Object

Representation ID: 57013

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Generally support the Council's broad location of development in so far as it seeks to accommodate growth within and on the edge of the existing urban areas.

However, in order to accommodate housing where it is needed there will be a requirement to review Green Belt boundaries, especially around key sustainable settlements for example, Kenilworth.

In addition the need to identify "areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet the longer-term development needs stretching well beyond the plan period." (NPPF para 85) has not been addressed in any of the evidence base documents or the RDS.

In the case of Kenilworth, which is recognised as one of the most sustainable centres in the District, there will be a need to accommodate further growth beyond the current plan period.

For the reasons set out in the current SHLAA and at paragraph 4.3.12 of the RDS it is accepted that there are limited opportunities for growth within the existing built up area of the Town.

As such growth will have to take place on edge of the Town within the Green Belt. In such circumstances the NPPF requires that land be 'safeguarded' to avoid further reviews at the end of the development plan period (paragraph 85 NPPF).


Paragraph 4.3.12 of the RDS recognises the need to expand in to the Green Belt in Kenilworth due to the lack of non-Green Belt options. However, no justification has been set out as to why the "Land at Thickthorn" is the "least harmful alternative in terms of the purposes of Green Belt land."

Indeed, in the Joint Green Belt Review, January 2009, all of the land to the east and north-east of Kenilworth is identified as being 'least constrained'. Table 6 of the Joint Green Belt Review assesses the various sites and the land at Thickthorn is given the same score (8.5) as sites K17 and K19, referred to in the report as site K4.

The Landscape Assessment in the Green Belt Review gives the same score (1 - low value) to both Thickthorn and K17/K19) in landscape impact terms recognising that the A46 forms a definitive boundary to built development in this part of Kenilworth.

The more recent landscape assessment commissioned by the Council does not refer to land around Kenilworth at all.

The question of whether the proposed site at Thickhorn is the most sustainable option is questioned on the basis of the findings of both the initial SA (May 2012), and the Final Interim SA Report (June 2013)

Both sites are equally as sustainable with regard to the criteria set out in the NPPF. Transport and highway issues have been fully researched by highway consultants acting for client and has been found not to be a constraint to bring sites K17 and K19 forward.