5.4.6 Infrastructure Requirements

The present traffic infrastructure is repeatedly critically overloaded at peak times & this development will greatly exacerbate the situation not withstanding some titivating of short lengths of additional lanes & traffic lights at the roundabouts.
Racetrack use along "the straight" of Glasshouse Lane (30mph limit, 50± not uncommon) will inevitably be the cause of further accidents, as it is used as a "rat run" to avoid the choked Warwick Road.

5.4.9
Urbanization of a small tourist town. How does this wider roundabout fit in with Stoneleigh Park slip roads off of the A46? The back log of traffic when lights were put in for Sainsbury's leads me to question the traffic arrangements. This needs to given a great deal of thought because of so many implications. Appearance of arrival to the tourists they do not want to spend time backed up in traffic and neither do the locals..

Ref Para 5.4.17
Sport England has been supporting WDC in the preparation of the playing pitch strategy and sports strategy. Therefore we support this statement.

Re Paragraph 5.2.24 - relocation of the sports grounds. At the Kenilworth Community Forum on 1st July, Castle Farm was suggested as an alternative venue for the Wardens and the Rugby club. Any move to Castle Farm will have a knock on effect on traffic and consequently noise and wildlife through the residential and semi rural areas surrounding Borrowell Lane and Castle Road. It is already difficult to pull out from Borrowell Lane and the access road to Castle road, onto Castle Road and increased traffic from sports grounds would seriously exacerbate this. There is already a high volume of traffic along Castle Road as a main route to Birmingham, and any increase would create substantial noise pollution and damage the environment around the Castle grounds.

Dear Sirs,

KENILWORTH TOWN DEVELOPMENT PLANS:
CASTLE FARM AND THE MERE PROJECT

1. I and my wife Catherine are at present abroad and unable to attend the various meetings at which it is understood it maybe decided to turn Castle Farm at the rear of our property into the new Kenilworth Rugby club with associated facilities including a road junction and road from Castle Road to the new development which will inevitably have the most severe impact on the existing quality of life for the residents on that side of Castle Road, quite apart from the additional risk of serious accidents on what is already a very scary road.

2. Castle Road residents benefit from the presence of the Abbey Fields on one side and an agricultural aspect and views and ready access also available to other members of the public including dog walkers especially up to the Castle. There is no doubt that all of the latter will either be significantly disrupted or disappear as soon as the bull dozers arrive on site.

3. We are also highly concerned to learn of the "Mere" project, which would appear to be a very expensive and unwanted development for which the motivation is commercial since apparently a hotel complex is going to be incorporated into that development. I have lived in Kenilworth for 57 years and one of the great sources of local pride to me and the several thousand other residents/ratepayers has been the knowledge that we the people of Kenilworth are the owners of our Castle as is evidenced by the huge amount of support which the periodic events at the Castle receive from the local population. Whilst the reasons for allowing English Heritage to take over the management of the Castle are generally understood, it does now appear that that was just the first step in a process which will further limit the access and enjoyment of the Castle and its surrounds by those who actually own it.

4. Quite apart from which there is huge concern about the drainage consequences of the construction of the mere. No one who lives in Kenilworth is unaware of the periodic floods which occur in parts of the Abbey Fields adjacent to Castle Road. What is not generally known is that properties on the opposite side of the road are also subject to a particularly high water table which has in the past resulted in the flooding of cellars and there is a real risk that the presence of the mere will raise the level of the water table further with disastrous results.

5. We therefore wish to add our objections to both of these hugely damaging development proposals in the hope that these matters are not permitted to proceed further.

On behalf of Kenilworth Runners, we would very much like to suggest the inclusion of an athletics track in Kenilworth, in the Local Plan for Warwick District, covering the next 15 years. (A track is incorporated in the Kenilworth Town Council Action Plan, demonstrating local support for this proposal)

If the housing stock of Kenilworth, and its population, is to grow, we believe the provision of facilities to the town should improve commensurately.

We are extremely keen to support the inclusion of an Athletics track in the plan for any redevelopment of sporting facilities in the town, and believe this could be well accommodated in the relocations of other sports clubs to Castle Farm Recreation Centre site. This would provide both schools and Community Groups an excellent facility to support the health & leisure of local residents.

Kenilworth Runners currently operates from Kenilworth Wardens Cricket Club on Glasshouse Lane, but without the benefit of an Athletics track, we are firmly limited at present, to being a road and cross country club. Anyone interested in taking part in athletics is forced to travel out of town, to either Coventry or Leamington.

The club is thriving and successful and has grown to almost 200 adult members with a diverse range and ability of runners, from 18 to 72 years old, county standard to beginners. We currently have no Junior or Youth section due to our inability to offer a safe environment in which to train, but would like to develop the club in this direction in the future.

We believe the inclusion of an Athletics track in the plan for any redevelopment would, be a tremendous benefit to the Kenilworth community.

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.

Conservation Advisory Forum
Comments on Local Plan Consultation Housing Sites

CAF Meeting 18 July 2013


* Scale of development. Concerns expressed about impact on Warwick . There will be a 40% increase in the population of Warwick which will have a dramatic effect on the existing settlement and on traffic passing through both Warwick and also Leamington along Europa Way.

* Sustainability. It is not considered to be a sustainable development rather suburban sprawl.

* Traffic impact . Significant concern expressed about the impact of traffic on the Conservation Areas in particular the increased use of Banbury Road and the need for upgrading of the road system and the impact on Castle Hill roundabout and the bridge over the River Avon which is a Listed Building.

* Increase in car usage .This type of development reverses the trend over the past 20 years a small scale infill and the reduction of car usage. These proposals will increase car usage which will impact upon the historic Town Centres, as all the sites are only accessible by car. This will have a roll on effect in terms of the transport infrastructure and will make everyone else use cars.

* Impact on cycling . It was felt there was no scope for cycling because of the intensity of traffic.

* Release mechanism for sites .The release mechanism of sites was questioned. It was felt that the present system will lead to sites being built on regardless of whether there is any infrastructure to support them. A staged approach is needed for any sites within the district.

* Impact on historic buildings .The impact of traffic entering the Town Centre will impact upon all the major junctions and will impact upon the Historic Buildings themselves and the setting of them.

* Thickthorn , Kenilworth .It was pointed out that Kenilworth did their own consultation and have come up with the Thickthorn site as the best of the options if we have to meet the five year housing supply.

* Infrastructure for Kenilworth . Kenilworth needs to have adequate infrastructure of eco houses and appropriately relocation of the various clubs that use the Thickthorn site before development commences.

* Integrated transport system. Kenilworth needs an integrated transport system with a proposed new station, each house being provided with two parking spaces.

* New Hospital .It was felt that to support the level of development a new hospital would be needed in Warwick.

* Transport mitigation measures .The impact of transport mitigation measures on Warwick would include a 3-4 lane Banbury Road development, traffic signals at Bridge End roundabout, effects on Listed Castle Bridge, gyratory system at the Castle Hill roundabout and traffic lights. All roads will have a greater amount of traffic; there will be significant effects on air pollution and the quality of air in the Town Centre. Congestion charges were suggested. It was felt that if traffic was removed completely the High Street shops would suffer.

* Station Approach site - it was felt that it should follow the SBD for that site.

* Student accommodation . It was felt that if more students were to be housed on Warwick and Coventry University sites this would release more houses in Leamington Spa for use by families and would reduce the housing need overall.

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