Sustainability Appraisal - Publication Draft

Object

Representation ID: 65414

Received: 27/06/2014

Respondent: Cllr George Illingworth

None of the Sustainability Appraisals appear to admit the existence of the proposed HS2 route and its likely effects, which in some cases could be significant.
As a minimum those particular areas that are likely to be affected should be updated. That will possibly include:
K2 Crackley Triangle
BG1-7 Burton Green
CU1-7 Cubbington
KO7 Kenilworth Golf Course

Object

Representation ID: 65576

Received: 27/06/2014

Respondent: Cllr George Illingworth

In Appendix V of the Sustainability Report SHLAA Ref K29 is about the Kenilworth School site. It states that there is only a very low/low risk of surface water flooding and refers to footnote 4. However that footnote states it relies on the Environment Agency (2014) Flood Maps - Risk of Flooding from Rivers and Sea. The correct reference should have been to the Environment Agency Flood Maps for Surface Water Flooding which shows that a significant part of the site is at risk with some of it at high risk.

Object

Representation ID: 65578

Received: 27/06/2014

Respondent: Cllr George Illingworth

In Appendix V of the Sustainability Appraisal Report K02 is Crackley Triangle. The Appraisal sates that this area is in the Green Belt. It is not.
This error significantly affects the Assessment which could have consequences in site allocation.

Object

Representation ID: 65742

Received: 24/06/2014

Respondent: Whitnash Residents Association

Alternative sites not fully investigated
Question calculation methods for housing requirement with new migration information omitted
Large shortfall in money to provide health facilities, schools and transport
Air quality in towns above legal limits and will be major health hazard and this has not been fully investigated
Revise Housing numbers in light of new figures released on migration/population
Less sites will then be needed
Less infrastructure needed so costs will be less. Fewer cars will result in less pollution

Object

Representation ID: 66413

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

The proposed Plan is unsound because there is no evidence that Policy DS16 is justified. The Plan should be the most appropriate strategy when considered against reasonable alternatives. There is no evidence that there has been a balanced evaluation of reasonable alternative sites. The Sustainability Appraisal claims major positive economic effects but does not seem to have included analysis of the environmental effects of the Sub-Regional Employment Site (Gateway) proposal. The proposed Plan, with its SA, is unsound.

Object

Representation ID: 66417

Received: 27/06/2014

Respondent: Hazel and Robin Fryer

Paragraph 5.27 & 5.31 SA objective 14 - The adverse health impact of implementing DS16 is ignored - the development proposes 1000 lorries will travel each day close to existing housing at Baginton.

Object

Representation ID: 66421

Received: 27/06/2014

Respondent: Hazel and Robin Fryer

24, 5.20 & 5.26 SA Objective 3
a)Clauses 24 and 5.20. Contrary to the statement in these clauses the NPPF sustainability requirement which should have been considered in plan making for the industrial! commercial developments is not examined.
b) The proposed new development is not assessed against the requirements of clause 5.26 for successful integration.
c) The SA fails to apply the sustainable development criteria to examine the speculative industrial development site at Baginton: Local Plan policy OS16.
d) The impact of 1000 lorries per day through the village of Baginton is not even mentioned. It is also in opposition to SA Objective 3.

Object

Representation ID: 66422

Received: 27/06/2014

Respondent: Hazel and Robin Fryer

Paragraph 26 and 5.15 SA Objective 1
a) The largest industrial development in Warwick District is not required for the district but is for sub-regional employment purposes. The sustainability report does
not contain a Sustainability Assessment of sub-regional plans or any sub-regional strategy and the report is therefore inadequate on this important aspect.
b) The area covered by the sub-region is not defined in the Report or the Local Plan and there are at least five different definitions of the sub-region in official documents. The LEP plus six district's Joint Study on Employment Land (described in Local Plan clause 2.25) is not assessed for sustainability and therefore any proposals relying on this study should be excluded from the Local Plan as they do not comply with the NPPF.

Object

Representation ID: 66423

Received: 27/06/2014

Respondent: Hazel and Robin Fryer

Paragraph 1.16 & 5.34 - SA Objective 10
a) The road transport assessment does not consider the need to encouraging freight to transfer onto the rail system to reduce road congestion and C02 emissions. In SA clause 3.80 road traffic is identified as the cause of 40% of C02 emissions and it is not included in SA Objective 10.
b) Transferring freight from road onto rail was the previously the policy of Warwickshire County Council and Warwick District Council at the start of the Local Plan process. It was a key aim of the Regional Spatial Strategy which is used as the evidence basis for the Local Plan. The report is inadequate in the respect of considering the C02 emissions problem caused by a major warehouse development with road access only.

Object

Representation ID: 66424

Received: 27/06/2014

Respondent: Hazel and Robin Fryer

Paragraph 4.52, 5.51 & 5.65 - SA Objectives 5 & 9
a) Thickthorn housing; the surface water drainage problems that will result from this large area of development has not been considered and currently all the run-off from the fields is into a small stream flowing through the village of Ashow. In recent years serious flooding has occurred and a 400mm diameter bypass pipe was installed but this will be totally inadequate to take the increased flow from the development.
b)This aspect of sustainable development for the site has not been evaluated.

Object

Representation ID: 66425

Received: 27/06/2014

Respondent: Hazel and Robin Fryer

Paragraph 28,5.33 - SA Objective 2 & 3
a) The proposed areas of investigation for Park & Ride facilities are not evaluated as whether they are in a suitable position to reduce the need to travel.
b) More suitable locations nearer to the main strategic highways should have been
investigated.

Object

Representation ID: 66437

Received: 27/06/2014

Respondent: Ms Myra Styles

Plan not sustainable. Process confuses and angers people. Housing numbers unsound - old estimates being used so proposals could change without consultation as there is no time. Infrastructure provision not fully assessed, upgrades long overdue. flooding issues in many locations and schools are full. Planned destruction of 1100 year old town

Object

Representation ID: 66445

Received: 25/06/2014

Respondent: Mr Robert Cochrane

Plan not sustainable. Process confuses and angers people. Housing numbers unsound - old estimates being used so proposals could change without consultation as there is no time. Infrastructure provision not fully assessed, upgrades long overdue. flooding issues in many locations and schools are full. Planned destruction of 1100 year old town

Object

Representation ID: 66581

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Policy DS8 is unsound - it does not satisfy the requirement to meet objectively assessed development requirements. The plan proposes excessive allocation of employment land. The Plan proposes redevelopment of existing employment land and this is part of the rationale for this. The SA's section on Consultation Responses shows no recognition of CPRE's earlier consultation responses despite claiming positive effects of the ammountof employment land. This makes both the proposed Plan and the associated Sustainability Appraisal unsound.

in summary:
 The margin "to provide flexibility of supply" (16.5ha) is excessive (almost 50% extra on top of the established demand of 36ha) in order to provide 'choice'. In terms of 'additional buffer to ensure choice' for housing, the NPPF proposes a 5% buffer. Even double that buffer (10%) amounts to 3.6ha rather than 16.5ha;
 The addition of a further 13.5ha for "potential replacement for redevelopment of existing employment areas" is also unjustified. This approach conflicts with the 'brownfield first' approach of policies DS4 (Spatial Strategy) and EC3 (Protecting Employment Land). There is no valid justification for releasing existing employment land in urban areas rather than regeneration as employment land, improving effective use of existing urban employment sites.

The established employment land requirement is 39.6ha. The Plan shows that there are 47.55ha of available employment land, confirming that there is an excess supply of employment land.

Object

Representation ID: 66723

Received: 26/06/2014

Respondent: Baginton Parish Council

The sections of this document referring to Baginton do not include a consideration of the effects on the
village and surrounding areas of the decision to remove the Green Belt, the provision of the Gateway
Development or the up to date census data. There has been no consultation following the councils decision
to remove the Green Belt. As such this proposal is unsound, you have failed to corporate and procedure has
not been properly followed.
In conclusion, the Local Plan proposals MUST protect the openness of the Green Belt countryside which
surrounds our rural village and our neighbouring rural villages from urban sprawl of Coventry into
Warwickshire and from inappropriate development with no special circumstances, retaining the Green Belt.
The current proposals are contrary to these fundamental requirements of the NPPF.
You have not paid attention to the needs or desires of the Parish Council and local residents, wilfully ignored
our requests and not even consulted us when changing your policy at the last minute to exclude the areas
from the Green Belt. The Green Belt must not be removed to pave the way for inappropriate development.
In addition, you have not adequately considered the alternatives and contravened process, basing the Local
Plan on excessive superseded growth projections.

Object

Representation ID: 66837

Received: 27/06/2014

Respondent: Dr Diana Taulbut

This objection refers to paragraph 14 of the SA
Paragraph 14 stipulates that "Lillington lies within the most deprived 20% of Super Output Areas nationally".
It is stated that it is Lillington East (one of 11 super output areas for Lillington) that has an index of multiple deprivation which puts it in the 10-20% most deprived areas nationally.
It was the housing of tenants originally displaced from Wood End Coventry and this area being used to house the "difficult to house" elements that has caused this spike in deprivation in this small area of Lillington.
The statement in paragraph 14 exaggerates the excuse for the building on green belt land at Red House Farm.

Object

Representation ID: 66838

Received: 27/06/2014

Respondent: Dr Diana Taulbut

This submission refers to section 3.106 of the SA.
Section 3.106 refers to "The Districts relative prosperity masks some significant areas of deprivation. In particular, Lillington Lies within the most deprived ")% of Super Output Areas nationally.
The statement in 3.106 exaggerates the excuse for building on Green Belt Land at Red House Farm. Building on Red House Farm will not address the underlying needs of Lillington East. It will simply massage the super output area statistics suitably to reduce the apparent deprivation. That is not regeneration.

Object

Representation ID: 66839

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Inaccuracies to Section 4.35 of the SA , Lillington is not as deprived as made out, this is being used as an excuse to enable the development of Red House farm in the green belt which should be scrapped and the original green belt boundary maintained.
The wider Lillington area does not need 'regeneration' and the development of Red House Farm is far from justified. The owner is willing to sell as the profits will be considerable, it is considered that whilst the land owner and local councillors have discussed this matter there has not been proper resident involvement.

Object

Representation ID: 66840

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Section 5.16 refers to the redevelopment of Crown Way shops, this should be removed from the plan as they have not been consulted on properly. The shops and the facilities have been improved over recent times , there is nothing to suggest that it needs demolition or replacement.

Object

Representation ID: 66841

Received: 27/06/2014

Respondent: Dr Diana Taulbut

This submission refers to paragraph 5.28 of the SA and suggests that Red House Farm along with the requirement to regenerate Lillington should be deleted from the plan as they are not soundly based decisions . Lillington is not as deprived as stated and that the green belt should be protected from new development.

Object

Representation ID: 67126

Received: 24/07/2014

Respondent: Drs Thornton and Mr & Mrs Vernon et al.

Number of people: 10

Agent: Dr Paul Thornton

Errors highlighted in the Sustainability Appraisal and repeated in the site selection matrix 2014 in relation to Burton Green sites and SA Objective 2 with regards transport and access matters.

Appears to bias the preferred options site of Burrow Hill Nursery

Object

Representation ID: 67146

Received: 26/06/2014

Respondent: Warwickshire Wildlife Trust

The Trust believes that there is insufficient evidence to justify the allocation of the Coventry Gateway scheme in the Local Plan. We are concerned that:

a) There is limited up-to-date ecological information to determine the environmental impacts of the Coventry Gateway scheme and other alternatives within the Local Plan evidence base

b) The provisions of policy DS16 have not been assessed within the 2014 Habitat Regulations Assessment

c) The Sustainability Appraisal omits an assessment of the Coventry Gateway scheme against the District's Sustainability Objectives and fails to conclude why the site is promoted in the plan over other reasonable alternatives

Object

Representation ID: 67186

Received: 24/06/2014

Respondent: Kenilworth Society

The sustainability appraisal of Crackley Triangle is inadequate. The report on Site No. H07 contains factual errors. Pages 41 and 42 of Appendix V of the SA/SEA state that the site is in the green belt. In fact the land is greenfield but not green belt. Page 42 also states that "the site is within 0.2 miles to the nearest school (Park Hill Junior School)", which is incorrect. Park Hill School is 0.57 miles from the Common Lane end of the Crackley Triangle.

Such elementary errors call into question the credibility of the Sustainability Appraisal. It is further undermined by the absence of any reference to the High Speed Rail line. As Local Plan Policies Map No. 1 (District Wide) shows, HS2's track runs through the greenfield gap between Coventry and Kenilworth, and there is additional "safeguarded land" at Crackley for diversions to watercourses. The new railway and associated works will impair undeveloped character of the Crackley gap and weaken its effectiveness as green barrier between two urban communities. The Sustainability Appraisal Report does not address this issue despite noting that site H07 is within an area of high landscape value where development would extend the built-up area of Kenilworth. In our view the omission of HS2 invalidates the recommendations on page 41 of Appendix V that "strong environmental policies are developed to protect and encourage enhancement of the natural environment and include provision for green infrastructure/ green space to extend the local habitats to create further wildlife corridors." These aims are unlikely to be achievable if the Crackley Triangle is developed and HS2 goes ahead (and we have to assume that it will as the major political parties are committed to it). The prospect of HS2 makes the Crackley Triangle even more important as a green buffer between developed areas, and the Local Plan should retain it as such.