Sustainability Appraisal - Publication Draft

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Object

Sustainability Appraisal - Publication Draft

Representation ID: 65414

Received: 27/06/2014

Respondent: Cllr George Illingworth

Representation:

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

Full text:

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

Sustainability Appraisal - Publication Draft

Representation ID: 65576

Received: 27/06/2014

Respondent: Cllr George Illingworth

Representation:

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.

Full text:

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. This is in line with local knowledge. NO weight can therefore be attached to the surface water assessment for this site. I have not checked any other sites but if the same basic error has been made then they are all similarly discredited.

Object

Sustainability Appraisal - Publication Draft

Representation ID: 65578

Received: 27/06/2014

Respondent: Cllr George Illingworth

Representation:

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.

Full text:

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

Sustainability Appraisal - Publication Draft

Representation ID: 65742

Received: 24/06/2014

Respondent: Whitnash Residents Association

Representation:

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

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66413

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Representation:


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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66417

Received: 27/06/2014

Respondent: Mr Robin Fryer

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66421

Received: 27/06/2014

Respondent: Mr Robin Fryer

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66422

Received: 27/06/2014

Respondent: Mr Robin Fryer

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66423

Received: 27/06/2014

Respondent: Mr Robin Fryer

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66424

Received: 27/06/2014

Respondent: Mr Robin Fryer

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66425

Received: 27/06/2014

Respondent: Mr Robin Fryer

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66437

Received: 27/06/2014

Respondent: Ms Myra Styles

Representation:

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

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66445

Received: 25/06/2014

Respondent: Mr Robert Cochrane

Representation:

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

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66581

Received: 27/06/2014

Respondent: CPRE WARWICKSHIRE

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66723

Received: 26/06/2014

Respondent: Baginton Parish Council

Representation:

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.

Full text:

See Attached

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66837

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66838

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66839

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66840

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 66841

Received: 27/06/2014

Respondent: Dr Diana Taulbut

Representation:

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.

Full text:

see attached

Attachments:

Object

Sustainability Appraisal - Publication Draft

Representation ID: 67126

Received: 24/07/2014

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

Number of people: 10

Agent: Dr Paul Thornton

Representation:

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

Full text:

See attached

Object

Sustainability Appraisal - Publication Draft

Representation ID: 67146

Received: 26/06/2014

Respondent: Warwickshire Wildlife Trust

Representation:

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

Full text:

The Trust believes that there is insufficient evidence to justify the allocation of the sub-regional employment site near Coventry Airport (hereafter referred to as 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 Habitat Regulations Assessment dated March 2014.

c) The Sustainability Appraisal report 2014 and its associated appendices omit a formal 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.

1) Evidence Base
In our consultation response to the draft Local Plan 2012, Warwickshire Wildlife Trust recommended that:

'The evidence base for the natural environment will ... have to be reviewed and updated in order to inform the sustainability appraisal for this site and any other reasonable alternatives that come forward as part of [the] review process.'

However, according to the Habitat Biodiversity Audit data (HBA) for Warwickshire, Coventry and Solihull (2012-2013), much of the habitat data for the land allocated for the Coventry Gateway scheme in Warwick District dates from 1997/98, with only a few small areas updated in 2006. The Gateway scheme was not included in the Warwick District Habitat Assessment 2008 and was not updated as part of the Landscape Sensitivity and Ecological & Geological Study - Landscape Assessment Update April 2014.

A planning application for the Coventry Gateway scheme was submitted in 2012. The application was accompanied by a detailed Environmental Statement (ES) which included up-to-date data on habitats, species and statutory and non-statutory wildlife sites within the proposed allocation, with the exception of Rock Farm potential Local Wildlife Site. Whilst this data may go some way to providing a baseline for the Coventry Gateway scheme, it is not included or summarised within the local plan evidence base and has not been referred to when assessing site allocations in the Sustainability Appraisal report 2014.

In paragraph 2.73 of the Local Plan Submission draft, the local authority broadly outlines the reasons for supporting the Coventry Gateway Scheme. The local authority quotes studies that have been undertaken to support the location of the allocation but these studies are not referred to in the local plan and it is not made clear if such studies are included within the local plan evidence base. Nor is it clear that these studies contain any wider sustainability assessment of the proposal and alternatives given the apparent focus on the economic merits of the proposal at the expense of any reference to environmental constraints and opportunities.

The Local Authority has not proposed alternative sub-regional site allocations as part of the local plan process, nor gathered associated environmental evidence to review the wider sustainability merits and constraints of such options.

We accept that it is unreasonable to require Warwick District to identify a range of alternative sub-regional employment sites alone when the review area for these sites will extend beyond the boundary of a single local authority area. We do believe however, that the local authority has a duty, under the Localism Act 2011, to work collaboratively with other local authorities in the Coventry and Warwickshire Local Enterprise Partnership (LEP) area to collate evidence for other sub-regional options in order to ensure that the preferred option is justified in accordance with sustainability principles. As the responsible local authority for allocating the preferred sub-regional site, we believe it is necessary for the results of this cross-boundary assessment to be present in the evidence base of this local plan so that the Gateway allocation, as with all other proposed housing and employment sites in the plan, can be reviewed using the sustainability Appraisal process.

2) Habitat Regulations Assessment
The local authority has updated the Habitat Regulations Assessment of the local plan in accordance with article 6(3) and (4) of the Habitats Directive; the findings of which are presented in the Habitat Regulations Assessment- Screening Report 2014. The report screens the likelihood that policies in the plan could impact on Natura 2000 sites; however the policies reviewed in the report were those detailed within in the 2012 Preferred Option draft and not the current submission draft of the Local Plan.

Paragraph 3.3.1 of the Habitat Regulations Assessment - Screening report 2014 states that:

'As the local plan is in development, this assessment will report the Local Plan Preferred Options as of May 2012. A further addendum may need to be prepared should the local plan policies or site allocations be materially altered'

The Trust believes that since 2012, the provisions of policies surrounding the Gateway Scheme have materially changed from a generic 'exploration of the case for the proposal' in policy PO8 to a specific 'allocation of land' in policy DS16 of the 2014 submission draft. The implications of this change should therefore be subject to further screening and added as an addendum to the 2014 screening report.

3) Sustainability Appraisal
The Sustainability Appraisal Report 2014 does not assess the Coventry Gateway site allocation against Warwick District's Sustainability objectives nor does it provide any assessment of the proposal against reasonable alternatives.

Article 5.2 of the European Directive 2001/42/EC "on the assessment of the effects of certain plans and programmes on the environment" states that:

"The environmental report shall include information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, [and] its stage in the decision-making process"

The Coventry Gateway scheme is a specific site allocation identified within the plan and is promoted by policy DS16. However, unlike all other specific housing and employment allocations, it is not reviewed or assessed within the Sustainability Appraisal report 2014.

The Directive further states that the report should contain information on:

"the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors. These effects should include secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects" (Annex I (f) and
footnote)

There appears to be no evidence about such effects within the local plan evidence base and no assessment of these effects against the District's sustainability objectives using the Sustainability Appraisal methodology employed for all other housing and employment allocations.

"an outline of the reasons for selecting the alternatives dealt with" (Annex I (h))

There are no alternatives identified for sub-regional employment sites in the Sustainability Appraisal and subsequently no supporting information for selecting the Gateway scheme in accordance with sustainability criteria.

"the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme" (Annex I (g))

Without an assessment of the Coventry Gateway scheme against the Sustainability objectives there is no option to consider any measures that may be required within the local plan to reduce and offset any adverse effects of the proposal.

In the absence of information for the above, the Trust firmly believes that the Sustainability Appraisal fails to provide the necessary justification for allocating land for the Coventry Gateway proposal within the local plan.

Object

Sustainability Appraisal - Publication Draft

Representation ID: 67186

Received: 24/06/2014

Respondent: Kenilworth Society

Representation:

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.

Full text:

Reasons for Objection

The Kenilworth Society considers that the designation of this site as an "Allocated Housing Site" is unsound because:

a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. It was not included in the Revised Development Strategy published for public consultation by Warwick District Council in June 2013. This is a sensitive site, and one that will be difficult to develop. The Crackley Triangle is part of the narrow greenfield gap between Kenilworth and Coventry. Therefore it is important that members of the community are given the opportunity to influence this part of the Local Plan

b) The sustainability appraisal of this site 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.

The Kenilworth Civic Society is concerned about the practical implementation of Local Plan policies at Site H07, even though there is a current planning application for housing on the site. (W/14/0618) There are a number of obstacles to the successful development of this land, namely:-
* Very difficult access via the Common Lane bridge over the Kenilworth/Berkswell Greenway and Leamington to Coventry railway line. It will be very expensive for developers to create a satisfactory vehicular access at this point.
* Previous suggestions by the developers of three way traffic lights and that the consequent platooning of traffic are considered a negative impact upon the Common Lane throughway, and impact on all the neighbouring residential areas.
* Drainage issues. In recent years the Crackley area of Kenilworth has suffered from surface water and foul sewer drainage problems, as residents of Crackley Cottages and Arborfield Close can confirm. The "Flood Risk Assessment & Drainage Strategy" carried out by Halcrow for Planning Application W/14/0618 says "STWL has inferred (sic) that there is a lack of capacity in the local public foul sewerage system and potential flooding..." See paragraph 4.2.2 Sewers. This problem, together with surface water run-off, can be overcome by new drainage schemes, but the capital and maintenance costs will be considerable. With regard to ongoing costs, paragraph 7.5.3 of Hacrow's report says "The attenuation basin and any other upstream sustainable drainage systems within the development will be maintained by a private management company....the piped surface water network serving the development will also be privately maintained."
* Blight from HS2. The construction of HS2 will cause enormous and lengthy disruption to the Crackley area during a significant proportion of the Local Plan period, reducing the appeal of Site H07's dwellings to potential buyers. The site is only 250m from the HS2 proposed route.

Because of the costs of development and the blight created by HS2, it is questionable whether site H07 will provide the number of affordable dwellings required by Policy H2 "Affordable Housing". It is even possible that the site will be unprofitable and therefore unviable, thanks the construction of HS2, lower than expected population projections for Warwick District and the allocation of housing sites elsewhere.