Object

Representation ID: 56597

Received: 29/07/2013

Respondent: Lenco Investments

Agent: RPS Planning

The SHLAA Site at Baginton/ Coventry Gateway (reference C10) has been promoted through all previous stages of both the Warwick and Coventry Local Development Framework processes, as an appropriate site for a Sustainable Urban Extension.

It should be recognised by the Council as a sustainable site adjacent to the urban area and large-scale employment.

It could accommodate a significant proportion of housing that would contribute towards the growth of Coventry and support the Gateway scheme, ensuring compliance with the NPPF in relation to the duty to co-operate, and should be allocated within the Local Plan.

The site was identified in the 2012 SHLAA, ref. C10, but was discounted as being unsuitable for a residential development due to landscape impact, noise and air pollution from the airport, and air pollution from the sewage works.

Extensive technical assessments have been undertaken for the site in relation to flood risk, noise, ecology, conservation and heritage, landscape, which have previously been submitted to the Council.

These reports demonstrate that the site is suitable for a significant residential-led development either in isolation or in connection with proposals for the wider area. An Air Quality Assessment can also to be undertaken to demonstrate the site's suitability for development.

The principal reasons for discounting the site from the SHLAA as being suitable are therefore all unjustified and evidence has/can be provided to demonstrate already that the site is suitable.

In respect to landscape impact, not aware of any specific Landscape Assessment prepared to an industry standard methodology that provides the evidence that this area of land has significant landscape importance and the development would impact upon it.

The site was appraised for Landscape under the Green Belt Assessment work and scored Medium Value as part of a larger area of survey. However, this assessment is not sufficient to justify exclusion from the SHLAA on landscape impact as it has not assessed the site on that basis. The Council have no evidence that can justify this position at examination.

In progressing the Local Plan, Warwick District Council should ensure that it uses the most up to date evidence available to it and significant recent events to ensure that the plan is robustly justified at examination.

In this context, it should have due regard to the approval of the Gateway site and the most recent landscape evidence (submitted as part of representation) which indicates that the area can be incorporated into the landscape satisfactorily and that it has the opportunity to assist in developing local green infrastructure assets and the integration of the Gateway Development into the local landscape.

On this basis, the area clearly scores favourably on assisting the countryside from encroachment through improving the natural buffer and integration of the Gateway Site and the provision of Green Infrastructure Assets helps contribute to the setting of Baginton in a considerably positive manner through development, as demonstrated by the Council's own landscape assessment evidence.


Noise and Air pollution

Extensive technical assessments have been undertaken for the site in relation to flood risk, noise, ecology, conservation and heritage, landscape, which have previously been submitted to the Council.

These reports demonstrate that the site is suitable for a significant residential-led development either in isolation or in connection with proposals for the wider area. Similarly air quality would also not rule out the site's suitability for residential development.

It is also noted that the Council is consulting on the Gypsy and Traveller site options and have included a significant part of the site promoted (SHLAA site C10) as a suitable location for Gypsy and Traveller accommodation.

Cannot see how the Council can consider the site acceptable for residential use for Gypsy and Traveller accommodation in the context of noise and air pollution and at the same time consider it not acceptable for residential use in the SHLAA on the same grounds.

The discounting of this site on such grounds for open residential use is therefore not justified.

Sustainability Appraisal.

This site should be considered as a reasonable alternative for accommodating future housing requirements. It offers a sustainable location on the edge of a significant urban area with extremely accessible links to existing and new areas of employment and can offer to meet the needs of Coventry and Warwick.

The site should therefore form part of the assessment of alternative and option sites and appraised formally through the local plan process.

This should also involve sufficient consultation by the Council prior to examination. Expects this site to be fully appraised alongside the preferred sites as a reasonable alternative in light of the Judgment on the appraisal of alternatives from the Norfolk authorities SA case. This expects alternatives to be given the same level of appraisal and assessment to that of the preferred approach.