It is unclear how the evidence base has been assessed to construct a preference in favour of the site abutting Smith's Covert in Hatton Park.

WDC appears to discount four other sites on the grounds that these either represent a threat to potential Local Wildlife Sites or constitute unwelcome ribbon development. I fail to understand why the same reasoning does not apply to Smith's Covert? This is a valuable tract of ancient woodland that harbours a variety of wildlife and fauna and is a potential Local Wildlife Site. In particular, it is an important roosting area for bats and many birds (including buzzards and owls). I should like to draw to the Council's attention the following recommendation in a study it commissioned and made public in 2008:-

(See page 67 of the Warwick District Habitat Assessment Habitat Biodiversity Audit Partnership for Warwickshire, Coventry and Solihull c/o Warwickshire Museum Field Services The Butts, Warwick, CV34 4SS August - published October 2008):

"Bats can be found in many buildings and trees, even those that initially appear to be unsuitable. Bats and their roost sites are protected under the 1981 Wildlife and Countryside Act, the Countryside and Rights of Way Act 2000 and the Habitat Regulations 1994, the latter of which deems them a European Protected Species. Therefore it is recommended that a pre-determinative bat survey of the buildings, woodland and mature trees is undertaken at an appropriate time of year by a qualified ecologist.

Recommendations The three pLWS/SINCs (Smiths Covert SP26N2, Budbrooke Farm Woodlands and Black Brake Plantation SP26T1 and Brownley Green Lane SP26N1) should be retained and a buffer zone implemented to prevent direct or indirect impact on the sites."

It appears that the Council has yet to act on this recommendation but is nevertheless recommending in the New Local Plan an environmentally detrimental housing development.

Further, I also note in Appendix 6 of the New Local Plan (page 280) it comments on preferred site 1: "Large open field site which has good connectivity to Hatton Park. Requires substantial
Environmental buffering to the north and east of the site and further work required on site access and localised surface water flooding." The matter of flooding should not be taken lightly and remedial works would be overly invasive and environmentally damaging. I note also that WDC indicates that Smith's Covert may be designated a Local Wildlife Site: "Smiths (sic) Covert potential Local Wildlife Site is to the north of the site." (also page 280).

On pages 233-36 in Appendix 7 of the New Local Plan (Warwick District Council Landscape Sensitivity and Ecological & Geological Study Produced jointly by WCC Ecological Services & Habitat Biodiversity Audit and WCC Landscape Architects November 2013), it appears that the Council's consultants believe that a small ribbon of trees extending only at least 10m would suffice to screen and protect the environment (p. 236): "It is also imperative that a landscape buffer of native trees, at least 10m in width, should be created to maintain a visual link and wildlife corridor between Smith's Covert and the wider countryside to the east." This would be a woefully inadequate remedial measure. Were any development within site 1 to take place, which in my view should not be allowed, a buffer extending at least 100m should be created using Ash and Oak saplings and native shrubbery.