Defend Kenilworth Castle

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Tick all the boxes below which you agree with:

I do not believe the South Warwickshire Local Plan is legally compliant. I do not believe the South Warwickshire Local Plan is sound. I do not believe the South Warwickshire Local Plan is based on a robust evidence base.

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The Sustainability Appraisal

Flood Risk

Pollution and Biodiversity

Landscape

The Regulation 18 Sustainability Appraisal used the existing Landscape Sensitivity, Ecological and Geological Study to assess landscape scores across Warwick District. This study was part of the previous Warwick District Local Plan and did not look at any part of the KEN.1/SG04 site. As such, the original landscape rating was awarded without any study of the landscape of KEN.1/SG04. This error was pointed in the 2025 public consultation, but instead of correcting this oversight and conducting a genuine landscape study, authors have simply removed all references to the Landscape Sensitivity, Ecological and Geological Study from the new Sustainability Appraisal. This is clearly unsound and not legally compliant. Incredibly, the South Warwickshire Landscape Sensitivity Assessment prepared by LUC in April 2026, claimed concerning KEN.1/SG04 that the skyline is largely undeveloped, with no notable landmark features, despite the fact Kenilworth Castle is clearly visible from the site. This is clearly unsound and this conclusion has not reached via a robust evidence base.

Cultural Heritage

Despite various reports claiming that KEN.1/SG04 makes no contribution to the setting of the historic town of Kenilworth, there has been a deliberate prohibition on major developments to the West of Kenilworth which would impact on the setting of Kenilworth Castle for decades. The Heritage and Settlement Sensitivity Assessment, the only significant heritage assessment conducted in the SWLP process, rated the area which covers much of KEN.1/SG04 stating “There is little scope to accommodate development in this area”. Any buildings constructed on the northern part of KEN.1/SG04 would become a permanent part of the setting of Kenilworth Castle, and once development in this setting has been allowed, it would surely create a precedent to allow future developments to further degrade the setting of this internationally significant heritage asset. Whilst some recent SWLP reports had admitted developing KEN.1/SG04 would impact on the setting of Kenilworth Castle (which completely undercuts the ruling that the site makes no contribution to Green Belt Purpose D), they have suggested that buffers could be employed to minimise impacts. This would simply not be possible as the northern section of KEN.1/SG04 sits on the top and side of a hill facing the Kenilworth Castle. While the original Sustainability Appraisal made no mention of Kenilworth Castle whatsoever, the new one states there ‘may’ be an impact on the setting. These conclusions are unsound and developing this site would be inconsistent with Section 20 of the August 2026 NPPF. The Heritage Impact Analysis which was supposedly conducted in response to comments from Historic England, who asked that KEN.1/SG04 should be removed from the SWLP made no attempt to address the issues raised by Historic England. There is no indication who wrote it or what methodologies which have been used. If does not assess of the significance of Kenilworth Castle, failing to comply the requirements of the NPPF, whether that is Paragraph 207 of the December 2024 NPPF, or Section HE5:1 (and others) of the August 2026 version. As such, it cannot be considered to be legally compliant.

Economy

The Economy assessment for KEN.1/SG04 is a cut and paste assessment solely concerned with perceived economic benefits associated with the construction process and makes no attempt to assess the potential negative economic impacts associated with developing a site within the setting of Kenilworth Castle, which currently attracts around 120,000 visitors per year and supports hundreds of jobs in Kenilworth. There has been significant investment from English Heritage to develop and promote Kenilworth Castle in recent years which has seen a significant increase in visitor numbers and an associated knock-on to the local economy. This investment included £1.1m spent constructing a staircase and viewing platform in Leicester’s Building, so that people could see the view Queen Elizabeth I would have seen out of her window on her visits to Kenilworth Castle, a view which includes KEN.1/SG04. English Heritage did not spend £1.1m to impress visitors to Kenilworth Castle with a view of a brand-new housing estate.

Exceptional Circumstances

The SWLP claims that Exceptional Circumstances exist for the removal of Green Belt protection, as otherwise housing targets cannot be met. This is simply not the case as more than enough non-Green Belt sites have been identified to meet Government housing targets. It is also the case that claiming KEN.1/SG04 is a sustainable location as it is connected to an existing town is proving not to be the case. Multiple housing estates have been built this decade around Kenilworth on the basis of this sustainability argument, but what has happened is that instead of existing towns making new developments sustainable, too many new developments are making the existing towns more unsustainable. The population has increased, but the provision of public services and transport has not. It is also the case that the SWLP authors have significantly overblown the level of services at Kenilworth Railway Station, which does not meet the definition of a ‘well-connected station’, as defined by Annex B of the August 2026 NPPF.

Removal of Green Belt Protection

Green Belt Purpose A)

Green Belt Purpose B)

Green Belt Purpose D)

It is claimed in the Green Belt Reviews that KEN.1/SG04 makes no contribution to preserving the setting and character of the historic town of Kenilworth. This assessment was based solely on proximity to the Kenilworth Conservation Area. No other factors were considered. This is the sole test on which KEN.1/SG04 has been deemed to provide no contribution to Green Belt Purpose D, and therefore that protection can be removed and KEN.1/SG04 can be redesignated as Grey Belt. This is clearly unsound and not legally compliant. There has been a specific prohibition of developments to the west of Kenilworth which would impact the setting a Kenilworth Castle, which predates to foundation of the West Midlands Green Belt in 1975. Both the December 2024 and August 2026 NPPFs clearly state that the setting of heritage assets must be considered, and it is the significance of the heritage assets, not the development itself, which is the most important factor in determining in detail of such an assessment. Various reports which make up part of the SWLP such as: the Heritage and Settlement Sensitivity Assessment, the Heritage Impact Assessment, the Masterplan and the Baseline Report all admit that construction at KEN.1/SG04 would impact the setting of Kenilworth Castle. &nbsp;However, the Green Belt Reviews determined that KEN.1/SG04 made ‘no contribution’ to preserving the setting and character of the historic town of Kenilworth. This is a clear factual error meaning this conclusion is unsound and unjustified.

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