Village Housing Options and Settlement Boundaries

Object

Representation ID: 61272

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

While it is understood that the Council is currently consulting on its preferred location for small scale village expansion sites, and not strategic land allocations, RPS is of the opinion that the selection of the preferred site at Baginton Village for expansion of the settlement and the consideration of potential alternatives within the current consultation document is predicated on inaccurate and limited evidence from the strategic assessment of the larger site at Baginton, particularly the 2012 Strategic Housing Land Availability Assessment (SHLAA). The process to date can therefore be demonstrated to have inappropriately excluded from the evaluation process not only a suitable site for a wtrategic allocation, but also the potential of the land promoted by RPS to provide a more appropriate and sustainable local extension to the village of Baginton.

Object

Representation ID: 63526

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

It is demonstrated below that the authority has not considered all reasonable alternatives within the geographic scope of the plan, has not evaluated or subject the alternatives to the same level of fair public analysis and has continued to reject a site as being suitable despite significant changes of circumstance early in the plan process. It has therefore failed to comply with the above statutes as clarified by recent case law.

Object

Representation ID: 63527

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

RPS objects to the selective and inconsistent approach that the Council has taken where it continues discount parcels of Land at Baginton on no evidence (despite it being presented to the Council on many occasions) and yet at the same time inconsistently include other parcels of land adjacent to land owned by Lenco Investments as a preferred housing allocation and suitable for development.

Object

Representation ID: 63528

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Coventry City will not be able to accommodate all of its need and Warwick will need to meet in part unmet need of Coventry City, Green Belt sites will need to be considered on the periphery of Coventry City in Warwick District. Land at Baginton will therefore need to be considered as a reasonable alternative in that debate and RPS expects this to occur without prejudice and by full public analysis before any Local Plan can be submitted for examination. In this context, the preferred approach for development at Baginton of just small scale village expansion cannot be predicated on the assumption that peripheral growth for Coventry City's need will occur elsewhere, without fair and equitable consideration of the strategic context.

Object

Representation ID: 63529

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Should the fair and equitable strategic assessment process, however, deem that the preferred approach at Baginton Village is one of localised housing need only, as is currently being pursued, then RPS has illustrated that the emerging preferred option at Baginton Village has also unjustifiably excluded Lenco Investment's site from the appraisal process based upon noise and odour issues. More concerning however, the Council has included a site as its preferred option adjacent to the land owned by Lenco Investments and not drawn the same conclusions on noise and odour, or explained how that decision has been made. On the basis of the above, the current preferred option for Baginton Village is not only premature but ill founded. As such, it is unjustified and unsound, but more pertinently unlawful.

Object

Representation ID: 63530

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

The consultation document sets out that 8 sites were initially considered leading to the discounting of some and then onto a preferred option, and 3 further discounted options. It is not clear, however, how this relates to the SA/SEA process and an explanation of the full range of options that were considered and discounted, or the reasons for discounting. It is a key requirement from the SEA Directive to fully explain for public comment what alternatives have been considered and the reasons for their discounting. It appears from the documentation that not all of this information is available, nor subject to public scrutiny.

Object

Representation ID: 63531

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

RPS is of the opinion that, should it be deemed through an appropriate fair, equitable and public evaluation of reasonable strategic alternatives within the Local Plan that the needs of Coventry
City should not be met at Baginton Village, then the authority should meet the full needs of Baginton Village as set out in the Revised Strategy Document. This should include extending the area of the preferred site contained within the existing consultation document to that set out in Appendix 2. This would provide for the needs of the village appropriately both in terms of overall need as set out in the following section, and provide a far higher quality of development proposal as discussed below.

Object

Representation ID: 63532

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

While RPS supports the principle of extending Baginton Village southwards with good links to the existing village, the current approach is not sufficient to provide enough housing required for the village as set out in Section 4 of this report, nor does it provide a sensitive well designed development for this location. It is also contrary to the consultation and findings of the most recent Baginton Parish Plan, the design principles of the Local Plan Revised Development Strategy or the adopted Residential Design Guide for Warwick District. RPS has set out below its objections to the current preferred approach and sets out the justification for an extended allocation as contained in Appendix 2.

Object

Representation ID: 63533

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

The current preferred option of delivering 35 dwellings on a site of 1.22ha net on the edge of a village that has existing local densities which are considerably lower that than proposed in the draft allocation will not lead to a sensitive development that respects both the nature of the village or its setting. The density of the proposed allocation will be out of character with the existing local environs and as such will appear as an isolated tightly constrained and consolidated expansion of the village with hard landscaping edges, rather than a natural and sensitively landscape interfacing with the settlement, landscape and Conservation Area. This would be more in-keeping with the existing village.

Object

Representation ID: 63534

Received: 20/01/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

The current boundary of the allocation does not have regard to the sensitive landscape, the current visual aspect of the land, nor the need to ensure that the development positively contributes to the local environs. As such, the allocation does not have a logical landscape boundary, nor does it contain sufficient land within the allocation to provide environmental enhancement and landscaping on the approach to the village. Instead the allocation boundary follows an ownership boundary around two plots of land. The resultant impact of this is that the edge of the development plot will have a hard residential landscape edge to it rather than a natural landscape buffer that allows the development to interface with both the Conservation Area to the north and the wider landscape to the south and west. Appendix 2 illustrates how the proposed extension of the allocation can achieve this on land owned by Lenco Investments.