These representations are made on behalf of the owners of the land referred to as Church Fields West & East in the Radford Semele Regulation 16 Draft Neighbourhood Development Plan (the draft NDP). The owners object to the proposed designation as their land as a Local Green Space in Policy RS2 of the draft NDP. The proposed designation does not meet the criteria set down in paragraph 100 of the National Planning Policy Framework (NPPF) or the national Planning Practice Guidance (PPG). The owners of the land dispute the land is of particular importance to the local community and submit there is no justification for giving it special protection against development beyond normal development management considerations.

Paragraph 100 of the NPPF states Local Green Space designation should only be used where the green space is:
(a) in reasonably close proximity to the community it serves;
(b) demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and
(c) local in character and is not an extensive tract of land.

There is no robust evidence in the draft NDP that the land is “demonstrably special” to the local community and holds a “particular local significance”.

Church Fields lies to the north of the settlement and comprises two parcels of land split by Church Lane. It is abutted to the south east by a ribbon of residential properties fronting Offchurch Lane, and to the south by a section of Offchurch Lane and the A425. To the north it is adjoined by St Nicholas Church and residential development. The eastern parcel, which constitutes the majority of the overall area is in active agricultural use. The western parcel is predominantly used for grazing purposes. There is streetlighting on Offchurch Lane, the A425 and Church Lane. There is a pelican crossing on the A425 just to the east of the junction with Church Lane. Development lines the southern side of the A425 opposite the land.

There are no public rights of way across the land nor other public access to it.

Although there are views over part of the land from the A425, a section of Offchurch Lane and from Church Lane, the land is of no particular beauty or landscape value. A proportion of the land may provide a setting to St Nicholas Church but this does not apply to the whole of the land which the draft NDP seeks to designate as Local Green Space. Furthermore, neither the setting of the Church, nor indeed of any other local heritage asset is a sufficient justification for designation of any part of the land as Local Green Space. The impacts of any future development on the setting and significance of the Church and other local heritage matters, as well as landscape impact, would be matters taken into account as part of normal development management considerations in order to comply with planning law and practice.

Further the land itself is of no particular historic significance and, once again any role its plays in contributing to the significance of local heritage assets above or below ground would be assessed as part of normal development management considerations.

As stated, there is no public access to the land which is in active agricultural use. Accordingly, it is of no recreational value.

The owners of the land dispute that the site is particularly tranquil or dark compared with other land around the settlement. Bearing in mind that there is no public access to the land the relative ‘tranquillity’ and ‘darkness’ of the site cannot be judged from within the land, only from surrounding public highways which have streetlighting and traffic movements (as noted elsewhere in the draft NDP). The view from private property is not a planning justification for designation as Local Green Space. In this case tranquillity and darkness do not justify designation as Local Green Space.

The land is in active agricultural use and is not of special ecological value.

The land amounts to an extensive tract of land amounting to 8.59 hectares and the proposal represents a blanket designation of land to the north of the A425 contrary to the NPPF and PPG. The reasons given for the designation in Table A1a of the draft NDP do not justify any part of the land being designated and the conclusion is drawn, having regard to the PPG that the proposal is a ‘back-door’ way to achieve what would amount to a new area of Green Belt by another name.

In summary the site known as Church Fields West & East should be deleted from Policy RS2 (RS2/1) of the draft NDP with consequential changes including to Policy Map 1, Policy Map 2, and Appendix 1.