Object

Representation ID: 57017

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

Object to the proposed allocation of land at Thickthorn, Kenilworth and also to the 700 dwellings proposed for following reasons:

Housing Number:
Object to the number of 700 dwellings to Kenilworth (see also objection to RDS4) . The final distribution should await the publication of the NPPF compliant update to the SHMA and joint working with neighbouring authorities. For this reason alone, the site area should be increased to include land at sites K17 and K19.
Capacity at Thickthorn:

* The land at Thickthorn (confirmed at 46.5 ha) is constrained by a number of factors that have been identified in detailed technical surveys that we have undertaken, including:

* the need for noise bunding due to proximity of the A46;

* ancient woodland;

* heritage assets - the Manor & Stables and Scheduled Ancient Monument;

* the need to replace two large areas of playing fields/sports grounds;

* the need for areas for water attenuation;

* proximity to existing housing; and,

* the presence of two local wildlife sites and the need to have 50m buffers around the sites and woodland.

Considers that the land at Thickthorn is not capable on its own of accommodating the proposed 700 homes. (Based on an assessment set out in the representation of the housing capacity of the site at different densities-allowing, for open space, community facilities, green infrastructure, education and employment requirements)

Stresses that the capacity figures are significant over estimates as many of the constraints on the site are greater than currently stated and the density figures are more likely to be around 25 - 30 dph for this site.

Furthermore, the clear view coming out of the public consultation carried out by Kenilworth Town Council on its Area Action Plan was that development should stop at Rocky Lane and that the current playing fields should either remain or the land given over for open space. This would further reduce the capacity of the site.

Playing Field/Sports Pitches:

The RDS acknowledges at paragraph 5.4.24 that the three playing fields/ sports pitches are a potential constraint to the development coming forward in its entirety.

Standing advice from Sport England is to object to the loss of such facilities unless suitable and convenient replacement facilities can be provided.

Sport England Require Local Plans to be justified with appropriate evidence. Aware that work on a Playing Field Strategy is on going but no timetable is in place for its conclusion. No informed decision can be therefore be taken on whether to include the playing fields until such a Strategy has been prepared and/or replacement facilities are provided in close proximity to meet the Sport England tests.

Encouragement for Sports Facilities

The Garden Suburbs prospectus encourage sports pitches/playing fields as part of a well planned, integrated, mixed use urban extension. It seems illogical to therefore move established facilities that are both convenient for local residents and ideally located to help plan a sustainable urban extension for Kenilworth.

Deliverability

Paragraph 173 of the NPPF confirms that "pursuing sustainable development requires careful attention to viability and costs in plan-making and decision taking. Plans should be deliverable."

The Thickthorn land is owned by several different landowners. There is no certainty that the land will come forward for development as a collective whole, as required to deliver the well planned and phased approach to development that is supported in the RDS and is essential for delivery of the key infrastructure required for the .

No assessment of the viability of the scheme has been made.

Alos, there are in consistencies between the requirement for 40% affordable housing on the site and the findings of the Warwick District Council Affordable Housing Viability Assessment Final Report, Nov 2011 that concludes that no development was viable at 40% affordable housing provision.

For the above reasons the allocation of the site at Thickthorn is uncertain and as currently drafted is unsound. Given the need to provide land for policy consider PO4 as it relates to Thickthorn is unsound.

Changes proposed to address the objection:

It is proposed that rather than looking at land at Southcrest and Woodside Training centre as different to Thickthorn, a comprehensive approach to the future growth at Kenilworth should be taken including all of the land to the east of the town.

This will enable:
* the principle of a Garden Suburb to be advanced.
* provide for retention and enhancement of the playing fields and provide expansion for employment uses close to the A46 junction.
* It will also enable greater mitigation in terms of noise and buffers around the ancient woodland and Scheduled Ancient Monument.

The above stance accords with the aims and objectives of sustainable development set out in the NPPF, that encourage longer term planning and the Garden City approach to development. The increased area of land would also enable the proposed housing numbers to be delivered and increase flexibility in the Plan. These changes would result in a sound strategy for development at Kenilworth.