Warwick District Council objects to the following paragraphs and policies in the Baginton and Bubbenhall Neighbourhood Plan.
Housing
Para 2.8 'Both Parish Councils support full retention of the green belt between Coventry and Baginton, to maintain the openness of the green belt and protect the community against the urban sprawl of Coventry into rural Warwickshire'.
The emerging Local Plan takes the village out of the green belt and also the large tract of land allocated for a sub-regional employment site. At this advanced stage of the Local Plan when we await the full Inspector's report, we have already had indicated to us that the Inspector does not intend to modify the Plan away from these proposals. It is therefore not compliant to say that the Green Belt must be retained and to leave this paragraph in as written will only serve to make the Neighbourhood Plan obsolete when the Local Plan is adopted within the next few months. The qualifying body is aware of the Council's view on this as it has been advised at previous stages of consultation and at a recent meeting to discuss the progress to examination.
para 2.9 '(There is some uncertainty about the future of the site following a recent appeal decision which was called in by the Secretary of State and dismissed for reasons including that the proposal would prejudice the outcome of the Local Plan and that the proposal would have an adverse impact on the openness of the green belt.)'.
This is not the case as we have the Local Plan Inspector's 'main modifications' which do not include removing the allocation of the employment site or it's removal from the green belt. The Secretary of State's decision on the application for the sub-regional employment site was based on his belief that the allocation is rightfully an issue to be addressed through the Local Plan. This has now been considered and the Inspector has accepted that this site is suitable for allocation. There is therefore no uncertainty.
para 2.10 ' However, the Parish Councils continue to support the view that the land south of Coventry is not developed to maintain the openness and effectiveness of the Green Belt and protect against urban sprawl in accordance with the NPPF.'
This is not an issue for this document. The planning system has already considered and approved the application from Jaguar Land Rover and any objections made have been taken into consideration, but not upheld, therefore this is no longer an issue. The Neighbourhood Plan is not a place to go over old planning decisions to which the parish council and qualifying body, objected. Continued objections to the removal of land in the Green Belt or allocations for development in the Green Belt, simply places the Neighbourhood Plan at odds with the emerging Local Plan and as the two documents should work together with the Neighbourhood Plan being in conformity with the Local Plan, this shows a disregard for the status and content of the Local Plan which a Neighbourhood Plan has no place in doing. Such references should be removed.
para 2.15 As above. These comments have no place in the Neighbourhood Plan. The issues, including those of the quality of the Green Belt and the impact of additional traffic, were discussed at length during the Local Plan Examination - the correct vehicle for such discussions. These comments are no longer applicable and can only serve to damage the quality and integrity of the Neighbourhood Plan showing a distinct lack of respect for the Local Plan Inspector's decisions and rejection of the Plan on which the Neighbourhood Plan should be founded.
Objective 3. 'Specifically, the Gateway proposal has been rejected by the Secretary of State and is now subject to the outcome of the Local Pan examination.'
This is no longer the case since the Local Plan Inspector has retained this allocation.
Objective 7. Deliberate omission of reference to the new sub-regional employment site does not mean that it will not be supported presumably? It is not the job of the Neighbourhood Plan to exclude development and allocations in the Local Plan.
Policy G5. This policy directly impacts on the sub-regional employment site since it cannot meet all of the policy criteria. This looks like a deliberate attempt to foil this major employment allocation and cannot be accepted as currently written.
Baginton
para. 5.20 ' These proposals are not accepted by Baginton Parish Council, who prefer the H19 allocation to be for no more than 35 houses as originally proposed. Land would have to be removed from the green belt at these locations to support this new development. Baginton village is currently washed over by the green belt and the remainder of the green belt should be retained.'
The qualifying body has been advised on a number of occasions that this is not an area for further discussion within the Neighbourhood Plan. The housing allocation and changes to the Green Belt were discussed during the Local Plan examination and were considered and accepted by the Local Plan Inspector.
Comments such as this have no place in the Neighbourhood Plan which should be in compliance with and supportive of the Local Plan. Neighbourhood Plans are not meant to be documents which prevent development. The Government has always been very clear on this. The paragraph should be removed.
Policy BAG1 (4). This is a matter for a planning application and restricting the development to roadside only would have the effect of reducing numbers below the designated number required for the village. To reduce this number would have an impact on the overall total number of houses to be provided and reduce the 5 year housing supply, neither of which the Council would or could support. This criteria should be removed.
para. 3.32 and Map 5. Some of these views (1 and 2) are over land which comprises the sub-regional employment site allocation. Whilst they may be 'key' they clearly cannot be 'maintained' as they are currently. The SoS agreed that there would be a 'moderate adverse effect on landscapes and visual amenity' in paragraph 16 of his decision letter regarding the sub-regional employment site, however, his decision was to leave consideration of these issues to the Local Plan examination. This has now taken place and the Inspector has included the sub-regional employment site within the allocations, which is the 'correct process for changing green belt boundaries'. These key views are therefore going to suffer the effect envisaged by the SoS in his previous report and protecting them in the Neighbourhood Plan is not an option as it deliberately flies in the face of the allocation.
para. 5.40 Does this include land within the sub-regional employment site area? If so, then it shouldn't and this reference should be removed.
BAG 7 Employment
There is no reference here to mitigation. Development, such as the sub-regional employment site is bound to impact on those features mentioned in the policy, it is therefore recommended that reference is made to mitigating harmful impacts to ameliorate that situation. It is the Neighbourhood Plan's opportunity to have a say in how the impacts can be reduced for the benefit of residents, visitors and users of the new employment site.
Summary
The qualifying body have been advised on a number of occasions, including in a recent meeting, that negativity and constant references to matters applicable to the Local Plan process rather than the Neighbourhood Plan, should not be included and should be removed before submission. Previous experience with other Neighbourhood Plans in the area demonstrating similar characteristics have shown both policies and text struck out at examination. Even if the Neighbourhood Plan were to negotiate its path through an examination unscathed, it would become out of date immediately on adoption of the Local Plan, which is due to take place within the next few months. This would be a waste of local people's time and effort and result in at least a partial review of the Neighbourhood Plan.
Neighbourhood Plans should be a suitable vehicle by which the local community can shape development that is happening in their area; it is not a means by which development can be halted or rejected. The Government has made quite clear that this is not the function of a Neighbourhood Plan. It is rather a way of supporting and positively influencing development which is taking place and in the best examples, suggesting additional development in their area.

Thank you for consulting HS2 Ltd on your Neighbourhood Plan.
We have reviewed the document and have no comments to make on the Policies proposed.

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