Testun llawn:
We support the proposed allocation of land north of Rosswood Farm for the development of 35 dwellings.
The site has been considered against reasonable alternatives and has been demonstrated have the least negative impact with good connectivity with the settlement with suitable access and provides opportunities to enhance the visual appearance of this part of the village, clearly defining an entrance to the village from the south. The site would form a logical boundary to this end of the village with development extending no further south than the pub and fronting the highway.
As such, as will be demonstrated below, the allocation of site H19 is the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence and is consequently sound.
Green Belt:
As set out in strategic policy DS4, some Green Belt will be released where exceptional circumstances can be justified. In this instance, the exceptional circumstance is to help address local housing needs and the imbalance in the current housing markets, which given the demographic trends in this physically constricted settlement is likely to have an impact on the future of the local services and facilities.
Each of the exceptional circumstances listed in Policy DS4 will be discussed in relation to this site in turn:
1. the availability of alternative suitable sites outside the Green Belt;
Baginton has been identified as a sustainable Growth Village in the Settlement Hierarchy Report (2014) meaning it is one of the most sustainable rural settlements according to a range of sustainability indicators, including the availability of local services and facilities as well as accessibility to larger settlements. Consequently, Baginton is deemed appropriate to accommodate part of the district's growth, according to the evidence base.
All alternative sites adjacent to Baginton are within the Green Belt and this site would have the least unacceptable impact on the Green Belt of the reasonable alternatives.
The site was included as parcel BAG4 under the Green Belt and Green Field Review November 2013. Whilst the parcel received a high sensitivity rating this referred to the land parcel as a whole which stretched from the A46 and sewage works, across to Coventry Road and Stoneleigh Road, as far south as Stoneleigh and Gantry Heath Wood and includes the castle. The results are therefore broad brush and not indicative of the entire parcel which was then assessed separately as a sub-parcel.
The sub‐parcel was considered to be "one which could accommodate a village extension as part of a sustainable pattern of development within the proposed village inset, with a modest impact on the fundamental aim and purposes of the Green Belt."
Furthermore, all of the land parcels at Baginton were considered to have between medium and high landscape value, save for land parcel BAG6 which is the very small parcel adjacent to the A46.
In addition to the Green Belt and Green Field Review, the owners of the site have sought specialist advice from landscape architects who have produced a full Landscape and Visual Impact Assessment (LVIA) and Site Comparison Assessment which are submitted alongside this representation. The LVIA exceeds the size limit so will be emailed separately. These documents demonstrate that site H19 could be developed without causing unacceptable harm to the landscape or result in an unacceptable visual impact and crucially, that development would have significantly less landscape and visual impact than the other sites considered as part of the Local Plan process meaning it is the most suitable choice for development at Baginton. All alternative sites around Baginton are within the Green Belt so no non-Green Belt options exist.
Taking into account the site conditions, visibility and the nature of the development proposals assessed, it is felt that the site could be developed without causing unacceptable harm to the landscape or result in an unacceptable visual impact and recommends various mitigation measures to minimise this impact.
2. the potential of the site to meet specific housing or employment needs that cannot be met elsewhere;
Given the considerable extent of the Green Belt in Warwick District, in order to provide for the district's full objectively assessed need in the locations where this need arises, Green Belt releases will be necessary.
Locating all growth outside of the Green Belt would result in a disproportionate amount of development in the south-eastern corner of the district and deprive the majority of the district of the benefits that growth can bring.
Paragraph 83 of the NPPF states that the appropriate time for the review of Green belt boundaries is through the preparation or review of the Local Plan. In doing so, consideration should be given to the permanence and endurance of the Green Belt boundaries in the longer term beyond the plan period. If Green Belt releases are not made at this point, the remainder of the District which is not in the Green Belt would be unable to accommodate the District's full objectively assessed need and it would therefore be likely that an early review of the Local Plan would be necessary. The current Green Belt boundaries cannot therefore endure in the longer term.
The housing needs of Baginton, which lies to the far north-east of the District, cannot be met through new development in the south of the District.
3. the potential of the site to support regeneration within deprived areas;
Given the relatively small scale of the allocation and that it is to serve the needs of Baginton which has no regeneration sites, allocation of this site would not prejudice opportunities for urban regeneration elsewhere within the District.
4. the potential of the site to provide support to facilities and services in rural areas.
Development of his site provides an opportunity to assist in re-balancing the local housing markets in Baginton and to provide much needed affordable housing and market homes for local residents. With new housing comes the positive benefits of helping support and sustain local services, facilities and businesses.
Site H19 serves none of the five purposes of including land in the Green belt, as defined in paragraph 80 of the NPPF:
To check the unrestricted sprawl of large built-up areas;
Baginton is a growth village; it is not a large urban area. Whilst close to Coventry, the site is remote from the edge of Coventry and located to the south of Baginton so the site does not act to constrain sprawl from Coventry.
To prevent neighbouring towns from merging into one another;
Whilst in the proximity of Coventry, the site is a considerable distance from Kenilworth, Warwick and Leamington Spa so would in no way contribute to the merging of these towns.
To assist in safeguarding the countryside from encroachment;
Although the site is located in the countryside it is adjacent to the village of Baginton and would not represent unacceptable encroachment. The site has been demonstrated to be the least impact on the Green Belt of the other Baginton site options. This is dealt with fully in the LVIA submitted with this representation.
To preserve the setting and special character of historic towns;
The sensitive historic features of Baginton, i.e., the Lunt Roman Fort, Baginton Castle and Fish Ponds lie to the north and west of the village, remote from the site. The site does not contribute to preserving the historic setting of Baginton.
The above evidence demonstrates that, measured against National Green Belt policy, the release of site H19 from the Green Belt is the most appropriate strategy when considered against the reasonable alternatives and allocation of the site is consequently sound.
Landscape:
Site H19 has been demonstrated by the Landscape Sensitivity and Ecological & Geological Study and the Green Belt Review to be the most appropriate site in Baginton for development in visual landscape terms.
The Landscape Sensitivity and Ecological & Geological Study has identified the site as having a high-medium sensitivity to housing development. To put this in context, of the 13 sites assessed in Baginton, 9 have been assessed to have a high sensitivity to housing development. Three were considered medium-high (including the preferred development site) and one assessed to have medium sensitivity. The medium site lies within the airport area and disconnected from the village.
The Landscape Sensitivity and Ecological & Geological Study recommends that development should be restricted to roadside only, with a landscape buffer of native tree planting to the west with development not being extended further south than the pub. These visual impact mitigation measures are all entirely achievable on this site. It also identifies that the visual appearance of the area has already been slightly degraded due to the lack of hedgerows which have been replaced by post and wire / tape fences and that Coventry Airport is very visible beyond the zone to the east. It identifies the potential for landscape enhancement as a result of development through replacing native hedgerows and the planting of a landscape buffer of native woodland around the new development.
Notwithstanding this, in order to better inform how this site can be sensitively masterplanned to accommodate the proposed level of development with least impact on the Green Belt, the site owners have sought specialist advice from landscape architects.
Consequently a full Landscape and Visual Impact Assessment is submitted alongside this representation. The LVIA exceeds the size limit so will be emailed separately. This demonstrates that:
Due to the local topography significant visual impacts are apparent only from certain locations, particularly nearby. The overall visual impact without mitigation was assessed to be moderate.
With mitigation measures, the landscape and visual impact were found to be low.
The mitigation measures recommended by the LVIA are:
* Implementation of perimeter tree and hedgerow planting as proposed
* Preservation of the existing roadside hedge and trees
* Use of native hedging shrub species to increase biodiversity and enrich the local habitat
The LVIA recommends that by employing these specific mitigation measures (as part of the site landscape proposals) it is considered that detrimental effects of landscape and visual impacts can be minimised.
In summary the LVIA concludes that taking into account the site conditions, visibility and the nature of the development proposals assessed, it is felt that the site could be developed without causing unacceptable harm to the landscape or result in an unacceptable visual impact.
Also submitted alongside the LVIA is a Site Comparison Assessment which concludes that site H19 could be developed with significantly less landscape and visual impact than the other sites considered as part of the Local Plan process, and due to the absence of other constraints such as contamination, existing trees, access problems, air pollution and flooding is the most suitable choice for development at Baginton.
The above demonstrates that, in light of the evidence base, allocation of site H19 is the most appropriate strategy when considered against the reasonable alternatives and is consequently sound.
Access:
There is currently an existing access into the site on Church Road opposite the bus stop. The advice regarding highways and transportation is that the site has excellent access to public transport with a pavement which provides safe access for pedestrians into the village centre. There are likely to be major positive effects on access to public transport which will outweigh any negative effects of the increase in traffic through allocation of this site which are likely to be minor.
In light of the evidence base, allocation of site H19 is the most appropriate strategy when considered against the reasonable alternatives and is consequently sound.
Flooding:
The effects on flooding are considered to be neutral for this site which lies outside of a flood risk zone and any development approved would be designed in accordance with SUDs and the NPPF requirement that development would not increase flood risk elsewhere.
In light of the evidence base, allocation of site H19 is the most appropriate strategy when considered against the reasonable alternatives and is consequently sound.
Environmental Health:
Whilst the site could be subject to noise, odour, light and air quality due to the proximity of the airport and sewage works, all the sites assessed in Baginton were within proximity of the sewage works so this constrain affects all sites equally. With regard to the airport, this can be mitigated by appropriate masterplanning and noise attenuation measures.
In light of the evidence base, allocation of site H19 is the most appropriate strategy when considered against the reasonable alternatives and is consequently sound.
Connectivity/Sustainability:
Whilst the site lies on the southern tip of the village it would be well connected to the existing village services, meaning development would not be peripheral or detached. The village does not have a defined "centre" with the main services (village hall, post office and pub) being spread throughout the village. The post office and village hall are to the north of the preferred site option with the pub in very close proximity to the south.
With the bus stop opposite the site and a pavement to all of the services it has excellent walking and public transport links. The pub lies directly opposite the site with open space (Millenium Field) directly adjacent. The village shop and post office is less than 500 metres from the site, an acceptable walking distance with the village hall just in excess of 500 metres from the site. The Manual for Streets (Paragraph 4.4.1) states "walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes' (up to about 800 m) walking distance of residential areas which residents may access comfortably on foot".
Whilst there are no healthcare or education facilities in Baginton, proximity of the village to Coventry means that it is reliant upon Coventry for such services.
In light of the evidence base, allocation of site H19 is the most appropriate strategy when considered against the reasonable alternatives and is consequently sound.
Whilst we are not seeking a modification, we would welcome the opportunity to participate in the oral examination in order to be able to fully represent the benefits of the site which cannot be dealt with satisfactorily through written representations alone.