Thank you for providing Harris Lamb Planning Consultancy (HLPC) with the opportunity to provide comments on the proposed Baggington, Bubbenhall, Stoneleigh and Ashow Parish Neighbourhood Plan Boundary. HLPC are instructed to make representations to the consultation by La Salle Investment Management (LIM). LIM control Stoneleigh Park, one of Warwick District's key employment sites. The entirety of the Park is in the proposed Neighbourhood Plan area. As such any Neighbourhood Plan has the potential to have significant implications for the operation of the Park. It will introduce an unnecessary and undesirable layer of planning policy.
It is, therefore, our view that Stoneleigh Park should be excluded from the Neighbourhood Plan area.

Background
Stoneleigh Park is a unique facility within the Green Belt in terms of its scale (c 100 hectares) and the range of activities taking place there. It became the permanent home of the Royal Agricultural Society of England (RASE) in 1963. The role of RASE is defined by its Royal Charter and in fulfilling this role Stoneleigh Park acts as the headquarters for a number of agricultural and countryside organisations as well as hosting many shows and conferences. There are in excess of 70 businesses on the site employing over 1,100 people and this is expected to increase by 1,500 employees over the next 15 years to 2,600 employees.
LIM have agreed a 150 year lease at Stoneleigh Park with the RASE. Under this agreement the management and development of Stoneleigh Park is the responsibility of LIM while RASE concentrates on its role to be champion of rural and agricultural advancement. As part of a long term plan to secure the future of Stoneleigh Park there is a shared vision between RASE and LIM to develop the site as an innovation science park as well as rural businesses and research activities. It is LIM's intention to work with the Council , local residents and other interested stakeholders to help revitalise and deliver sustainable development at Stoneleigh Park.

LIM agreed the lease at Stoneleigh Park on the basis that Stoneleigh Park should evolve into a national hub for rural and sustainable research alongside an equine centre of excellence and innovation and Science Park. The Park should attract businesses involved in the sustainability and knowledge based industries. Showground events will continue to provide unique opportunities to showcase knowledge and trade. Farming, education and higher education providers will ensure that new methods are exchanged and debated at the existing events, hotel and conference facilities.

In order to assist in delivering this objective, Warwick District Council have granted planning permission for a major mixed use development on the site (application reference: W/12/0766).

Outline planning permission was granted in November 2012 for:
"Outline planning application for the development/redevelopment and use of buildings at Stoneleigh Park to provide a science, business, technology and innovation park (Use Class B1(a) and B1 (b) equine facilities, livestock and agricultural facilities, education and learning (Use Class D1), research (Use Class B1b), sustainability and energy, exhibitions, showground, hotels and conference facilities (Use Class C1ID1), animal husbandry, animal hospital, visitor centre, camping facilities, together with other ancillary uses and activities including retail, leisure and catering, and associated roads, footpaths, cycle routes, junction improvements, parking, servicing and landscape (including off-site highways infrastructure) which support the functioning of the Park and demolition of some buildings and infrastructure".

This planning permission allows for the quantum of floors pace on the site to be increased by approximately 28% from 96,347 sq. m. to 123,672 sq. m. There is the ability to submit reserved matters applications under this outline planning permission until November 2020. A series of applications have been submitted to the local authority to discharge the various precommencement conditions associated with this planning permission. Furthermore two reserved matters planning applications have been approved.

Since the grant of this outline planning permission the route of HS2 has been safeguarded, which passes directly through Stoneleigh Park. This does have significant implications for future development at Stoneleigh Park. However, LIM remain committed to working with the local authority in order to deliver new development to assist in realising Stoneleigh Park's role as a high quality rural science and innovation park. It has been agreed with the District Council that whilst the HS2 safeguarding does impact upon the indicative masterplan submitted with the outline planning permission, the outline planning permission is flexible enough to deliver the range of uses identified and the quantum of floorspace proposed at Stoneleigh Park, albeit in an alternative configuration.

Turning to the Development Plan, the adopted Warwick District Local Plan and the emerging Warwick Local Plan both include text that recognise the important role that Stoneleigh Park plays within not only the local, but also the regional economy. These plans include policy guidance to help Stone leigh Park continue to develop given its important role in the economy. Indeed, Stoneleigh Park is identified as one of nine sites in Warwick District that is expected to help the Council to deliver 47.35 ha of employment land during the plan period.
In summary, Stoneleigh Park is a key employment site where new development is actively supported by the Council.

Removal of Stoneleigh Park from Neighbourhood Plan Area
It is LIM's view that Stoneleigh Park should be excluded from the emerging Baggington, Bubbenhall, Stoneleigh and Ashow Neighbourhood Plan area. It is our view that the inclusion of Stoneleigh Park within the Neighbourhood Plan area is unnecessary and has the potential to significantly hinder the delivery of development on the site. It is suggested that Stoneleigh Park could be excluded from the Neighbourhood Plan area on the following grounds.

1. Desirability of Plan Area
The National Planning Practice Guidance (NPPG) sets out a series of requirements for Neighbourhood Plans including the role the local authority should play in assessing Neighbourhood Plan areas. The NPPG advises at paragraph ID: 41-032-20140306 that local planning authorities are required to have regard to the "desirability" of designating the whole of the area of a Parish or Town Council as a Neighbourhood Plan area. The NPPG goes on to advise that local planning authorities should consider a range of factors when determining Neighbourhood boundary areas including:
* Whether the area forms all or part of a coherent site either for businesses or residents; and
* Whether the area is wholly or predominantly a "business area". In business areas there should be two referendums, one for residents and one for businesses operating in the area, if the Neighbourhood Plan progresses that far. If both referendums agree (i.e. either both say yes or both say no) the decision is binding on the local authority. If the two referendums return a different decision, it will then be for the local authority to decide whether they should bring the Plan or Order into legal force In considering the "desirability" tests it is necessary to have regard to the requirements of the National Planning Policy Framework (the Framework). Stoneleigh Park is an employment site of strategic importance. The Framework advises that the Government is committed to securing economic grow1h in order to create jobs and prosperity building on the country's inherent strengths. The planning system should do "everything it can" to support sustainable economic grow1h. Planning should operate to encourage and not act as an impediment to sustainable grow1h. Significant weight should be placed on the need to support economic grow1h through the planning system (paragraph 19). Investment in businesses should not be overly burdened by the combined requirements of planning policy expectations (paragraph 21).

The message in the Framework is clear. The planning system should actively encourage sustainable economic grow1h and not introduce policies to constrain sustainable employment developments.
The adopted Local Plan includes a specific policy to guide the development of Stoneleigh Park (policy SSP3 - Stoneleigh Park). Furthermore, the emerging Warwick Plan includes a new policy, MS2 - Major Sites in the Green Belt that provides guidance in the policy and its supporting text on how future development proposals will be treated at Stoneleigh Park. The exact policy wording is currently the subject of negotiation between HLPC and officers of Warwick District Council and it is expected that a Statement of Common Ground will be agreed prior to the Examination with updated wording. Furthermore, there is an outline planning permission in place that will guide the future development of Stoneleigh Park for the next several years. The policies in the adopted and emerging Local Plan and the outline planning application have all been the subject of public consultation. The policies and outline planning permission guiding the development at Stoneleigh Park have all been informed by the views of the public.

It is our view that it is not "desirable" to include Stoneleigh Park within the Neighbourhood Plan boundary as there is the potential to introduce a further layer of planning policy that is not necessary. There is already ample guidance in place in the form of adopted and emerging local plan policy and the outline planning application to guide development at Stoneleigh Park. Any Neighbourhood Plan has the potential to add an unnecessary layer of additional planning policy that has the potential for development at Stoneleigh Park being "overburdened by the combined requirements of the planning policy expectations". The introduction of policies to guide the development of Stoneleigh Park in any Neighbourhood Plan is both unnecessary and undesirable.
Furthermore, in considering Neighbourhood Plan boundaries local authorities are required to consider whether part of an area forms all or part of a coherent site for businesses or residents and whether the area is wholly or predominantly a business area. There are distinct character areas within the proposed Neighbourhood Plan area. Whilst the villages are clearly residential in character, Stoneleigh Park and Coventry Airport are clearly large scale employment sites. Indeed, on plan at least, it would appear that the amount of employment land area within the proposed Neighbourhood Plan Area is significantly greater than the amount of residential area. In our view it would be more appropriate to exclude the large scale employment areas from the Neighbourhood Plan area given the significant scale, the strategic importance and different characters that these areas have to the residential elements of the proposed Neighbourhood Plan area.

2. The Justification for the Proposed Neighbourhood Plan Area
The NPPG requires applications for Neighbourhood Plan areas to be accompanied by a statement explaining why the proposed neighbourhood area is an appropriate area (paragraph 10: 41- 032- 20140306). Local planning authorities should take into account the Relevant Body's statement explaining why the area applied for is considered to be appropriate (10: 31-035 - 20140306). The Application for the Designation of a Neighbourhood Plan letter, of the joint Parish Councils (21 S1 November 2014) advises that it is believed that the Neighbourhood Plan is appropriate as it "recognised the rural nature of the Parish and the needs of the villages and commercial parts of the Parishes, it is essential to balance demand of all parts so that the most appropriate development plan is produced for the whole of the Parishes".
There is not, in our view, a proper explanation why it is necessary for Stone leigh Park to be incorporated within the Neighbourhood Plan. The commercial interests and pressures that affect the Park are best understood by LIM. LIM are of the view that the current and emerging planning policy situation is appropriate to guide future development at the Park. The existing and emerging Local Plan policies have been developed following detailed discussions with officers and both the planning and economic departments of the Council. There is no need to add an additional layer of policy guidance or explanation in the Council's statement as to why this would be appropriate. It is not clear what the Parish hopes to achieve by including Stoneleigh Park in the Neighbourhood Plan Area and how including the Park in the Neighbourhood Plan will actively support the Frameworks presumption in favour of sustainable development.
3. Duplication of Policies
Whilst the NPPG advises that Neighbourhood Plans can include sites that are allocated for development in a Local Plan, it is necessary for the parties producing the Neighbourhood Plans to discuss with the local planning authority the planning context and circumstances that may inform the local planning authority's decision on the area it will designate. Furthermore, if the local planning authority is intending to, or has, allocated sites for development in the Neighbourhood Plan area, the local planning authority should avoid duplicating planning processes that will apply to the Neighbourhood Plan area.
As referred to above, both the adopted emerging Warwick District Local Plan include policies to guide the development of Stoneleigh Park. Stoneleigh Park is recognised as a key employment site by both documents and it is actively expected to contribute towards not only Warwick District's economy but also the sub-regional economy. This clearly suggests that it is inappropriate for Stoneleigh Park to be included in the Neighbourhood Plan since to do so would clearly result in "duplicating planning processes that will apply to the neighbourhood area".

It is also noted that the NPPG advises at paragraph 41 - 043 -2010306 that Neighbourhood
Plans should not be used to constrain the delivery of strategic sites allocated for development in the Local Plan. Any policies within the Neighbourhood Plan guiding the development of Stoneleigh Park can, therefore, have a limited influence on future development within the Park's boundaries as they can constrain development beyond what is already proposed or approved by the outline planning permission. There is, therefore, little point in Stoneleigh Park being in the Neighbourhood Plan.

4. Business Area
It is also questionable whether the proposed Neighbourhood Plan area would constitute a "business area". In order to be considered a "business area" the Plan area in accordance with the definition in the NPPG should be wholly or predominantly used for businesses. Whilst the proposed Neighbourhood Plan area includes a number of villages, there are significant employment sites within the Plan boundary including Stoneleigh Park and the Coventry Airport site. In our view there is a case to be made that the area should be treated as a predominantly business area given the balance of employment to residential land uses. As a consequence, the non-domestic rate payers within the Plan area should also have the opportunity to vote in any referendum on the Neighbourhood Plan's ultimate adoption if the large commercial areas are included within the finalised Plan area.

We trust you have found these representations useful. If you have any comments, or would like to discuss this matter further, please do not hesitate to contact me.

Network Rail is the owner and operator of Britain's railway infrastructure, which includes the tracks, signals, tunnels, bridges, viaducts, level crossings and stations - the largest of which we also manage. All profits made by the company, including from commercial development, are reinvested directly back into the network.

Network Rail has the following comments to make.

The proposal area includes Network Rail land in the Stoneleigh section as well as running the boundary alongside our land and the operational railway.
Whilst Network Rail has no objection in principle to the Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan, we are concerned developments within the boundary red line will not require planning permission. Network Rail is a statutory undertaker and as such LPAs consult our Town Planning Teams on a wide variety of proposals that may impact upon Network Rail land and infrastructure. We are consulted about proposals next to, near to, on, under or over the railway as well as schemes for stations, mining and mineral extraction and also proposals that might impact upon Network Rail access points, level crossings etc.

We are concerned that the Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan which shares a boundary with the railway may result in proposals being undertaken near to or next to the operational railway / Network Rail land which may impact upon its safety and operation as we will not have had the opportunity (as via the current planning application notification process) to review and pass comments on vital asset protection measures to the council and developer / applicant. Equally we would be concerned if any Network Rail rights of access were affected by proposals, as these require unblocked access around the clock including emergency vehicles.

In light of the above we would request that the Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan group should contact Network Rail for any proposals within the area to ensure that:
(a) Access points / rights of way belonging to Network Rail are not impacted by developments within the area.
(b) That any proposal does not impact upon the railway infrastructure / Network Rail land e.g.
* Drainage works / water features
* Encroachment of land or air-space
* Excavation works
* Siting of structures/buildings less than 2m from the Network Rail boundary / Party Wall Act issues
* Lighting impacting upon train drivers ability to perceive signals
* Landscaping that could impact upon overhead lines or Network Rail boundary treatments
* Any piling works
* Any scaffolding works
* Any public open spaces and proposals where minors and young children may be likely to use a site which could result in trespass upon the railway (which we would remind the council is a criminal offence under s55 British Transport Commission Act 1949)
* Any use of crane or plant
* Any fencing works
* Any demolition works
* Any hard standing areas
We would very strongly recommend that the Baginton, Bubbenhall, Stoneleigh & Ashow Parish Neighbourhood Plan Area authority / group are made aware that any proposal within 10m of the operational railway boundary will also require review and approval by the Network Rail Asset Protection Team, and such schemes should be accompanied by a risk assessment and a method statement.

We would request that the Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan Area authority / group when submitting proposals for a development contact Network Rail's Town Planning Team and include a location plan and a description of the works taking place for review and comment.

All initial proposals and plans should be flagged up to the Network Rail Town Planning Team London North Western Route at the following address:

RE: Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan Area Consultation
Thank you for consulting High Speed Two (HS2) Ltd on the above proposal to designate a Neighbourhood Plan Area.
While HS2 Ltd has no specific comments to make on the proposed designation, should a neighbourhood plan be produced for the area it should take account of the proposed Phase One line of route of HS2 which passes through this Neighbourhood Area. Further advice is provided in paragraphs 22-27 of the guidance for Local Planning Authorities to accompany the adopted safeguarding direction, which can be found at the link below.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/379788/HS2_Phase_One_safeguarding_directions__June_2014_.pdf

Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan - Area Designation

Thank you for the notification of the 13 February 2015 consulting The Coal Authority on the above

The Coal Authority is a non-departmental public body which works to protect the public and the environment in coal mining areas. Our statutory role in the planning system is to provide advice about new development in the coalfield areas and also protect coal resources from unnecessary sterilisation by encouraging their extraction, where practical, prior to the permanent surface development commencing.

As you will be aware the proposed neighbourhood plan area is located within the deep coal resource area of the defined coalfield. However no surface coal resource is present and there is no 'high risk' mining legacy features present in the plan area. The eastern side of the proposed area falls in the 'development low risk'. Consequently The Coal Authority has no specific comments to make on the Neighbourhood Plan.

In the spirit of ensuring efficiency of resources and proportionality it will not be necessary for you to provide The Coal Authority with any future updates to the emerging Neighbourhood Plan. This letter can be used as evidence for the legal and procedural consultation requirements.

The Coal Authority wishes the plan team every success with the preparation of the Neighbourhood Plan.

Dear Sir,

NEIGHBOURHOOD PLAN AREA CONSULTATION FOR BAGINTON BUBBENHALL STONELEIGH AND ASHOW

BAGINTON, BUBBENHALL, STONELEIGH AND ASHOW

Thank you for engaging with the Environment Agency for the designation of the above area.

Drawing up a neighbourhood plan is an opportunity to think about improving a local environment. General opportunities for neighbourhood planning include:

* New green spaces or improvements to public space through new development. This could include linking open spaces to make green corridors for people and wildlife, planting trees, or making improvements to local waterways.
* Helping a community to manage the risk of flooding by providing landscaping to manage and store water and by promoting the use of sustainable drainage systems (SuDS).
* It could also help to promote the use of wood and recycled materials in construction and encourage energy efficiency measures for new builds. These measures will reduce the cost of construction for developers and help to reduce utility bills for those using the building. This will also help the environment by reducing emissions and improving air quality.

A key principle of the planning system is to promote sustainable development. Sustainable development meets the needs for housing, employment and recreation while improving the environment. It ensures that the right development is built in the right place at the right time.



To assist in the preparation of any document and sustainable development we have identified the following information to help you maximise environmental gain from future development and to reduce its environmental impact.

Water Quality

The Water Framework Directive (WFD) came into force on December 2000 and was transposed into UK law in December 2003. The first principle of the WFD is to prevent deterioration in aquatic ecosystems. No deterioration requires that a water body does not deteriorate from its current ecological or chemical classification and applies to individual pollutants within the water body.

There are five WFD river catchments within, or just falling outside of the neighbourhood area:

* GB109054044620, River Sherbourne;
* GB109054043920, River Avon;
* GB109054043840, River Avon;
* GB109054044540, River Sowe; and
* GB109054044480, Finham Brook


The waterbodies are achieving a 'Moderate' or 'Good' status.

The Environment Agency has worked with a number of partners to deliver a variety of projects in the Warwickshire Avon catchment that have sought to mitigate pressures preventing good status in water bodies. These have included community projects to reduce pollution from urban areas in Coventry, mitigating barriers to fish movements on the River Sowe, soil management workshops for farmers and campaigns to educate the public and businesses about misconnections to surface water drains.

It is hoped that any Neighbourhood Plan in this area would actively encourage practices and developments that would help prevent deterioration in water quality and maximise the environmental benefits. In particular, it is hoped that farmers are encouraged to reduce their inputs into local watercourses in order to improve the local water environment.

We would welcome the opportunity to provide advice on practices and future proposals to avoid unexpected issues arising.

Water Resources

The Neighbourhood Plan should take into account the availability of potable water supply when assessing new development in the area. The parish lies within the area supplied by Severn Trent Water and it is assumed that any additional water will be supplied using existing courses and under existing abstraction licence permissions. Advice should be sought from the water company to find out whether this is the case, or whether new sources will be needed in the future. For further information on where water is available for abstraction in the area, please see:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/291400/LIT_2604_7a244e.pdf


Every opportunity should be taken to build water efficiency into new developments and innovative approaches should be encouraged.

Any proposed development should consider setting high standards regarding water use and other indicators to deliver sustainable development. Making a minimum of Code Level 3 or 4 of the Code for Sustainable Homes mandatory, would ensure high water efficiency and sustainability performance is achieved for all buildings.

We encourage water efficiency in all development. For residential proposals, we recommend a minimum standard of Level 3 of the Code For Sustainable Homes. For advice see:

http://www.planningportal.gov.uk/uploads/code_for_sustainable_homes_techguide.pdf

For commercial use, we recommend rainwater harvesting and grey water recycling. Development should try to meet the 'very good' rating under the BREEAM Standard for non-residential development. www.breeam.org

Flood Risk

The Parishes contains sections of Main River: River Avon, River Sowe, Finham Brook. The floodplain extent can be viewed in the 'What's in your Backyard?' section of the Environment Agency's website at www.environment-agency.gov.uk

We would hope that any Neighbourhood Plan in this area would consider the need not only that flood risk does not increase, but will seek to actively reduce flood risk and provide betterment wherever possible in line with paragraph 100 of National Planning Policy Framework (NPPF). It is also considered appropriate for a Neighbourhood Plan to investigate possibilities to enhance watercourse corridor biodiversity, as well as contribute to achieving WFD aims of improving the ecological status of the waterbody.

Although the Environment Agency will remain concerned with flooding from main rivers, the Lead Local Flood Authority (in this case Warwickshire County Council) is the lead for local flood risk which includes groundwater, surface water and ordinary watercourses and should be included in any discussions. Further information about flood risk can be found in the Warwickshire County Councils Strategic Flood Risk Assessment at: http://www.warwickshire.gov.uk/sfra

Works proposed to main rivers, functional flood plains or within 9m of the landward toe of the channel: Any proposed works affecting statutory main rivers or within the indicative floodplain or within the byelaw distance requires the prior written consent of the Environment Agency under the relevant statutory legislation and current land drainage byelaws. Please contact the Environment Agency Partnerships and Strategic Overview team if further information is required.

Surface water drainage

The Neighbourhood Plan is essentially placed to play a vital role in managing surface water runoff and reducing the risk of surface water flooding. This can be achieved through an understanding at a local level of existing surface water flooding issues and recommending action to alleviate or resolve these issues. The Neighbourhood Plan can then go further and actively promote sustainable methods of drainage that ensure surface water runoff does not increase as a result of new development.

It is strongly recommended that the Plan includes strong support for Sustainable Drainage Systems (SuDS). These can achieve multiple environmental benefits not only by reducing flood risk from surface water, but also in areas such as biodiversity, amenity and water quality.

Documents such as Ciria C697 (the SuDS Manual) and Part H of the Building Regulations 2000 can provide excellent reference points for determining a suitable working practice for surface water drainage considerations. It should be noted that any such recommendations within the Neighbourhood Plan must conform to and complement the requirements and aims of local planning policy, as well as the Lead Local Flood Authority's aims in respect of their role as SuDS Approval Body

Groundwater

NPPF paragraph 109 states that the planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of water pollution. Government policy also states that planning policies and decisions should also ensure that adequate site investigation information, prepared by a competent person, is presented (NPPF, paragraph 121).

The majority of the Parishes are underlain by a variety of bedrock which is classified as a Principal Aquifer. Principal Aquifers are geological strata that exhibit high permeability and provide a high level of water storage. They may support water supply and/or river base flow on a strategic scale. The use of groundwater in the area makes parts of the area vulnerable to pollution from certain types of development. In addition, parts of Stoneleigh lie within groundwater Source Protection Zone classification 3.

A number of historic landfill sites are located within the Parishes. These are:

* Home Farm, Kimberley Road, Baginton, Coventry, Warwickshire, which operated from 1979 to 1983 and was licensed to accept inert waste.
* Hall Drive, Baginton (our records show that no further information is available)
* Rowley Road, Baginton, which operated from 1961 until 1970 and accepted household waste and liquid sludge. Gas control measures have been taken at some point during the sites lifetime.
* Coventry Airport, Baginton, which operated from 1974 until 1989 and accepted, inert, commercial and household waste as well as liquid sludge
* Rock Farm, Baginton, Coventry, which operated from 1940 until 1991 and accepted inert, industrial and special (hazardous) waste as well as liquid sludge
* Disused Gravel Pits, A445, Bubbenhall, Ryton on Dunsmore, Warwickshire which operated from 1978 to 1993 and accepted inert, industrial, commercial, household and special (hazardous) waste as well as liquid sludge

We are able to provide further advice on protecting groundwater, including guidance on the use of SuDS.

We recommend that developers:

1. Follow the risk management framework provided in CLR11, Model Procedures for the Management of Land Contamination, when dealing with land affected by contamination. 2. Refer to the Environment Agency Guiding Principles for Land Contamination for the type of information that we require in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, such as human health.
3. Refer to the Severn River Basin Management Plan (currently out for consultation).
4. Refer to our website at www.environment-agency.gov.uk for more information.

We would like to refer the enquirer to our groundwater policies in Groundwater Protection: Principles and Practice (GP3), available from our website. This sets out our position for a wide range of activities and developments including:

* Waste management
* Discharge of liquid effluents
* Land contamination
* Ground source heat pumps
* Cemetery developments
* Drainage

Piling or any other foundation designs / investigation boreholes / tunnel shafts / ground source heating and cooling systems using penetrative methods can result in risks to potable supplies from, for example, pollution / turbidity, risk of mobilising contamination, drilling through different aquifers and creating preferential pathways. Thus it should be demonstrated that any proposed piling will not result in contamination of groundwater.

Waste

The waste hierarchy - reduce, re-use, recycle - should be implemented when developing proposals within the Parish. Community composting schemes and the necessary waste handling facilities could be developed as part of the essential infrastructure within the Parish.

The Neighbourhood Plan should be based on a robust long term vision and a clear enough structure for development and change to help make it happen even with changes in political and economic conditions. We look forward to engagement with the Parish to tackle issues and achieve exemplar development wherever possible.

We cannot over-emphasise the importance of early pre-application discussions on all proposals to ensure that any initial issues can be resolved and subsequent planning applications can run smoothly. As sites or more detailed area plans come forward, we will provide more detailed comments. Early liaison will achieve our aim of ensuring that schemes are enabled in a joined up way and avoid issues arising unexpectedly at advanced stages in the process.

Climate Change

We now have a role to provide advice and support to businesses, public sector and other organisations to help them adapt to changing climates. Our aim is to help key sectors increase their resilience to climate risks and we are working closely with Defra as part of Climate Ready - the Government's national programme for adaptation, to help achieve this. It is therefore hoped that the Neighbourhood Plan in this area would encourage development that would address climate change. We would welcome the opportunity to provide any early pre-application advice on future development.

Natural England, together with the Environment Agency, English Heritage and Forestry Commission has published joint advice on neighbourhood planning which sets out sources of environmental information and ideas on incorporating the environment into plans and development proposals. We have appended this to the letter for useful advice.

Please note that this advice is given in good faith on the basis of the information supplied at the time of writing. This advice is given without prejudice to matters that may arise from further information, consultation or examination and id therefore not binding on any formal consultation reply or decision that may be made by the Environment Agency.

Should you require any additional information, or wish to discuss these matters further, please do not hesitate to contact me on the number below.

Baginton, Bubbenhall, Stoneleigh & Ashow Neighbourhood Plan Area Consultation
Thank you for consultation dated 13 February 2015 notifying Natural England of your Neighbourhood Planning Area.
Natural England is a statutory consultee in neighbourhood planning. We must be consulted on draft Neighbourhood Development Plans where the Town/Parish Council or Neighbourhood Forum considers our interests would be affected by the proposals. We must be consulted on draft Neighbourhood Development Orders and Community Right to Build Orders where proposals are likely to affect a Site of Special Scientific Interest or 20 hectares or more of Best and Most Versatile agricultural land. We must also be consulted on Strategic Environmental Assessments, Habitats Regulations Assessment screening and Environmental Impact Assessments, where these are required. Your local planning authority will be able to advise you further on environmental requirements.
The following is offered as general advice which may be of use in the preparation of your plan.
Natural England, together with the Environment Agency, English Heritage and Forestry Commission has published joint advice on neighbourhood planning which sets out sources of environmental information and ideas on incorporating the environment into plans and development proposals. This is available at: http://webarchive.nationalarchives.gov.uk/20140328084648/http://cdn.environment-agency.gov.uk/lit_6524_7da381.pdf
Local environmental record centres hold a range of information on the natural environment. A list of local records centre is available at: http://www.nbn-nfbr.org.uk/nfbr.php
Protected landscapes
If your neighbourhood planning area is within or adjacent to a National Park or Area of Outstanding Natural Beauty (AONB), we advise that you take account of the relevant National Park/AONB Management Plan for the area. For Areas of Outstanding Natural Beauty, you should seek the views of the AONB Partnership.
National Character Areas (NCAs) divide England into 159 distinct natural areas. Each is defined by a unique combination of landscape, biodiversity, geodiversity and cultural and economic activity. Their boundaries follow natural lines in the landscape rather than administrative boundaries, making them a good decision making framework for the natural environment.
http://www.naturalengland.org.uk/publications/nca/default.aspx
Protected species
You should consider whether your plan or proposal has any impacts on protected species. To help you do this, Natural England has produced standing advice to help understand the impact of particular developments on protected or Biodiversity Action Plan species should they be identified as an issue. The standing advice also sets out when, following receipt of survey information, you should undertake further consultation with Natural England.
Natural England Standing Advice
Local Wildlife Sites
You should consider whether your plan or proposal has any impacts on local wildlife sites, eg Site of Nature Conservation Importance (SNCI) or Local Nature Reserve (LNR) or whether opportunities exist for enhancing such sites. If it appears there could be negative impacts then you should ensure you have sufficient information to fully understand the nature of the impacts of the proposal on the local wildlife site.
Best Most Versatile Agricultural Land
Soil is a finite resource that fulfils many important functions and services (ecosystem services) for society, for example as a growing medium for food, timber and other crops, as a store for carbon and water, as a reservoir of biodiversity and as a buffer against pollution. It is therefore important that the soil resources are protected and used sustainably. Paragraph 112 of the National Planning Policy Framework states that:
'Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality'.
General mapped information on soil types is available as 'Soilscapes' on the www.magic.gov.uk and also from the LandIS website; http://www.landis.org.uk/index.cfm which contains more information about obtaining soil data.
Opportunities for enhancing the natural environment
Neighbourhood plans and proposals may provide opportunities to enhance the character and local distinctiveness of the surrounding natural and built environment, use natural resources more sustainably and bring benefits for the local community, for example through green space provision and access to and contact with nature.
Opportunities to incorporate features into new build or retro fitted buildings which are beneficial to wildlife, such as the incorporation of roosting opportunities for bats or the installation of bird nest boxes should also be considered as part of any new development proposal.
Should the proposal be amended in a way which significantly affects its impact on the natural environment then, in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, Natural England should be consulted again at consultations@naturalengland.org.uk
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Thank you for giving notice that Bagington, Bubbenhall, Stoneleigh and Ashow Parish Council has applied for designation as a Neighbourhood Area under Part 2 of the Neighbourhood Planning (General) Regulations 2012.

English Heritage has no objection to this proposal.

The proposed neighbourhood plan area contains a varied range of designated and undesignated heritage assets including five grade I listed buildings and five listed at II*. There is one very extensive grade II* Registered Park and Garden and the Parish also hosts five scheduled monuments. Due account should be taken of the conservation of all of these assets and their settings in formulating the neighbourhood plan proposals. Consideration should also be given to the protection of undesignated heritage assets and archaeological remains (both known and potential) within the Parish. Many of these will be recorded in the Warwickshire County Council Historic Environment Record (HER).

Having a sound evidence base for the Plan is important so as to form a properly supportive context for plan policies. The National Planning Policy Framework (paragraph 58) requires Neighbourhood Plans to develop robust and comprehensive policies setting out the quality of development that will be expected in an area based upon an understanding and evaluation of its' defining characteristics. The aim is to ensure that developments (inter alia) "respond to local character and history, and reflect the identity of local surroundings and materials....."

Neighbourhood Plans are a positive way to help communities care for and enjoy the historic environment. English Heritage is expecting that as Parish Council's come to you (and perhaps particularly to your specialist conservation staff) to seek advice on preparing Neighbourhood Plans they will value guidance on how best to understand what heritage they have, as well as assistance on preparing appropriate policies to secure the conservation and enhancement of this local heritage resource.

Information held by the Council and used in the preparation of your Core Strategy/Local Plan is often the starting point for Neighbourhood Plans as for example the Historic Environment Character Assessments completed by Warwickshire County Council. Comprehensive data on Heritage Assets including archaeological remains in your area will be available from the Warwickshire Historic Environment Record held by the County Council and local environmental and amenity groups often also hold useful information.

Plan preparation also offers the opportunity to harness a community's interest in the historic environment by getting them to help add to the evidence base, perhaps by creating and or reviewing a local heritage list, inputting to the preparation of conservation area appraisals and undertaking or further deepening historic characterisation studies.
English Heritage has a statutory role in the development plan process and there is a duty on either you as the Local Planning Authority or the Parish Council to consult English Heritage on any Neighbourhood Plan where our interests are considered to be affected as well as a duty to consult us on all Neighbourhood Development Orders and Community Right to Build Orders.

English Heritage will target its limited resources efficiently. We will directly advise on proposals with the potential for major change to significant, nationally important heritage assets and their settings. Our local offices may also advise communities where they wish to engage directly with us, subject to local priorities and capacity.