Sustainability Appraisal - Publication Draft

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Sustainability Appraisal - Publication Draft

Sustainability Appraisal - Publication Draft

Representation ID: 67186

Received: 24/06/2014

Respondent: Kenilworth Society

Representation Summary:

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.

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