Interim Sustainability Appraisal

Comment

Representation ID: 53419

Received: 29/07/2013

Respondent: Mr Rod Scott

The SA document is very detailed and comments on individual statements are difficult to make without expert knowledge. Where local knowledge is available to me on the location of site 16 in the Gipsy and Traveller site appraisal I was surprised to find that this was noted to 'fall within a medium flood risk zone202'.
As this area is a pond and is specifically designed as a rainwater run-off for the by-pass I would have classed this as permanently flooded and thus extremely high risk!
This error does cast doubt on the usefulness of the whole document.

Object

Representation ID: 53660

Received: 26/07/2013

Respondent: Mr Paul Newton

Concern about access to Leamington town centre from South Leamington, Warwick Gates and Whitnash as only three routes exist; one frequently closed due to flooding and another already suffering from excessive traffic congestion.

Object

Representation ID: 54865

Received: 10/07/2013

Respondent: Ann Jennings

Final Interim SA Report (enfusion) defines sixteen objectives for each site which are then 'rated' according to their potential suitability for each site. This process does not appear to have been executed with due diligence: Why have some appraisal summaries in the report been carried out giving inaccurate information, and others been left incomplete or with a question mark, when the information is readily available and could have been used to give a more sensible and useful conclusion?
Item 16: Crime is given a rating for each of the 20 sites. Why has this objective been itemised on both the report and the response forms on which local residents are invited to make their comments and what does it mean by 'crime'? Comments in opposition from local residents which mention fear of an increase in crime on any response forms would be indicative of racism and therefore unacceptable, despite the fact that this is a factor defined by the council as an 'area of concern'. Please could you clarify this issue?

Concerned that it is the responsibility of the Council to employ suppliers who will execute due diligence in their work, and for the council to ensure that such a task is carried out to a high level of efficiency? This report was commissioned and published by the Council and is therefore your responsibility.

Expects a 'high level appraisal' to contain accurate facts. With regard to one of the sites mentioned, a neutral rating is given by Enfusion including an assertion that the site is close to a GP Surgery (within 1.5 miles). It is not. The closest GP surgery, is more than twice that distance away (3.3 miles), and a single phone call would confirm that that particular surgery is closed to new patients. The next closest is 4.7 miles away.

A 'high level appraisal' would compare like with like. One site is given a positive rating for travel and transport as there is access to a bus stop. Another site is also given a positive rating for having access to a bus stop. One of those bus stops however is in an overgrown grass verge in a rural location on a dangerous road, with no pavement or street lighting. The other is sited on a far safer road, with a pavement. On the surface they are comparable, but in reality they are far from it.

Having only been involved with looking in detail at one site, I cannot comment on any other inaccuracies that may be contained in the document, but I am not filled with confidence that there are not more basic errors in the report, or that comparisons are uniform across the different sites.

I do appreciate that at this stage the appraisal cannot be more detailed but I would expect 'like' to be compared with 'like' in order to make an informed comment with regard to relevant factors. And I would certainly expect basic facts to be correct.

In my particular area of interest alone, there has already been one lost house sale and a demonstrable loss of future business as a direct result of this small element of the Local Plan. There are also many of those most directly affected whose lives have been thrown into complete chaos by the proposals, and this effect will undoubtedly multiply out across the various proposed sites, whether they are Gypsy and Traveller related or simply with regard to proposed new housing.

Whilst this will always be a predictable consequence of any such report, I would have thought that, given the devastation that is currently being caused in the lives of many local residents, the Council and its chosen supplier(s) would at least have due regard for its effects by ensuring the highest possible level of accuracy.

Support

Representation ID: 56486

Received: 29/07/2013

Respondent: Natural England

Natural England welcomes the production of the Final Interim Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA). The Interim Report provides a clear narrative of the SA / SEA process. We note the conclusion that the focus of development to the south of Warwick, Leamington and Whitnash has the potential for significant cumulative long-term negative effects on landscape and the historic environment but that careful planning and design is expected to mitigate these impacts. We note the imperative for sustainable design to protect and enhance the landscape and historic environment, as well as biodiversity, air, water and soil quality.

Object

Representation ID: 57022

Received: 29/07/2013

Respondent: Gleeson Developlments Ltd and Sundial Group

Agent: Savills (L&P) Ltd

The consideration of the Options for the Distribution of Sites for Housing refer to the potential impact on heritage to the east of Kenilworth.

However, in the options with less development at Kenilworth the SA report states that the impact on the heritage assets will be less. This is not necessarily the case and will depend on the layout and location of the proposed housing not just the quantum.

Paragraph 4.58 of the SA Report refers to Thickthorn and confirms the potential long term negative impact on Thickthorn Manor and Stables which are Grade II listed buildings. Parts to the north-east of the site are also within a Scheduled Ancient Monument. The document identifies the need for buffer strips around the woodland and along the edge of the A46.

Paragraphs 4.107 - 4.109 refer to sites K18 and K19. The SA should refer more precisely to sites K17 and K19 which is in the control of Gleeson and the Sundial Group and is available for development.

Land at Crewe Gardens Farm is not being actively promoted. As set out in the above representations, sites K17 and K19 should be assessed in the SA report as an extension to the land at Thickthorn and not as an alternative to it. The current SA wrongly appraises the land.

In addition, concerns are raised regarding statement re visibility at the existing entrance to and from the site. Client's highways report has demonstrated that good visibility can be provided to a number of access solutions to the land to serve a development scheme. The site should not been marked down for having poor visibility at an existing access point when this will be resolved in any new layout.

Draft masterplan layouts for the site that have been circulated to Officers and Members clearly demonstrate that the site can be developed without any impact on the Scheduled Ancient Monument or its setting.

Table 4.1 in the SA Report rejects Glasshouse Lane/Crewe Lane on the basis of "updated landscape and transport evidence suggests more development could be delivered to the south of the district on non-Green Belt Land."

The site has not therefore been rejected on any site specific grounds. If it is shown that further housing growth is required at Kenilworth either now or in the next plan period the land should be taken out of the Green Belt now and safeguarded in accordance with the advice in the NPPF.

Comments on the site assessments have been made elsewhere.

Support

Representation ID: 62078

Received: 29/07/2013

Respondent: Environment Agency

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".