Publication Draft

The Kenilworth Civic Society objects to:

Chapter: 1 Introduction, Vision and Objectives
Paragraph: 1.10, third sentence: "The population (of Warwick District) has grown from 124,000 in 2000 — an 11% increase — and is forecast to continue to grow, with potentially a 17% growth over the next 15 years."

This forecast underpins the Draft Local Plan's policies on housing and development, as Para. 1.42 confirms. This says that "providing opportunities to deliver the housing needed to support the District's changing and growing population is central to the Plan". The Sustainability Appraisal Report April 2014 also uses a population growth rate of 17% to assess the validity of policies in the Plan.

Reasons for Objection
The Kenilworth Civic Society considers that the Plan is unsound because the 17% growth rate is a) outdated and b) an overestimate. It is not supported by the latest population projections, which were published by the ONS in May 2014. These forecast that by the year 2031 the population of Warwick District will total 155000. The figure for that year quoted in the Draft Local Plan is 161,594. (See Chapter 4 Para. 4.3). The difference in the figures equates to a requirement for around 2800 fewer houses, calculated using the Warwick District SHMA's estimated average household size of 2.33. (See Para 2.14 of the Warwick District Council Strategic Housing Market Assessment Final Report March 2012)

The Kenilworth Civic Society supports in principle the allocation of Site No. H06 for housing, and unreservedly supports the designation of the adjacent Site No. E2 as an employment site. However we do object to the inclusion of the following parcels of land within H06
* The field marked on Local Plan Policies Map 5. Kenilworth as Pavilion/Sports Ground and currently occupied by Kenilworth Wardens Cricket Club
* The field marked on Local Plan Policies Map 5. Kenilworth as Glasshouse Spinney and Ruby Football Ground, currently occupied by Kenilworth Rugby Football Club
* The field marked on Local Plan Policies Map 5. Kenilworth as track and pavilion, currently occupied by Kenilworth Rugby Football Club

Reasons for Objection
The Kenilworth Civic Society considers that the allocation of the above sites for housing is unsound because they will not be available for this use unless Kenilworth Rugby Football Club and Kenilworth Wardens Cricket Club can be relocated. The main text of the Draft Local Plan does not identify any sites for relocation of these sports facilities. The only reference to possible sites is on page 15/34 of Appendix VII of the Warwick District Council Publication Draft Local Plan SA/SEA. This says "Relocation of sports clubs to Castle Farm and land to south of Kenilworth".

Both locations are in the green belt, and although the National Planning Policy Framework allows "provision of appropriate facilities for outdoor sport, outdoor recreation" on green belt land, any such developments have to preserve "the openness of the Green Belt". This policy would appear to rule out large pavilions and conference rooms of the sort that the Rugby Club and the Wardens Cricket Club have now. If they are not going to get facilities at least as good as those they currently enjoy, they will not move from their present site.

Castle Farm is a particularly sensitive location. In addition to being in the green belt, it is near to Kenilworth Castle and very close to the site of the Castle Fish Ponds, a scheduled monument. There is also the question of what would happen to Castle Farm sports hall (owned by Warwick District Council) should the Rugby Club and/or the Wardens Cricket Club re-locate there. Appendix III of the Warwick District Council Publication Draft Local Plan SA/SEA says on page 41/82 "SH5 The Council ensure that in any potential changes at Castle Farm that sport hall access in Kenilworth is protected / replaced". If the sports hall at Castle Farm is to be replaced, where will it go? Abbey Fields has been suggested, but this idea was strongly opposed in a survey carried out last year by Kenilworth Town Council.

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.

Reasons for Objection

The Kenilworth Society considers that the
The designation of H09 as a housing site is unsound because:
a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. Kenilworth School, Leyes Lane , was not in the list of housing sites in the "Revised Development Strategy" that was published for public consultation in June 2013.
b) The Sustainability Appraisal of Site H09 is inaccurate and unsatisfactory. Appendix V page 3/87of the SA states that
"...there is only a very low/ low risk of surface water flooding." This is incorrect. The Environment Agency website's map of "Risk of Flooding from Surface Water" shows approximately one third of the site as being at some risk of surface water flooding. Parts of the site are shaded dark blue, indicating that they are exposed to a high risk of flooding. Plans to put dwellings, roads etc on this site would have to address this problem, and also the dangers of acerbating drainage problems offsite. Much of the watercourse (the Millbrook) into which this Kenilworth School site drains is coloured in dark blue on the Environment Agency's map of "Risk of Flooding from Surface Water".

In the opinion of the Kenilworth Society the Sustainability Appraisal's formula for dealing with drainage - "Mitigation is offered to a certain extent by the NPPF which requires that new development should not increase the risk of flooding elsewhere" - is inadequate when applied to sites that pose serious and specific problems.

c) As said in our submission on Site No. ED2, we do not believe there is adequate justification for moving Kenilworth School to Southcrest Farm. We understand that operating on split sites creates problems for Kenilworth School, but the Southcrest Farm is not the only, nor necessarily the best option. The proposed solution appears to be driven by the county Council's desire to raise money from the sale of land for housing rather than the needs of the local community.

Reasons for Objection

The Kenilworth Society considers that the
The removal of Site No. H12 from the green belt and its designation of as a housing site are unsound because:
a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. Kenilworth School, Rouncil Lane, was not in the list of areas of Warwick District to be removed from the green belt in the "Revised Development Strategy" that was published for public consultation in June 2013. Nor was it in the Revised Development Strategy's list of housing sites.
b) The site will only be available for housing if Kenilworth School moves to Southcrest Farm. As said in our submission on Site No. ED2, we do not believe there is adequate justification for moving Kenilworth School to Southcrest Farm. We understand that operating on split sites creates problems for Kenilworth School, but relocation to Southcrest Farm is not the only, nor necessarily the best option. The proposed solution appears to be driven by the county Council's desire to raise money from the sale of land for housing rather than the needs of the local community.

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

Reasons for Objection
The Kenilworth Society considers that Policy H0 is unsound because it is not supported by up-to-date evidence on the likely increase in the population of Warwick District and the resultant need for new housing. The latest population projections, which were published by the ONS in May 2014, forecast that, by the year 2031, the population of Warwick District will total 155000. The difference between the ONS figure and the figure stated in Para 4.3 equates to a requirement for around 2800 fewer houses, calculated using the Warwick District SHMA's estimated average household size of 2.33. (See Para 2.14 of the Warwick District Council Strategic Housing Market Assessment Final Report March 2012)

Reasons for Objection

The Kenilworth Society considers that the removal of these sites is unsound because:
a) The Local Planning Authority has not involved the community in the preparation of this part of the Plan. The "Revised Development Strategy" that was published for public consultation in June 2013 retained all three sites in the green belt. With regard to the land near Coventry Airport (Coventry Gateway) Para. 5.5.8 of the 2013 document specifically said "...It is not proposed that this Local Plan amends Green Belt boundaries in this area..."

b) There do not appear to be good planning reasons for the removal of these sites from the green belt. In the case of the Coventry Gateway, the reason seems to be the local planning authority's retrospective justification of consent to a planning application. The Draft Local Plan does not provide evidence to support the change. Nor does Sustainability Appraisal Report assess the merits or otherwise of removing the sites from the green belt. It merely states that they are within the green belt.