Object

Publication Draft

Representation ID: 65209

Received: 24/06/2014

Respondent: Kenilworth Society

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Local Planning Authority has not involved the community in the preparation of this part of the Plan. Kenilworth School, Leyes Lane , was not in the list of housing sites in the "Revised Development Strategy" that was published for public consultation in June 2013.

Full text:

Reasons for Objection

The Kenilworth Society considers that the
The designation of H09 as a housing site is unsound because:
a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. Kenilworth School, Leyes Lane , was not in the list of housing sites in the "Revised Development Strategy" that was published for public consultation in June 2013.
b) The Sustainability Appraisal of Site H09 is inaccurate and unsatisfactory. Appendix V page 3/87of the SA states that
"...there is only a very low/ low risk of surface water flooding." This is incorrect. The Environment Agency website's map of "Risk of Flooding from Surface Water" shows approximately one third of the site as being at some risk of surface water flooding. Parts of the site are shaded dark blue, indicating that they are exposed to a high risk of flooding. Plans to put dwellings, roads etc on this site would have to address this problem, and also the dangers of acerbating drainage problems offsite. Much of the watercourse (the Millbrook) into which this Kenilworth School site drains is coloured in dark blue on the Environment Agency's map of "Risk of Flooding from Surface Water".

In the opinion of the Kenilworth Society the Sustainability Appraisal's formula for dealing with drainage - "Mitigation is offered to a certain extent by the NPPF which requires that new development should not increase the risk of flooding elsewhere" - is inadequate when applied to sites that pose serious and specific problems.

c) As said in our submission on Site No. ED2, we do not believe there is adequate justification for moving Kenilworth School to Southcrest Farm. We understand that operating on split sites creates problems for Kenilworth School, but the Southcrest Farm is not the only, nor necessarily the best option. The proposed solution appears to be driven by the county Council's desire to raise money from the sale of land for housing rather than the needs of the local community.