Too many houses are being planned. This 'consultation process' is so byzantine and bureaucratic that local people's opinions will not hold sway. NOBODY wants so many houses built. Stop approving them, and ruining our wonderful rural market town. Do your job, and protect our town.

Barford Neighbourhood Plan - Submission Version
Comments of Warwick District Council

Policy B1 - Future Housing Development
It is considered that the policy requirement for housing development within the settlement boundary to meet all of the identified criteria is too restrictive and that some of the criteria/ bullet points identified are unnecessary and/or inconsistent with the emerging Local Plan/ National Planning Policy.

Bullet point 1
The preferred sites as defined by Plan Policy B1 (Map 5.7) omit reference to the land currently identified for allocation in the Publication Draft Local Plan south of Barford House (H20 for 8 dwellings) and therefore is not in conformity with the Local Plan.
Paragraph 5.7 refers to the County Car site that has been granted permission for residential development however this should be treated as a 'windfall' and not an alternative to the land south of Barford House which, in the District Council's opinion remains suitable and available for development and as an appropriate allocation in the Local Plan.

The site North of Westham Lane may benefit from being labelled as a site currently under construction as the implementation of a planning approval for 60 dwellings is currently underway.

The smaller parcel of land shown south of Westham Lane currently has Outline Planning permission for 8 dwellings and has already been taken into consideration in the context of the overall Local Plan housing numbers as a 'site with permission'.

The policy would benefit from an additional statement / bullet stating that whilst the identified / allocated sites should deliver the majority of all new housing developments for Barford over the plan period, other windfall proposals may be considered acceptable subject to other policies of the Neighbourhood Plan and Local Plan / National Guidance.

Bullet Point 2
This is considered overly restrictive. The numbers of houses for Barford as identified in the Local Plan amount to a rudimentary assessment of the potential capacity of the land parcels identified as being suitable for development. These are not prescribed 'target figures'. Ultimately the number of houses coming forward will be dictated by the precise environmental capacity of each area and the layout and design solutions that are presented within detailed planning applications.
Therefore the overall housing numbers presented in the Local Plan should not be treated as a target/ ceiling figure , but as guidance as to what numbers are likely to come forward/ form part of the Districts overall supply. It is therefore not appropriate for the Neighbourhood Plan to curtail any additional development beyond this figure provided that any additional developments are environmentally acceptable / accord with Local Plan / Neighbourhood Plan policies.

Bullet Point 3
Good planning should (wherever possible) defend locally valuable open spaces and facilities from alternative development. There should however be an acceptance that in some instances (in line with the National / Local Plan policy) development can occur at such locations provided that certain relevant tests/ requirements have been satisfied.
It is considered that bullet point three is therefore unnecessary.



Bullet Points 4 and 5
Appropriate access and parking provision are a necessary/ fundamental requirement of all development, therefore these bullets are considered unnecessary.

Other
Residential development beyond the confines of the Village Settlement boundary may occur other than for the purpose of providing for rural workers/ replacement dwellings (as stated in the policy). It may be allowed provided that it is in accordance with policies H3 (Affordable Housing on Rural Exception Sites), H12 (Housing for Rural Workers), H13 (Replacement Dwellings in the Countryside, H14 (Extensions to dwellings in the countryside) and policy BE4 (Converting Rural Buildings) of the Local Plan (2011-2029).

Policy B2 - Ensuring an appropriate range of tenures, types and sizes of future housing and meeting local housing need.
Seeks to emphasise the importance of delivering the right mix of housing and broadly reflects the thrust Local Plan policy regarding housing mix and reflecting local demand (Local Plan policy H4).

Policy B3- Ensuring the provision of accommodation and / or facilities to enable the elderly, infirm or disabled
Offers support for the provision of homes for older people. It is arguable that a policy is not required and this matter might be better presented as a sub-section of policy B2?

Policy B4 - Supporting existing local employment
Policy B4 appears to focus on supporting (by protection) existing employment opportunities/ sources of local employment. It may be more relevant to re-title this' policy protecting local shops, services and employment uses within Barford' as this embraces the wider range of uses referred to in the text that supports the policy (other than ' pure 'employment B1, B2, and B8 as prescribed in the Local Plan).
It could be argued that the requirements of this policy are adequately covered by Local Plan policy EC3 (Protecting Existing Employment Land and Buildings), TC17 (Local Shopping Facilities), TC18 (Farm Shops) and HS8 (Protecting Community Facilities).

Policy B5- New local employment opportunities
Offers support/ encouragement for new employment development with caveats, arguably offers no more than Local Plan policy. This policy only refers to new employment opportunities within the 'settlement boundary'. It is also considered necessary/ relevant to mention employment opportunities that could occur within the Neighbourhood Plan area within the rural context e.g. farm diversification etc. in accordance with Local Plan policy EC2 (Farm Diversification).

Policy B6 - Heritage Assets
This policy further emphasises the importance of Local Plan policy regarding the treatment of Listed Buildings and new/ future development in Conservation areas. It introduces the need for the consideration of locally identified important views (set out in the Plan).

Policy B7- General Design Principles
Sets general design principles and specifies the need to refer to the Village Design Statement as a necessary reference in development management decision making process within the Village Settlement Boundary. Introduces concept of identified views that are worthy of retention/ protection.

Policy B8- Biodiversity and Landscape Design Principles
This policy may benefit by being re-titled 'Protecting and enhancing environmental assets', this may better fit the extensive range of issues raised for consideration within the policy.

Policy B9- Agricultural Land
As currently set out Policy B9 would appear to curtail any future development outside the settlement boundary. It would not appear to be in accordance with the Local Plan policy NE5 (Protection of Natural Resources) that balances the need to preserve agricultural land/ quality with other compelling reasons for development.
Note the section on trees and woodlands might be better located within a section of the NDP setting out policies regarding the natural environment (biodiversity/ landscape and open spaces).

Policy B10 - Protection and enhancement of Local Green Spaces
This policy identifies important open spaces areas of nature conservation value and aims to protect them from development wherever possible.
Arguably, assets A6 and B5 and some of the farmland parcels identified in C6 (being agricultural land) are a little too broad/ vague to fit comfortably into this policy.

Policy B11- Traffic Management
Albeit traffic management is a locally important issue policy B11 appears to do little more than replicate Local Plan policy and therefore it may not be necessary/ required.

Policy B12- Transport Improvements
All planning applications for residential development are subjected to assessment / comment from Warwickshire County Council highways officers. Issues that may require mitigation are identified and specific improvements may require financial contributions to improve traffic related matters (e.g. highway improvements / cycleway provision or public transport matters). The policy appears a little confused as it appears to be asking for developer contributions to a range of issues other than just highway related matters (broadband and community facilities being the last two bullet points).

Policy B13- Parking
This policy appears to be at odds with the District Council's current parking SPD (Vehicle Parking Standards Nov' 2007). It could only be considered if appropriately 'evidenced'/ researched.

Policy B14 - New Communications Technologies
Considered to replicate Local Plan policy BE5 (Broadband Infrastructure)

Policy B15- Provision, retention and enhancement of community facilities
This policy is proactive in supporting the enhancement of and/or the provision of additional community facilities within Barford.

Policy B16 - Allotments and Community gardens
This policy appears to be broadly in line with National / Local Plan policy.

re: BARFORD NEIGHBOURHOOD PLAN - PUBLICATION DRAFT

Thank you for the invitation to comment on the draft Neighbourhood Plan. We are disappointed to note that our comments on an earlier draft (letter dated 13 November 2014) do not seem to have been taken into account.

Beyond those earlier observations, which we strongly recommend are acted upon before the draft is formally adopted, we have no substantive comments to make on the draft plan.


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re: BARFORD NEIGHBOURHOOD PLAN - PUBLICATION DRAFT

Thank you for the invitation to comment on the draft Neighbourhood Plan. We are disappointed to note that our comments on an earlier draft (letter dated 13 November 2014) do not seem to have been taken into account.

Beyond those earlier observations, which we strongly recommend are acted upon before the draft is formally adopted, we have no substantive comments to make on the draft plan.

Thank you for your consultation on the above document which was received by Natural England on 09 March 2015.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Natural England generally welcomes the Neighbourhood Plan and considers that it provides a useful framework for achieving the sustainable development of.
We have reviewed the Plan (submission publication) and we are pleased to note that our comments on the draft document have been taken on board. Natural England consider that our interest in the natural environment is well covered within the Plan. We particularly support the policies encouraging; protection and enhancement of biodiversity - including local biodiversity action plan (BAP) and landscape, protection of the best and most versatile (BMV) agricultural land, retaining woodland and trees, protection and enhancement of local green spaces and provision of community spaces such as allotments, gardens and playing fields for children. We also support encouraging people to use more sustainable methods of transport and having access to enjoy countryside and green spaces by walking and cycling.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

Having reviewed the consultation version of the Barford Neighbourhood Development Plan I have the following comments.

I am broadly supportive of the document however:

At para 5.53 the document talks about Area 8 (Barford House Land) as an important wood / spinney or " Green Corridor". The area is undoubtedly free from development but I believe its importance and environmental significance has been over egged and its inclusion here is misleading. It is not a woodland, nor a spiny, but an enclosed area of pasture. There is no clear evidence base that makes this piece of open land stand out in comparison to any others in and around the village.

Under Policy B10 land around Barford House is included as worthy of protection as a "Local Green Space". No evidence is presented as to why this might be the case. Parts of the area may have a role in providing the setting to a listed building but the area is visually enclosed and is not accessible to the public. The inclusion of this land in this policy is unsubstantiated and may be seen to be inconsistent.

The Plan does not put forward a clear rationale or position about development of land to the west between the existing settlement edge and the bypass. There are clearly development opportunities here, however there is an argument for some restraint to avoid the creation of a "wall" of development along the bypass. There is an argument for the creation of a staggered or feathered edge along the bypass avoiding wholesale development of the infill area. Whilst implicit in the land allocations in the Neighbourhood Development Plan, this principle has not been articulated. IT would be helpful if it was.

In the "Main Issues" section under the heading "Traffic", there is a suggestion that removal of a grass strip along Wasperton Lane to provide parking would be a good idea. This is a proposal I have heard mentioned by the Parish Council. Such a scheme would have a dramatic urbanising effect on what is a pleasant street and junction with Wellesbourne Road. A further unintended adverse effect of such a scheme would be to remove the natural traffic calming provided by the on-street parking. I suggest that this proposal would cause significant harm to the character of this part of the village and would deliver very little benefit.

CONSULTATION ON NEIGHBOURHOOD PLANS - REPRESENTATIONS BY HSE
BARFORD AND WHITNASH NEIGHBOURHOOD PLAN
Thank you for your request to provide a representation on the Barford and Whitnash
Neighbourhood Plan consultation document. When consulted on land-use planning matters,
the HSE where possible will make representations to ensure that compatible development
within the consultation zones of major hazard installations and major accident hazard
pipelines (MAHPs) is achieved. HSE acknowledges that early consultation can be an effective
way of alleviating problems due to incompatible development at the later stages of the
planning process.
HSE gives advice on neighbourhood plans with reference to the condition that neighbourhood
plans or Orders must be in general conformity with the strategic policies of the Local Plan, and
that neighbourhood plans or Orders must be compatible with European Union obligations, as
incorporated into UK law, in order to be legally compliant (Planning Practice Guidance -
Neighbourhood Planning - Para 065). Our advice therefore is given with consideration to the
following.
1. Paragraph 172 of the National Planning Policy Framework (NPPF) requires that
planning policies should be based on up to date information on the location of major
accident hazards and on the mitigation of the consequences of major accidents.
2. Regulation 10(b) of the town and Country Planning (Local
Planning)(England)Regulations 2012 requires that in local plans and supplementary
planning documents, regard be had for the objectives of preventing major accidents
and limiting the consequences of such accidents by pursuing those objectives through
the controls described in Article 12 of Council Directive 96/82/EC(Seveso II)1.
2
Regulation 10(c)(i) requires that regard also be had to the need in the long term, to
maintain appropriate distances between installations and residential areas, buildings
and areas of public use, major transport routes as far as possible and recreational
areas.
Scope of Advice
At this early stage HSE can give a general opinion regarding development compatibility
based only on the outline information contained in the plan. This opinion takes no account
of any intention to modify, relinquish or revoke hazardous substances consents2. Planning
authorities are advised to use HSE's Planning Advice for Developments near Hazardous
Installations Information Package (PADHI+) to verify any advice given. Further information
on PADHI+ is available on the HSE website:
http://www.hse.gov.uk/landuseplanning/padhi.htm
PADHI+ cannot be used for developments around nuclear sites, explosive sites or quarries.
In these cases you must consult the appropriate HSE directorate for advice. Guidance on
consulting the HSE about developments that could encroach on specialist major hazard sites
is also available on the website:
http://www.hse.gov.uk/landuseplanning/padhi/faqs.htm#hazardous-substances-consent.
Encroachment of Plan Boundaries and Consultation Zones
The following consultation zones are within the proposed neighbourhood plan boundary.
i) The neighbourhood plan boundary encroaches upon the inner, middle and outer
consultation zone associated with a MAHP operated by National grid Gas Plc 14"
feeder Churchover/Wormington HSE Reference 7183 National Grid Reference 1453
Compatibility of Development with Consultation Zones
The compatibility issues raised by developing housing and workplaces within the inner middle and
outer zones are summarised below.
Housing Allocations
Inner Zone - Housing is not compatible with development in the inner zone. PADHI+ would
normally give an Advise Against decision for such development. The only exception is
developments of 1 or 2 dwelling units where there is a minimal increase in people at risk.
Middle Zone - The middle zone is compatible with housing developments up to and including 30
dwelling units and at a density of no more than 40 per hectare.
Outer Zone - Housing is compatible with development in the outer zone including larger
developments of more than 30 dwelling units and high-density developments of more than 40
dwelling units per hectare.
Workplace Allocations
Inner Zone - Workplaces (predominantly non-retail) providing for less than 100 occupants in each
building and less than 3 occupied storeys are compatible with the inner zone. Retail developments
with less than 250 m2 total floor space are compatible with the inner zone.
3
Note Workplaces (predominantly non-retail) providing for 100 or more occupants in any building or
3 or more occupied storeys in height are compatible with the inner zone where the development is
at the major hazard site itself and will be under the control of the site operator.
Middle Zone - The middle zone is compatible with workplaces (predominantly non-retail). Retail
developments with total floor space up to 5000 m2 are compatible with the middle zone.
Outer Zone - Workplaces (predominantly non-retail) are compatible with the outer zone.
Workplaces (predominantly non-retail) specifically for people with disabilities (eg sheltered
workshops) are only compatible with the outer zone. Retail developments with more than 5000 m2
total floor space are compatible with the outer zone.
This is a general description of the compatibility for housing and workplaces. Detail of other
development types for example institutional accommodation and education and their compatibility
with consultation zones can be found in the section on Development Type tables (page 9) of
PADHI - HSEs Land Use Planning Methodology, which is available at :
http://www.hse.gov.uk/landuseplanning/padhi.pdf
Mixed use Allocations
Because of the potential complexity when combination use classes are proposed, advice regarding
mixed-use allocations is outside the scope of the general advice that can be given in this
representation. Please refer to PADHI+ to determine HSEs advice regarding mixed-use
developments.
Verification of Advice using PADHI+
The potential for encroachment is being brought to your attention at an early stage so that
you can assess the actual extent of any incompatibility on future developments.
Information on the location and extent of the consultation zones associated with major
hazard installations and MAHPs can be found on the HSE extranet system along with
advice on HSEs land-use planning policy. Lists of all major hazard installations and
MAHPs, consultation zone maps for installations, and consultation distances for MAHPs
are included to aid planners. All planning authorities should have an authorised
administrator who can access the HSE Planning Advice for Developments near
Hazardous Installations Information Package (PADHI+) on the extranet, further information
is available on the HSE website: http://www.hse.gov.uk/landuseplanning/padhi/htm. When
sufficient information on the location and use class of sites comes available at the preplanning
stages of the neighbourhood plan, the use of PADHI+ could assist you in making
informed planning decisions about development compatibility. We recommend that for
speculative testing of advice that the PADHI+ training database is used. This is accessed
on the land-use planning extranet services screen.
Identifying Consultation Zones in Neighbourhood Plans
The HSE recommends that where there are major hazard installations and MAHPs within
the area of the neighbourhood plan, that you mark the associated consultation zones on a
map. This is an effective way to identify the development proposals that could encroach
on consultation zones and the extent of any encroachment that could occur. The proposal
maps in site allocation development planning documents may be suitable for presenting
this information. We particularly recommend marking the zones associated with any
MAHPs and the HSE advises that you contact the pipeline operator for up to date
information on pipeline location, as pipelines can be diverted by operators from notified
routes. Most incidents involving damage to buried pipelines occur because third parties
are not aware of their presence3.
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Identifying Compatible Development in Neighbourhood Plans
The guidance in PADHI - HSEs Land Use Planning Methodology available at
http://www.hse.gov.uk/landuseplanning/padhi.pdf will allow you to identify compatible
development within any consultation zone in the area of the neighbourhood plan. The
HSE recommends that you include in the plan an analysis of compatible development type
within the consultation zones of major hazard installations and MAHPs based on the
general advice contained in the PADHI guidance. The sections on Development Type
Tables (page 9) and the Decision Matrix (page 17) are particularly relevant and contain
sufficient information to provide a general assessment of compatible development by class
within the zones.
There are a number of factors that can alter a PADHI+ decision, for example where a
development straddles 2 zones. These factors are outside the scope of the general
advice in this letter. HSEs final advice on development compatibility can only be
determined through use of PADHI+
Provision of Information to Interested Parties - Pipeline Operators
The pipeline operator/s referred to will be send a copy of this representation to make them
aware of HSE's preliminary advice on this matter.
If you have any questions about the content of this letter, please contact me at the address
given in the letterhead.

Thank you for giving the Highways Agency the opportunity to comment on the above referenced documentation.
The Highways Agency is responsible for the operation and maintenance of the strategic road network in England, which includes all motorways and major trunk roads.
We have reviewed your documents and feel that the policies contained therein are an appropriate approach to ensuring the necessary planned development growth within Barford. In view of this the Highways Agency is content with your Policies in so far as they might affect the operation of the strategic road network. The Agency therefore supports the proposals without further comment.
Please feel free to contact me if you wish to discuss this response in more detail.

I refer to the consultation for the Barford and Whitnash Neighbourhood Plans.
The County Council is one of the major infrastructure providers for the Warwickshire, providing and managing many important services that communities use and rely upon. We are supportive of neighbourhood planning as a way for local communities to have a greater say in where they live and work.
We will provide specific advice for particular developments as they evolve. I attach the County Council highways comments and draft Public Health checklist as useful guidelines for the Neighbourhood Plans.