DS12 Allocation of Land for Education

The Myton School expansion is in conjunction with the agreed 2 secondary school solution with Campion School to address the increase in student numbers arising from housing developments contained within the Local Plan that are located within the current Myton School and Campion School priority areas.
Myton School will expand it's current school capacity from 1,700 students (including 325 post-16) up to 2,400 (including 425 post-16), subject to the appropriate DfE approval. Campion School will expand its current school capacity from 885 (including 100 post-16) up to 1,400 (including 200 post-16), subject to the appropriate DfE approval.
Campion School requires no additional land to expand but will require s106 / CILL funding.
The Myton School site will need to increase from the current 12.52 hectares up to 15 hectares for the secondary school provision. Myton School will sell 4.7hectares of its own land (at the north of it's site running parallel to Myton Road) to part-fund this project. Myton School will re-use some of its current building stock and will build additional capacity to create a learning campus in the south area of its site. Myton School requires an additional land allocation to the south of its site of 7.18 hectares to deliver its part of the secondary school solution.
Myton School will also look to redesignate from an 11-18 school to a 3-18 school (subject to DfE approval) and build a 2 form entry (plus nursery) primary school next to the secondary school. Myton School requires a further 2 hectare donation of land to accommodate the primary school.
The total Myton School site will total 17 hectares (including 2 hectares for primary provision). This will comprise 7.82hectares of current land owned by Myton School and 9.18 hectares of donated land for educational provision due to the local plan delivery.

Reasons for Objection

The Kenilworth Civic Society considers that the allocation of this site for educational uses and other compatible uses (i.e sports facilities) 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. Chapter 5 (Strategic Development Sites and Infrastructure) para. 5.4.13, of that document assessed the need for new education provision resulting from proposed housing developments in Kenilworth. It made no reference to a new site for Kenilworth School, or a new primary school at Southcrest Farm. On the contrary it said that "there is a need to provide capacity for a one form entry primary school on site, located towards the northern end of the (Thickthorn/Glasshouse Lane) site. In terms of secondary provision, offsite contributions would be necessary to support Kenilworth School which will have capacity if places are provided to those within the priority area first."

Furthermore the Draft Local Plan proposes to remove Southcrest Farm from the green belt without prior consultation. (See the Kenilworth Civic Society's objections to Policy DS19.) This area of Kenilworth is already due to lose green belt land to the High Speed 2 railway line. HS2 will cut across Kenilworth Golf Club's land in Crewe Lane. We believe that it is inappropriate to sacrifice more green belt land to development in this area.

b) The justification for Site No. ED2 depends on a circular argument, i.e. Kenilworth School will expand more than envisaged in the Revised Development Strategy because it is giving up its existing sites for housing developments, something that was not envisaged by Revised Development Strategy. The proposed change of use of Kenilworth School's Leyes Lane and Rouncil Lane sites was not included in the Strategy, therefore the community has not been formally consulted on it.

c) The Sustainability Appraisal has not assessed the suitability of Southcrest Farm as a site for the provision of a secondary school, 6th form centre and primary school. It does not appear to be an appropriate site for a primary school designed to serve the new housing estate at Thickthorn/Glasshouse Lane. We assume that the new primary school is intended for this purpose. The Draft Local Plan does not suggest that it will be a replacement for the nearby Park Hill Junior School, which would be a possible alternative.

d) Putting Kenilworth Secondary School on one new site will not solve the problem of the size of the school. It is already the largest secondary school (maintained sector) in Warwickshire. Ofsted, in its report on Kenilworth School dated February 2013, said "The school is much larger than the average secondary school with a sixth form." The number of pupils on roll at the time was 1750. In our opinion two new schools on the existing sites would be preferable to one huge school of around 2000 pupils on a new site

The land at Southcrest Farm Kenilworth as a site for the new Kenilworth school... this decision has appeared from no where it was not mentioned in the consultation document.Once again it is on green field/belt land and is along a busy narrow lane . The Lane will have to be widened to allow coaches along it. This is really going to have an adverse effect on one of the major employers in the town, Woodside and the Sundial Group Hotel and Conference Centre. At the moment these facilities look out over the lovely countryside, but will, if the plan goes ahead be surrounded by houses and a large education complex.
How long before they decide to move?

This site seems reasonable for the secondary school - although its location on the edge of town does mean that students will have to travel across the centre to get there from Western Kenilworth (making an East-West cycle route crossing the railway essential). It is not the best site for the primary school. This should be located within the Thickthorn development to minimise journey distance to the school from the new housing and have the primary school embedded in a local community.

I write as a Councillor for the County Council. At the time of writing there is no detailed plan agreed for secondary schools. Also there seems to be no possibility of agreement on primary school provision in Warwick.

The Kenilworth Education Trust wants to ensure that the Local Plan properly accommodates and integrates the future needs of Kenilworth School and Sixth Form through policies and allocations which will allow for the growth and consolidation of the school on one site. Kenilworth School currently operates from two sites; the secondary school being located at Leyes Lane and the Sixth Form at the Rouncil Lane site. Kenilworth School and sixth form has 1,750 pupils on roll, which includes 450 sixth form students on the Rouncil Lane site.
The School will need to accommodate additional students based on forecast growth within the Kenilworth catchment, primarily associated with the new families being accommodated within new housing developments in the area, including those sites identified in the Local Plan. Additionally, because of a higher birth rate, there will be an increased requirement from 2019 to accommodate more students from within the existing Kenilworth primary catchment.
Many of the buildings on the two sites were built in the 1950/60s and the fabric of many of the buildings is approaching the end of its viable use. Furthermore the split between two sites has issues, such as duplication of roles, it detracts from efficient management and operations and increases teaching and running costs. It is therefore unlikely to prove to be practical or viable to continue to provide facilities on both sites whilst growing and developing the School to accommodate a larger numbers of students, whilst also providing a community service out of school hours. The School is therefore seeking to consolidate its buildings and other facilities onto one site.
To date there has been dialogue between Kenilworth Education Trust and Warwick District Council and Warwickshire County Council about the future plans of the School. Furthermore the School has responded to earlier public consultation on the Council's proposed development strategy and site allocations for the new Local Plan.
The decreased funding from government and the increased pressure to provide value for money whilst retaining the current outstanding results means it is an imperative that a viable solution is found which seeks to maximise any returns. This will include ensuring that there is sufficient return from any land that may need to be disposed, if one or potentially two sites are surplus to the School's requirements.
Given these considerations, the only way of ensuring that a new and better school can be provided to serve Kenilworth and the wider catchment area is to identify a viable and deliverable solution for redevelopment on either one of the existing school sites or potentially on a new site. For these reasons the School appointed advisors to undertake a comprehensive feasibility study with the aim of identifying a preferred approach. The Arup study has identified a number of potential options for the new facilities within Kenilworth, including South Crest Farm on Glasshouse Lane which is contained within the Warwick District Council Local Development Plan.
There is still a considerable amount of work to be undertaken in looking at these options, not least in considering the financial viability of each. Throughout this process the aim of the Governors and senior staff is to keep all options open so that any decisions that are taken will be in the best interests of the school and the community.
Until this time the current allocations may not meet the following tests of soundness:
1. Justified: The allocated sites have not been fully demonstrated to be the most appropriate strategy when considered against reasonable alternatives. The alternatives and the evidence are currently being evaluated by advisors and a strategy will emerge from this work. The Kenilworth Education Trust would like to discuss and agree this strategy with the objective that it will inform the allocations of land for Education and Housing Use in the Submission version of the Local Plan.
2. Effective: There is currently insufficient evidence that the sites currently allocated on the existing school sites and on the new proposed site for school (ED2) can be delivered during the plan period. Evidence on deliverability will form part of the advisors' findings from the Feasibility Study.
3. Consistent with National Policy: The current allocations may not be consistent with national policy as set out within the NPPF, in particular paragraph 173. This states "pursuing sustainable development requires careful attention to viability and costs in plan making and decision making. Plans should be deliverable". Also the current allocations may not be consistent with paragraph 177 of the NPPF that reads "It is equally important to ensure that there is a reasonable prospect that planning infrastructure is deliverable in a timely fashion". Again the evidence on whether a site for a new school can be delivered within the plan period on any of the three potential site opportunities will be fully set out within the advisors' Feasibility Study.
The Kenilworth education Trust wants to ensure that the local Plan properly accommodates and integrates the future needs of Kenilworth School and Sixth Form through policies and allocations which will allow for the growth and consolidation of the school on one site. The only way of ensuring that a new and better school can be provided to serve Kenilworth and the wider catchment area is to identify a viable and deliverable solution for redevelopment on either one of the existing school sites or potentially on a new site. A comprehensive feasibility study has been commissioned to identify a preferred approach.

See attachment

see attached

See attached Representations.

See attached Representations.

see attached

see attached

see attached

Response of Kenilworth Town Council to the Warwick District Local Plan Consultation
June 2014
General
As the District Council will be aware, the Town Council has drafted and continues to refine a Town Action Plan which makes detailed proposals for the development of the sites proposed in the Local Plan and which the Town Council hoped would be incorporated into the Local Plan. The Local Plan deals with many of our requirements in general terms but we feel that this is not in sufficient detail and would press for the incorporation of the detailed requirements set out in our Action Plan into the Master Plans suggested for each main site.
Subject to this general comment, these responses are delivered on the basis required by the Consultation as to whether the Plan is:
a) Sound
b) Deliverable
c) Sustainable
d) Followed proper process.

Housing Growth (Policy DS6)
Kenilworth Town Council has responded to all of the previous consultations on the Plan on the basis that it must not only provide for the specific needs of Kenilworth itself but also has to bear in mind that the town is part of the District and must reflect the amount of housing necessary across the District. As such the Town Council has appreciated the necessity to accept more development than is needed on a parochial basis as part of the larger community whose benefits we enjoy.
However the recent ONS forecast of population growth has indicated that the actual needs of the District, which we had accepted, may now have been superseded as it indicates a significantly smaller increase in need for the District as a whole. In these circumstances we feel there is a requirement for those figures to be investigated, and if a lesser figure is indicated then this must lead to a re-evaluation of the needs of the District as a whole, including Kenilworth, which saw an increased share in the latest version of the Plan.
As the forecast for Coventry has increased, we are concerned that the pressure may return for over the border development. However the analysis for the previous RSS showed that even with the revised figures there will be spare capacity within the Coventry boundary and therefore any cross-border pressure should be firmly resisted by the District Council. In particular there must be no development for the benefit of Coventry on Green Belt land in Warwick District, when development on Green Belt land in Coventry is not being considered.
The Town Council's view was that the development within the Town at Thickthorn should cease at Rocky Lane and should not include the Crackley Triangle. In the light of the new figures these two areas may need to be revisited.

Crackley Triangle (Policy DS11 Ref H05)
In relation to the Crackley Triangle, it is the Town Council's view that this is a very sensitive area, which although not within the Green Belt, is very much part of the barrier between Coventry and Kenilworth where the Green Belt is extremely narrow. Further, it is likely to be devastated by HS2 and as such the barrier against coalescing with Coventry will become almost meaningless unless further protection is given.
No consultation took place in respect of this area by the District Council in its consultations on the Plan. Whilst the Town Council's views were known as a result of it's draft Action Plan, this area was not referred to in the public consultation, so the public's views have not been ascertained.
Further, we do not believe that this area is deliverable because it has no access (except on to a narrow bridge with a difficult configuration which cannot be widened or straightened) and as such is not really safe or sufficient even for current traffic.
We feel therefore that this area should be revisited as to whether there is need, whether it is deliverable and whether due process has been followed.
Note: There is a current outline planning application for this site to which the Town Council has objected on access and drainage grounds.

Kenilworth School Relocation Site (Policy DS11 Ref ED2)
Whilst the Town Council acknowledges that it was likely that Kenilworth School would find it necessary to relocate onto a larger site because of current numbers, coupled with the increase likely to arise as a result of the new developments within the Town, no formal consultation has taken place upon the proposed move, or the site concerned. The site proposed is within the Green Belt and as such requires very careful consideration including enquiry as to the need for relocation, its siting and the deliverability of this relocation, particularly from a financial stand point.
Kenilworth School Sites in Leyes Lane and Rouncil Lane (Policy DS11 Refs H09 and H12)
The Plan now provides that the possible move of the Kenilworth School makes it's existing sites in Leyes Lane and Rouncil Lane available for development. This however has also not been previously proposed and again no formal consultation has taken place. Whilst the main site in Leyes Lane is within the Town envelope, the Rouncil Lane site falls within the existing Green Belt and therefore again must meet the tests appropriate to sites being taken out of the Green Belt. The Town Council is concerned whether the Plan is sound, having regard to there having been no formal consultation in regard to either sites.

Thickthorn Sites School Provision (Policy DS12)
In relation to the sites at Thickthorn it has always been the Town's contention that a development of this size must provide for a primary school within the development. The object of siting it within the development is to encourage families to walk to the School and thus decrease the use of transport and also promote a healthy life style. The proposal that this new primary school should be on the Southcrest Farm site is completely contrary to this logic and would lead to additional and unnecessary traffic movements, thus making it unsustainable.
It also could result in some of the existing primary schools being closer to the residents of Thickthorn than the one provided by the plan for this development. This would in our view make the Plan in this regard unsustainable in these respects.

Sports Fields (Policy HS4 and HS5)
Whatever the final agreed extent of housing and employment development at Thickthorn, there will be a need for some relocation of the existing sports facilities. Although there have been discussions, we note that no relocated sports sites feature in the Local Plan. Whilst we appreciate that alternative sites need not be identified until the planning permission stage we wonder whether there should have been some indication given here in order to ensure deliverability.

Local Plan Policies Maps (Maps 1 and 5)
We note that the Great Mere of Kenilworth Castle, a nationally Listed II* Historic Park and Garden is not identified on the relevant Policies Maps 1 and 5 although Policy HE4 clearly states that such areas are defined on the Policies map. We have not checked to see whether this serious omission is repeated for any other locations.

Retail Area Map (Map 5a)
We note and approve that the Kenilworth Town Centre Map 5a has been amended to include the Waitrose store within the Retail Area but note that the actual building has not been added to the map and the car park entrance has not been updated. There is also a missing building at the North end of Abbey End where the Almanack and flats are. Although the houses in Harger Court remain outside the Retail area, the houses in Harger Mews have been included together with houses in Bertie Road. We feel the boundary should exclude all these houses unless there is a specific reason to include them. When the map is corrected it would be useful to update the Wilton Court site development as well, although that is not within the Town Centre boundary.