Proposed Modifications January 2016

Object

Representation ID: 69798

Received: 22/04/2016

Respondent: Bubbenhall Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Public consultation has been constrained to the issues of soundness. No adequate public consultation on key proposals at a stage when the Council was open to considering changes. Lack of adequate consultation renders element of the plan legally non-compliant.
NPPF states Green Belt is an areas where there is no presumption in favour of development. The erosion of the southern boundary of the city of Coventry and the harm to the villages of Baginton and Bubbenhall in terms of traffic, air and light pollution, noise, has not been given sufficient consideration. There are no 'very special circumstances' to justify development.

Object

Representation ID: 69799

Received: 22/04/2016

Respondent: Bubbenhall Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The proposal that Warwick district should take the largest share of Coventry's unmet housing need is unsound, given the Green Belt status of a large part. The NPPF requires that unmet needs from neighbouring authorities should only be accommodated 'when it reasonable to do so and consistent with achieving sustainable development'. Para 14 footnote 9 specifically excludes land in Green Belt.
Insufficient attention has been paid to infrastructure, and pressure on local roads. The proposed development at King's Hill and the proposed sub-regional employment site (DS16) and 80 houses at Rosswood Farm in Baginton (H19) will generate intolerable amounts of traffic through the villages of Stoneleigh, Baginton and Bubbenhall.
The policy has not paid sufficient attention to the Joint Green Belt Study 2015.

Object

Representation ID: 69800

Received: 22/04/2016

Respondent: Bubbenhall Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Proposing Green Belt locations for development on the edge of built-up areas is contrary to established Green Belt policies. A purpose of the Green Belt is to curb urban sprawl but the proposed policies include 'urban extension' which is the same. The SA Addendum recognizes that proposed urban extensions would have cumulative and potentially major negative effects on landscape, visual amenity and openness through loss of Green Belt and that these would remain even after so-called mitigation.
The Joint Green Belt Study, 2015 states the proposed site at Kings Hill (H43), comprises Green Belt assessed as making a considerable contribution.
The combination of unjustified sub-regional employment site (Policy DS16) and excessive housing proposals would devastate the Green Belt south of Coventry, extending Coventry's sprawl around Baginton, towards Stoneleigh and Bubbenhall.

Object

Representation ID: 69801

Received: 22/04/2016

Respondent: Bubbenhall Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The proposed approach is based on Warwick District providing in full unmet needs including those arising from outside the district (Ref Mod 20 and DS16). The Proposed Modifications claim that meeting Coventry's needs "is an important aspect of creating a sustainable and secure base for the growth of the city" (Ref Mod 21). The NPPF explicitly excludes Green Belt from its presumption in favour of sustainable development, stating that unmet needs from neighbouring authorities should be met 'where it is reasonable to do so and consistent with achieving sustainable development'.
The Government has repeatedly confirmed that the single issue of unmet demand is unlikely to outweigh harm to the Green Belt to constitute the very special circumstances needed to justify inappropriate development in the Green Belt.
The cumulative impact of meeting in full sub-regional needs for both housing and employment would be very harmful, excessive and not justified. The policy is unsound because it has not fully considered the Joint Green Belt Study 2015.

Object

Representation ID: 69802

Received: 22/04/2016

Respondent: Bubbenhall Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Joint Green Belt Study of June 2015 is listed in the Evidence Base, but its findings ignored. The associated SA Addendum makes a single mention of the JGBS with reference to Baginton as a growth village, recognizing that the JGBS 'found that the parcel of land (C14) comprising the Rosswood Farm site (H19) represents the principal protector of the countryside from further encroachment' and consequently the SA concluded that Rosswood Farm development in Baginton would have 'major negative effects on the Prudent Use of Land and Natural Resources).
The SA acknowledges the proposed urban extensions south of Coventry would have cumulative and potentially major negative effects on landscape, visual amenity and openness through loss of Green Belt and that these would remain even after mitigation.
Development in the Green Belt is excessive and not justified, particularly when the chosen sites are some of the most sensitive parts of Green Belt. The plan is unsound because it has not taken account of the Joint Green Belt Study.