DS11

Support

Representation ID: 67230

Received: 05/12/2014

Respondent: Coventry and Warwickshire Local Enterprise Partnership (CWLEP)

Agent: Coventry and Warwickshire Growth Hub

The Warwick District Council Publication Draft Local Plan: Focused Consultation document maintains the volume of employment land proposed during the Plan period and increases the volume of proposed housing land - this is supported by CWLEP. CWLEP would be happy to continue to work with Warwick District Council to ensure that land identified for housing and employment opportunities is brought forward for development as part of the implementation of the Local Plan. In particular the CWLEP is happy to assist with collaborative working across the sub region to achieve high quality outcomes for existing and future communities.

Object

Representation ID: 67235

Received: 08/12/2014

Respondent: Mr Richard Simmons

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

1) Ref: H06 The A46 is a key route forming the connection between the M6, M1 and the M40. The massive infrastructure improvements at Tollbar Roundabout (Baginton Coventry) and the widening of the A45 connection to A46 is a clear indication that the Ministry of Transport expects traffic load on this road to increase very substantially.
The 'current' road noise between housing in Glasshouse Lane/Birches Lane , Kenilworth and the A46 is about on the limit of comfortable noise acceptability. Sports pitches are ideal for filling this noisy void as currently the case.

Drawing a convenient line along the A46 simply to limit 'urban sprawl cannot make for good planning. The Council has first duty to 'care' for its people. By building up to the boundary of the A46 the Local Plan sentences new inhabitants to a life of noise and pollution hell and distress; no doubt the developers will shove all of the affordable housing nearest to the motorway. If they were newts and badgers they would be shown more respect.

2) Ref: ED2 Running along the South side of Crewe Lane is an Arboretum planted by Mr. Field the former owner of Southcrest Farm. He has labelled every tree with a brass disc. Please exclude this strip from ED2 and place a blanket TPO on these trees.

Housing Generally: Kenilworth Golf Club has survival worries about HS2. To allocate this even noisier land for Housing would be bad planning for occupants.

Support

Representation ID: 67245

Received: 11/12/2014

Respondent: H E Johnson

Agent: Bond Dickinson

Landscape and Visual Report attached to representation in support: The proposed extended allocation offers an excellent opportunity to accommodate approximately
12.4 ha of sustainable residential settlement expansion accommodating approximately 400 dwellings, comprehensively contained within a new Green Infrastructure framework of structural broadleaved woodland, wetland SUDS, and interconnecting cycleways and footpaths.
Working with the undulating topography of the area, and building upon the existing retained network of hedgerows, hedgerow trees and woodland, the new residential neighbourhood can be subdivided into discrete but interconnected parcels, each with accessible greenspace on their doorstep. Structural woodland planting along the higher south eastern and eastern slopes of the local landform will deliver effective filtering of views towards Lillington from the wider countryside beyond, whilst at the same time connecting The Runghills wood across to Newbold Comyn Park.
Combined with the planned demolition of the currently intrusive high rise developments set within
Lillington, there is potential to create a much more sympathetic urban/rural interface than currently exists.

Object

Representation ID: 67273

Received: 25/11/2014

Respondent: Mr Clive Narrainen

Legally compliant? No

Sound? No

Duty to co-operate? No

The land north of Kenilworth and South of Coventry (Kings Hill) should be allocated to meet the needs of both Warwick and Coventry

Object

Representation ID: 67511

Received: 12/12/2014

Respondent: The Warwick Society

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Further work carried out by Warwickshire County Council and its consultants has failed to resolve the inadequacy of the phase 4 Transport Strategy. Its effect, with the proposed development on greenfield land, will be to increase congestion and worsen air quality in Warwick and Leamington town centres. The Plan remains unsupported by a sustainable transport scheme. On this ground too it fails, therefore, to comply with the NPPF.

The damage done to the historic environment by the inadequacy of the transport strategy and its 'mitigation' measures remains unresolved. No Heritage Impact Assessment of the Transport Strategy and its 'mitigation' (of traffic flows, not of environmental impact) on Listed Buildings and the Conservation Area of Warwick Town Centre has been carried out. The recent response of English Heritage to a planning application for the demolition of a 1960s house2
in the Conservation Area demonstrates the threat to the character of the Conservation Area and its
Listed Buildings should the proposed 'mitigations' be carried out. They would, at Bridge End, Castle Hill, St John's, Eastgate, and probably at Northgate, cause immediate visual damage. In the longer term, the economic impact of failing to protect and enhance the settings of buildings affected by increased traffic throughout the town centre would place at risk the maintenance and condition of over two hundred Listed Buildings. Again, the failure of the Plan to comply with the requirements of the NPPF for the historic environment is a deficiency of the 'Focussed Changes'.

Object

Representation ID: 67539

Received: 12/12/2014

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

A level 2 SFRA is required. The site lies adjacent to the Saltisford Brook, further investigation which may include Hydraullic Modelling will need to be undertaken to establish whether a fluvial flood risk exists to the site from this source. No Flood Zones currently exist in this location.

All built development including drainage features should be sited outside of the 100 year climate change fluvial outline.

The Flood Risk assessment (FRA) must demonstrate that safe access to and from the site can be achieved for emergency vehicles up to and including the 100 year climate change fluvial event.

Object

Representation ID: 67540

Received: 12/12/2014

Respondent: Barwood Strategic Land II Limited

Agent: HOW Planning LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

These representations must be read in conjunction with those submitted by HOW Planning in response to the Warwick Local Plan 2011-2029 Publication Draft consultation,
submitted in June 2014.
The objections raised in June, which demonstrate that the Plan is unsound, still stand and as detailed in the accompanying representation forms relate specifically to draft policies DS4, DS6, DS7, DS10, DS11, DS19 and DS20.
These representations have been prepared to specifically respond to the publication of the Coventry and Warwickshire Strategic Employment Land Study (ELS) October 2014, which is a key part of the Council's evidence base underpinning the emerging Plan. It is understood that the Council in the preparation of the Publication version used the emerging ELS (March 2014) to inform the Plan, however presumably at the time the ELS had not been finalised and certainly it was not publically available.
Barwood appointed specialist consultancy Peter Brett Associates (PBA) to carry out an independent assessment of the Study, in order to establish the key implications for the housing market area.
A report by PBA is attached, however in summary it is clear that if the local authorities accept the findings and recommendations of the ELS, then a significantly increased
amount of housing will need to be delivered over and above the Strategic Housing Market Areas demographic scenarios if the economic strategy is to be delivered. There would
need to be compelling reasons to justify why the recommendations of the report might not be followed.
The ELS and in particular its recommendations have implications which go to the heart of the emerging Local Plan and have a specific bearing on draft policy DS6: Level of Housing Growth and DS20: Accommodating Housing Need Arising from Outside the District.
Previous work undertaken by PBA, presented in Barwood's June representations, highlighted that the Council had underestimated its proposed level of housing growth and
therefore that draft policy DS6 is unsound. The recommendations of the ELS only serve to support PBA's findings.
Draft policy DS20 sets out that in the event that unmet housing need arising outside the District needs to be met within the District, then a review of the Plan will be carried out.
Barwood's previous representations highlighted the shortcomings of this policy, but the Council's approach is undermined further with the recommendations of the ELS clearly pointing towards the need for additional housing across the HMA. The likelihood therefore of additional housing being needed in the District is increased by the ELS
recommendations and there can be no assurance that the Council's approach will translate to the HMA's unmet housing requirements being provided for.
In summary, as set out in the attached representation forms, it continues to be Barwood's firm opinion that the Council's new Local Plan cannot be considered sound
unless fundamental amendments are made as detailed in these representations and those submitted in June.