our food security.
The following comments are made in respect of the SA for Southam. The Site promoted by HLM forms part of Southam Southeast (Broad Location 22). In assessing the four Broad Locations identified in Southam against the SA Objectives, the SA concludes that Southam Southwest is the best performing. That is not the correct conclusion to draw from the Appraisal based on its findings as evidenced below, moreover Southam Southwest is heavily constrained by HS2 which splits the area into two, separating the majority of the Broad Location from the town itself. This site is not therefore a ‘reasonable alternative’ for up to 2,000 homes as part of a single strategic allocation as any new community would be divided by HS2, and therefore the site should not be carried forward in the SA process. Indeed, it is obvious from the assessment of Broad Locations against the SA Objectives at Table 4.1 of the SA that Southam Southeast is the strongest performing Broad Location in the town. The following specific comments are made in relation to the SA and Southam Southeast. SA Objective 2: Flood Risk identifies Southam Northeast as the best performing Broad Location in Southam as it has the smallest proportion of land coinciding with Flood Zone 3. However, and as set out in the SA, Southam Southeast has only a small proportion of land within Flood Zone 3 and indeed this is negligible given it can be easily avoided and mitigated through masterplanning. As such, HLM consider Southam Southeast should be considered equal best performing with regard to SA Objective 2. SA Objective 4: Landscape incorrectly concludes that Southam Southwest is the best performing Broad Location in Southam. The commentary in the SA (at Paragraph 4.11.9) concludes that Southam Southeast is the best performing parcel in terms of landscape sensitivity as it falls within an area of medium landscape sensitivity. The other three Broad Locations contain substantial quantities of high/medium and high sensitivity land parcels which will be more challenging to mitigate, with major adverse effects anticipated. This error should be remedied in the next iteration of the SA. Further, HLM endorse the evidence base that has informed the SA within the Landscape Sensitivity Assessment of Main Settlements including Areas of Restraint Assessment (White Consultants) - July 2011. HLM have supplemented this work with a more up-to-date Landscape and Visual Overview of the town which is appended to these representations. HLM would request the Council take this work into account if it chooses to update its Landscape Character Assessments. SA Objective 5: Cultural Heritage states that Southam Northeast and Southam Southeast are the best performing Broad Locations in Southam. However, in the conclusion Southam Northeast is singled out as the best performing Broad Location without further explanation. This error should be remedied in the next iteration of the SA. With regard to SA Objective 11: Accessibility, HLM acknowledge that connectivity of Southam Southeast would benefit from enhancement through investment in infrastructure and safe pedestrian/cycle crossings of the A423. HLM have submitted with these representations a Wider Connectivity Plan to demonstrate how it would improve and enable connections to the existing built-up area. These include links to the existing underpass under the A423 to the north, a new controlled toucan crossing of the A423 at grade connecting into Stowe Drive, links to the existing signalised crossing point adjacent to the junction of the A423 and A425, and proposed links across Banbury Road. We consider that insufficient account has been taken of accessibility issues elsewhere in Southam, for example school congestion concerns at Southam Northwest and Southam Southeast being effectively cut off from the main settlement because of HS2; this is should rectified in the next iteration of the SA. Given Southam Southeast is free from such accessibility issues, and considering the accessibility enhancements described above, HLM argue that Southam Southeast is the best performing Broad Location when assessed against SA Objective 11. With regard to SA Objective 12: Education, the SA summary suggests that Southam Northeast is the best performing Broad Location in Southam on the basis of having the largest proportion of land within 800m of an existing primary school. However, any strategic development of this scale will include on-site provision of primary education facilities. Therefore at the very least, the Broad Locations should be considered to perform equally in relation to this SA Objective. Southam Southeast also has advantage in education terms due to the willingness of HLM to accommodate a new sixth form centre within this area (as described within the Education Technical Note). This new facility would relieve pressure on the Southam College site, remove traffic generated by sixth form students from Welsh Road West, and improve facilities for students and staff. The new sixth form centre is proposed to form part of a wider Education hub which is to include a primary school, supporting the combination of administration and other facilities which will reduce running costs. As such, it is contended that Southam Southeast performs strongest in relation to Education and this should be reflected in the SA. Taking all of the above into account, it is clear that Southam Southeast does in fact perform best when assessed against the SA Objectives. Southam Southeast performs strongest compared to other Southam Broad Locations and this should be recognised in the next iteration of the SA.
The assessment of the sites at Appendix 3 concludes that development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. I think it ignores the main purpose of designated Green Belt, particularly in this location
Firstly, as a general comment, it is noted from the Introduction and description of the SWLP area that the SA has focussed on what is inside the boundary administered by the two authorities. But the SA should also recognise what is beyond the boundary, and notably Redditch as a major town on its borders that has a significant influence over the western part of the South Warwickshire area. This should be recognised in the description of the area. The following comments are made in respect of the SA for Studley (C.18). The Small Settlement Location for Studley (as with other settlements) covers a large area of land around all sides of the edge of the village. Some edges of the settlement will have more adverse impacts than others due to their different characteristics. For example, land to the north east falls within the flood zones 2 and 3, and land to the north west would increase the risk of coalescence with Redditch. 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. However, it is clear from Table 5.1 that the only major adverse impacts identified relate to landscape sensitivity and agricultural land classification. Landscape sensitivity will of course vary between areas, and can be mitigated by sensitive design and careful masterplanning. Agricultural land classification will of course be a factor that needs to be taken into consideration, but is not an overriding constraint upon development of a site. The SA demonstrates therefore that there are no in principle impediments to growth at Studley, and this is a suitable location for growth given its accessibility to facilities and services, including those within Redditch. 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.
The following comments are made in respect of the Sustainability Appraisal (SA) for Kenilworth. As a general point, the fact that a Broad Location may not be the best performing location does not automatically mean that within that Broad Location there are no suitable sites that should not come forward as a strategic allocation. The Councils will need to 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. The Site promoted by HLM (Site 102) forms part of Kenilworth Northeast (Broad Location 5). It is noted that in assessing the six Broad Locations (BL) identified against the SA Objectives, the SA concludes that parcels to the north of Kenilworth perform better overall. The following specific comments are made in relation to the SA and Kenilworth Northeast. SA Objective 2: Flood Risk acknowledges that only very small proportions of Kenilworth Northeast coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. SA Objective 3: Biodiversity considers Kenilworth Northwest is the best performing BL, but it is very marginal. Whilst Kenilworth Northeast is located within close proximity to a Local Nature Reserve, as recognised in the SA it is possible to mitigate potential adverse effects through layout and location of development. With regard to SA Objective 4: Landscape, reference is made to increased risk of coalescence with Gibbet Hill to the north, although the SA acknowledges that mitigation can be provided to create a robust settlement edge. Such a robust settlement edge is demonstrated as deliverable within the Illustrative Masterplan submitted by HLM, which will not extend the built form of this part of Kenilworth closer to Gibbet Hill than is already experienced. SA Objective 6: Pollution raises concerns in relation to Kenilworth Northeast with regard to coincidence with a Groundwater Source Protection Zone, proximity to an Air Quality Management Zone (AQMA) and vicinity of either a railway line or main road. However, and as acknowledged in the SA, mitigation can be achieved to limit any adverse impacts. SA Objective 10: Health also raises concerns in relation to Kenilworth Northeast with regard to target distances for leisure facilities, GP surgeries and a hospital with an A&E department, and proximity to a main road or AQMA. However, and again as acknowledged in the SA, mitigation can be achieved to limit any adverse impacts. SA Objective 11: Accessibility concludes that Kenilworth North is the best performing BL due to its connectivity score. It is considered that Kenilworth Northeast performs equally as well in the connectivity assessment within the Settlement Design Analysis. It is also within the target distance for a bus stop (Coventry Road). Kenilworth Northeast is therefore equal best performing option; the SA should be amended accordingly in the next iteration. Further, with regard to SA Objective 12: Education, Kenilworth North is considered to be the best performing BL as it will likely require less mitigation. However, Kenilworth Northeast performs equally as well in terms of access to primary, secondary and tertiary education. The SA should be amended accordingly in the next iteration. Kenilworth Northeast performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, what is evident from the SA is that where adverse impacts are identified they can very often be mitigated or avoided.
The following three comments are made in respect of the SA. Firstly, as a general comment, it is noted from the Introduction and description of the SWLP area that the SA has focussed on what is inside the boundary administered by the two authorities. But the SA should also recognise what is beyond the boundary, and notably Coventry as a major City on its borders that has a significant influence over the area should be recognised in the description of the area. Secondly, the Appraisal has only assessed South Coventry for 50-500 homes as a reasonable alternative Small Settlement Location (SSLs) alongside a number of villages. South Coventry has a level of infrastructure, jobs, and services (not least a World Class University) which dwarfs the other SSLs and therefore is out of place in this list. South Coventry is clearly more akin to the Main Settlements, and therefore Broad Locations (BL) should be appraised for up to 2,000 homes as reasonable alternatives. South Coventry as an area is sufficiently large that it could have three or more BLs in accordance with paragraph 3.6.1 of the SA. Further, having regard to Figure 3.3 of the SA, the area around South Coventry is within 800m of service provision that is either existing (e.g. bus interchange at the University, Woodfield Primary School, GP and retail facilities at the University, Tocil Wood Nature Reserve, Wainbody Wood, Crackley Woods Nature Reserve) or planned as part of the Kings Hill SUE or Coventry South Rail Station and Public Transport Interchange. Finally, land has been put forward through the call for sites process in 2021 (including the HLM site 103) which could accommodate a scale of growth up to 2,000 homes in this location, so this is a ‘realistic option’ having regard to Paragraph: 018 Reference ID: 11-018-20140306 of the NPPG. It is not clear from the SA on what basis the HLM site has not been assessed in the SA, with only one site south of Coventry having been assessed as an SSL (C.17). Having regard to Figure 3.3 of the SA, the entire HLM site falls within 800m of the existing Woodfield Primary School, and the planned Primary School which is part of Phase 1 of the Kings Hill SUE to the immediate north of the site (illustrated within the Vision Document). Whilst it is acknowledged that Woodfield Primary School is a special education school, and that the primary school at Kings Hill SUE is yet to be built, it will be within the next 5 years based on the Council’s Housing Trajectory. Further, the Transport Authorities for the area have consulted on a new train and bus station/interchange within the HLM site, and are planning for its delivery during the early part of the Plan period (as illustrated within the Vision Document). In respect of GP surgery and local shop, all of these facilities will be provided within the Kings Hill SUE to the north of the site. This is likely to be slightly beyond 800m, however, the HLM site is of a scale such that it has capacity to accommodate a GP surgery and local shop within a local centre as illustrated within the Vision Document. In respect of publicly accessible greenspace, the majority of the site is within 800m of Wainbody Wood to the north as acknowledged within the Landforms Analysis in the Settlement Design Analysis. The HLM site does therefore satisfy the criteria within Figure 3.3 for primary schools and publicly accessible greenspace, and can satisfy the criteria in respect of all other elements during the Plan Period. As only one criteria needs to be satisfied, the HLM site is therefore a BL and should be assessed as a reasonable alternative. An overly rigid application within the SA of Figure 3.3 that ignores planned service provision that is to be delivered early in the Plan period, and ignores potential service provision that can be delivered within the site, will result in missed opportunities to contribute sustainably towards growth up to 2050. It is worth remembering that paragraph 73. a) requires Councils to consider the opportunities presented by existing or planned investment in infrastructure when deciding the location of new development. The SA should therefore take into account the planned facilities at Kings Hill SUE. The HLM site 103 is well placed to achieve the 20 minute neighbourhood principle for all services listed in Figure 3.3, and is therefore a BL reasonable alternative which HLM would request be assessed as part of the next iteration of the SA. Failure of the SA to appraise realistic growth options south of Coventry as a reasonable alternative could result in the Plan not demonstrating that its proposals are ‘appropriate’ and ‘justified’.
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 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. 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.
The following comments are made in respect of the SA for Kenilworth. As a general point, the fact that a Broad Location may not be the best performing location does not automatically mean that within that Broad Location there are no suitable sites that should not come forward as a strategic allocation. The Councils will need to 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. The Site promoted by Richborough Estates forms part of Kenilworth South (Broad Location 8). In assessing the five Broad Locations (BL) identified against the SA Objectives, the SA concludes that parcels to the north of Kenilworth perform better overall. However, given the planned growth south of Coventry, parcels to the north of Kenilworth are likely to be less acceptable in relation to Green Belt purposes and preventing neighbouring towns merging into one another. It is also noted that a large parts of these areas have not been submitted through the call for sites. If a large proportion of the land is not available, this is not a ‘reasonable alternative’. The following specific comments are made in relation to the SA and Kenilworth South. SA Objective 2: Flood Risk acknowledges that only very small proportions of the area coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. SA Objective 3: Biodiversity considers Kenilworth Northwest is the best performing, but it is very marginal and Kenilworth South performs equally as well and should be assessed as such. Further, any effects can be more than mitigated within the site as evident for site 199 as part of this BL within the Vision Document submitted by Richborough Estates with the call for sites submission. It is noted for SA Objective 4: Landscape that additional surveys are required to understand latest sensitivity qualities at each BL. This is welcomed and little weight can be attributed to this assessment in the absence of this information. Any survey undertaken should have regard to the landscape evidence provided within the Vision Document submitted by Richborough Estates for site 199 with the call for sites submission. Reference is made to increased risk of coalescence with Leek Wootton to the south, although it acknowledges that mitigation can be provided to create a robust settlement edge. Such a robust settlement edge is demonstrated as deliverable within the Vision Document submitted by Richborough Estates for site 199 with the call for sites submission. SA Objective 5: Cultural Heritage notes the potential major impact of Kenilworth South on the setting of Wootton Grange Farmhouse. This asset is identified in the Heritage and Settlement Sensitivity Assessment but not identified as a constraint, and the area is assessed as ‘Green’ and therefore the equal best performing option. Any harm to this asset can easily be avoided through careful masterplanning and providing an appropriate buffer. As the Heritage Assessment confirms this is the equal best performing option, the SA should be amended accordingly in the next iteration. SA Objective 11: Accessibility concludes that Kenilworth North is the best performing BL due to its connectivity score. Kenilworth South performs equally as well in the connectivity assessment within the Settlement Design Analysis. It is also within the target distance for a bus stop (Mortimer Road). Kenilworth South is the equal best performing option, the SA should be amended accordingly in the next iteration. Further, with regard to SA Objective 13: Economy, Kenilworth South falls within the sustainable target distance for employment, and therefore performs equal best. The SA should be amended accordingly in the next iteration. Kenilworth South performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, what is evident from the SA is that where adverse impacts are identified they can very often be mitigated or avoided. However, the key constraint of heritage limits development of the town to the west, the A46 is a strong barrier to the east, and the planned growth south of Coventry limits growth to the north. The most logical location to extend Kenilworth is to the south, provided a strong robust edge is provided to avoid any risk of future coalescence with Leek Wootton. Richborough Estates have put forward proposals to the Council as to how this robust edge could be delivered and retained in perpetuity.
The following comments are made in respect of the SA for Warwick. The site promoted by Richborough Estates forms part of Warwick West (Broad Location 32). In assessing the three Broad Locations (BL) identified against the SA Objectives, the SA concludes that parcels to the east and west of Warwick perform better overall. It should be noted that Warwick Northeast falls within the Green Belt and so should only be considered where all other reasonable options (such as Site 214, the part of Warwick West that falls outside of the Green Belt) have been fully examined. It also should be noted that the boundary of Warwick West can be extended to include land available to the north that falls between the racecourse and the A46 (as illustrated as site 214). This land to the north has a role in mitigating any adverse impacts arising from the SA, for example in relation to ecology, and so should be included within the next iteration of the SA. The following specific comments are made in relation to the SA and Warwick West. SA Objective 2: Flood Risk acknowledges that only very small proportions of the area coincide with Flood Zone 3, and therefore there is negligible impact. All BLs perform arguably equally, and should be assessed as such. It is noted for SA Objective 4: Landscape that additional surveys are required to understand latest sensitivity qualities at each BL. However, the conclusion that Warwick West performs best is agreed, particularly in respect of the part of the Broad Location that falls to the east of the A46 and thereby contained within the urban area. Reference is made to increased risk of coalescence with Hampton on the Hill to the west, although this would be avoided if development is limited to the eastern side of the A46. SA Objective 5: Cultural Heritage notes the potential negative impact of Warwick West on the setting of the Warwick Conservation Area. This is identified in the Heritage and Settlement Sensitivity Assessment, where it considers there is ‘little scope for development within the bypass without causing harm to the asset’ and accordingly the site is assessed as ‘red’. It is recommended to the Councils that this Broad Location is not dismissed on the basis of this evidence alone for the following reasons. Firstly, the Assessment itself acknowledges this is a ‘high level’ assessment undertaken without the benefit of a site visit. Richborough Estates have undertaken a more detailed assessment, including site visits, to arrive at an illustrative masterplan for the area within the bypass. This masterplan retains views across the area from St Mary’s Church and the town centre to the countryside beyond the A46, sets any development back from the Racecourse Conservation Area to ensure a sense of openness around the asset, and retains field patterns to the north of the site filtering any views of development from the Canal Conservation Area. These three components of any masterplan avoid harm to the setting of the assets. These components are illustrated within the Vision Document submitted with the call for sites form by Richborough Estates. Secondly, the Assessment appears to have incorrectly identified the area as ‘red’ and as it does not identify any potential major impacts within the report. Any major impacts could be avoided and so the area should not be classified as ‘red’. Richborough Estates fully acknowledge that this is a sensitive area in heritage terms, and that careful masterplanning is necessary to avoid or limit harm to the setting of the Conservation Area. This requires a more detailed assessment than the high level assessment undertaken, and Richborough Estates would be happy to work with the Councils in undertaking their more detailed assessment as part of the next iteration of the Plan. SA Objective 11: Accessibility concludes that Warwick Northwest is the best performing BL due to its connectivity score. Warwick West performs equally as well in the connectivity assessment within the Settlement Design Analysis, save for the Analysis has concluded that the land north of the existing racecourse straight within the bypass has the poorest connectivity (E). It is not clear from the text why this part of the area has been assessed differently to land to the south of the straight. Access to the land to the north can be provided around the racecourse straight as illustrated within the Vision Document submitted with the call for sites submission by Richborough Estates. This parcel of land therefore has the same connection to the town as the remainder of the broad location assessed as (D). Warwick West is therefore the equal best performing option, and the SA should be amended accordingly in the next iteration. Further comments are made on the Settlement Design Analysis under Q-S4.2. SA Objective 12: Education concludes Warwick Northeast is the best performing option, however this does not reflect the analysis in Appendix B which places them as equal with Warwick West. Moreover, Warwick West is within 1.5km of Aylesford School, Warwick and therefore within the target distance. Warwick West has therefore been incorrectly scored, and is therefore the best performing option and this should be amended in the next iteration of the SA. 18. Warwick West performs better than has been recorded in this SA, and this should be recognised in the next iteration of the SA. Further, what is evident from the SA is that where adverse impacts are identified they can be mitigated or avoided. 19. The key constraint to growth at Warwick is the A46 which is a strong barrier to the west. The most logical location to therefore extend Warwick is on land between the town and the A46, and to do this in a way that avoids and minimises any harm to the heritage assets. Richborough Estates have put forward proposals to the Council as to how Warwick West (within the bypass) could come forward in a comprehensive and sensitive manner, and we would request the Councils allocate site 214 for strategic development.