Guide to Objecting Against Proposed Lodge Farm Development

OBJECTION GUIDE AND SAMPLE OBJECTIONS 1STAND AGAINST LODGE FARM VILLAGE – WWW.SALFV.ORG
STAND AGAINST LODGE FARM VILLAGE (S.A.L.F.V)
Objection Guide and Sample Objections

AGENDA
• What is the Local Plan?
• What key criteria must it meet?
• What is a Sustainability Appraisal?
• The Lodge Farm Proposal Assessed
• Objections against the NPPF/SA Criteria
• Other Objections
• The objection form explained

THE LOCAL PLAN, NPPF, PCPA, SA…...?
• PCPA 2004 – Planning and Compulsory Purchases Act 2004 – governs the creation of Local Plans
• NPPF – National Planning Policy Framework – the Planning “Bible”
• NPPF – has 13 “commandments” to deliver “Sustainable Development”
• SA – Sustainability Appraisal – Required by S. 19 PCPA in the preparation of a Local Plan
• Tests evidence which underpins plan
• Demonstrates that plan is sound and sustainable
• Tests that the proposals are aligned with the objectives in the plan
PCPA 2004 NPPF SUSTAINABILITY
APPRAISAL
THE LOCAL
PLAN

WHAT CRITERIA MUST THE LOCAL PLAN MEET
The
Local
Plan
complies with
the legal
requirements
the duty to
co-operate
is ‘sound’
OK
PCPA states that the purpose of the public examination is to consider whether the Local Plan:
OK
1. POSITIVELY PREPARED
2. JUSTIFIED
3. EFFECTIVE
4. CONSISTENT WITH NATIONAL POLICY

IS THE LOCAL PLAN SOUND?
• Positively Prepared
• Based on a strategy (18 strategic aims)
• Objectively assessed development & infrastructure
• Achieves sustainable development
• Justified
• Founded on robust and credible evidence base
• Most appropriate strategy when compared to reasonable alternatives
• Alternatives must be realistic and sustainability appraised
• Effective
• Deliverable over plan period
• Able to be monitored
• Identifies who is responsible for ensuring policies and proposals are
delivered
• Flexible to deal with changing circumstances
Is the local plan Sound? (Para. 182 National Planning
Policy Framework)

IS THE LOCAL PLAN SOUND?
• Consistent with National Policy (NPPF)
• Delivers sustainable development in accordance with NPPF
• Building a strong, competitive economy
• Ensuring the vitality of town centers
• Supporting a prosperous rural economy
• Promoting sustainable transport
• Supporting high quality communications infrastructure
• Delivering a wide choice of high quality homes
• Requiring good design
• Promoting healthy communities
• Protecting Green Belt land
• Meeting the challenge of climate change, flooding and coastal change
• Conserving and enhancing the natural environment
• Conserving and enhancing the historic environment
• Facilitating the sustainable use of minerals
Is the local plan Sound? (Para. 182 National Planning Policy
Framework)

SUSTAINABILITY APPRAISAL
What is a sustainability appraisal?
Section 19 of the Planning and Compulsory Purchase Act (PCPA) 2004 requires a local planning authority
to carry out a sustainability appraisal of each of the proposals in a Local Plan during its preparation.
• It can be used to test the evidence underpinning the plan and help to demonstrate how the tests of
soundness have been met.
• RBC’s Local Plan contains 18 strategic OBJECTIVES – almost identical to the 13 NPPF criteria

SUSTAINABILITY ASSESMENT FRAMEWORK (RBC)

Sustainability Assessment Framework

OBJECTIONS AGAINST THE SCORES GIVEN TO LODGE FARM
AS PART OF THE SUSTAINABILITY ASSESSMENT

SA1: REDUCE AND ELIMINATE POVERTY
- Discourages active involvement of local people in community activities by being located away from the rest of the town, at the edge of
the Borrow in the middle of nowhere. Negative impact on SA.
- Due to the envisaged high infrastructure costs of the site, and only 840 homes delivered during the plan period, a low or no amount of
affordable housing will be delivered, initially or at all. This will have a likely negative impact on this SA.
- The low number of affordable homes will create an expensive “executive estate” located in the countryside which will only increase
disadvantage and social exclusion. Significant negative impact expected.
- It will add a further burden on rural facilities through increased traffic and access to limited school and GP spaces, and as well as
already stretched services such as policing and fire. A negative impact is expected.
- Broadband cannot be said to reduce social exclusion on it’s own.
DS10 will have an overall significant negative impact on the SA Objective 1, and should be rescored as such.

SA2: PROVIDE ACCESS TO SERVICES, LEISURE AND CULTURE
- A score of ‘++’ is considered to be too positive given that the proposed allocation would not include any provision of leisure or cultural
opportunities and although there is a policy requirement for public transport links within policy DS10, this requirement is not listed in the
Infrastructure Delivery Plan and there is no evidence that such provision would be delivered.
- No access to local services and will increase the need to travel by personal vehicle. Bus services operate 4 times per day Mon-Sat 7AM
to 3pm only, excluding Sunday and Bank Holidays. Overall negative impact on this SA.
- Land for GP surgery provision does not guarantee the operation of a GP surgery – there are no plans shown for funding to build, own
and operate. Doctors and medical staff are in short supply not land for GP surgeries. Overall negative impact on SA.
- There is no definition of the amount of commercial space proposed, nor what it will deliver hence it is premature to assess Lodge Farm
as including a “good range of services and facilities”. It is clear that on a relatively small development a “range” of services and facilities
are unfeasible from a cost perspective. An overall significant negative impact is expected.

SA3: PROMOTE HEALTH OF POPULATION
- Site will contribute with additional traffic to the Dunchruch intersection, already designated a AQMA, by promoting reliance on own
vehicle as a means of transport to access local amenities, such as a GP surgery, supermarket (Sainsbury’s), post office and
employment opportunities;
- Site is not within walking distance nor does it deliver access by public transport to any healthcare facilities;
- Healthcare centre or GP facilities are proposed but not defined, nor is there any definition of deliverability and funding for such a centre.

SA4: PROVIDE AFFORDABLE AND DECENT HOUSING
- Site will not provide adequate supply of affordable housing in it’s initial stages, and within the local plan period because high
infrastructure development costs associated with building on a remote greenfield site will make it difficult for developers to recover
infrastructure investments early to have a positive business case. A negative impact is expected on this SA.
- No affordable housing provision by plan stage is available in the consultation documentation provided.
(This was admitted by Rob Back during one of the consultation meetings and is available as a recording)
- Site will not reduce homelessness due to it’s remote nature, which will make it unsuitable for council housing for families without a car.
- The low number of deliverable affordable homes will create an expensive “executive estate” located in the countryside, catered for
commuters from London, Coventry, North Rugby, etc.
DS10 will have an overall minor negative impact on the SA Objective 4, and should be rescored as such.

SA6: PROVIDE A STRONG STABLE LOCAL ECONOMY
- Very limited employment opportunities exist in the area, and none within walking distance;
- Bus services operate 4 times a day, Mon-Sat 7AM to 3pm only, excluding Sunday and Bank Holidays;
- No other public transport infrastructure provision can be seen in the local plan, and no evidence exists that such infrastructure would be
delivered;
- Very little employment land is allocated at the site;
- Due to traffic difficulties in accessing Rugby Town Centre through Dunchurch, Rugby Town will loose out in valuable trade and
commerce as residents will likely choose the outskirts of Coventry accessed via the A45 dual carriageway or Daventry for shopping and
other economic activities.

SA7: PROMOTE VITALITY AND VIABILITY OF TOWN CENTER
- Due to traffic difficulties in accessing Rugby Town Center through Dunchurch, Rugby Town will loose out in valuable trade and
commerce as residents will likely choose the outskirts of Coventry accessed via the A45 dual carriageway or Daventry for shopping and
other economic activities.
DS10 will have an overall minor negative impact on the SA Objective 7, and should be rescored as such.

SA8: PROMOTE REGENERATION OF URBAN AREAS
- Objective 8 is scored as a ‘-‘ and it is considered that this should be ‘- -‘ as the proposed allocation will not support the regeneration of
urban areas due to its greenfield location that is isolated from existing urban areas.
- Site will not provide adequate supply of affordable housing in it’s initial stages, and within the local plan period because high
infrastructure development costs associated with building on a remote greenfield site will make it difficult for developers to recover
infrastructure investments early to have a positive business case. A negative impact is expected on this SA

SA9: USE AND MANAGE ECO RESOURCES PRUDENTLY
- The council has not provided enough information to determine the impact on sustainability under this category. There is no
environmental impact assessment, the quality of the agricultural land is not known with any certainty.
- No phase 1 ecology assessment is present;
- No landscape assessment is present;
- No agricultural classification report is present;
- Energy efficiency measures are not discussed in the plan in any detail and are unknown;
- Sustainable energy production is not encouraged and no evidence is provided in this sense;
- The site’s location in the remote open countryside will lead to an increase in consumption of materials and resources;
DS10’s impact on SA Objective 9 is largely unknown at this stage therefore consultation is impossible at this stage. The only reasonable
score is an overall significant negative impact on SA Objective 9, and should be rescored as such.

SA11: REDUCE THE BOROUGH'S CONTRIBUTION TO CLIMATE CHANGE
- No access to local services or employment opportunities will increase the need to travel by personal vehicle. Bus services operate Mon-
Sat 7AM to 3pm only, excluding Sunday and Bank Holidays and thus do not provide a reliable public transport opportunity.
- Cycle network discussed in the plan refers to a cycle network within the village and does not link to surrounding towns and villages, and
no evidence exists such a network will be delivered within the local plan.
- Community services and facilities are limited, and no details exist as to what such services could be delivered for 800 houses during the
plan period. The assertion that this development could operate as a self contained Main Rural Settlement within the plan period is
downright false.
DS10 will therefore have a significant negative impact on SA11 and should be scored as such.

SA12: AVOID, REDUCE AND MANAGE FLOOD RISK
- Conversion of greenfield land to concrete surface will increase water collection, reduce permeability and infiltration in a zone prone to
flooding by the Rainsbrook and Leam Rivers as happens regularly on the A45, in Willoughby, Grandborough and surrounding villages;
- The requirement for deployment of SuDS will reduce the available space for housing on the site;
- The collected water will need to be transported to the Rainsbrook which will cause a backup into the Leam River and thus promote
flooding upstream, in neighboring lands and villages;
- No coherent flood impact assessment or mitigating plans have been presented by the Council and full implications are presently
unknown, especially with reference to impact on neighboring localities.
DS10 will therefore have a significant negative impact on SA12 and should be scored as such.

SA13: CONSERVE AND ENHANCE HISTORIC ENVIRONMENT
- The council’s RAG assessment of sites should not be used in an evidence based sustainability assessment, without any detailed
evidence on heritage or archeological assets;
- A “modern village” as described by the policy will be incongruent with existing historical villages and their settings;
- The village will be substantially larger than existing settlements negatively impacting their surroundings and detracting from the
distinctiveness of villages such as Willoughby, Woolscott, Grandborough, Onley which it will border.
- It will remove and permanently destroy a number of existing farmsteads in the area.
- The site is remote with no relationship to the Rugby or Coventry main urban areas.
- In terms of landscape character, due to the flat nature of the site the proposed development would result in a major impact on the open
character of the area. The development would be unable to mitigate the impacts within the short to medium term.
- The site has no previous use or merit to set it apart from other locations.
Whilst properly evidenced assessments do not exist it is impossible to consult on the sustainability impact on Objective 13 at this stage,
therefore it has to be assumed that a significant negative impact can be derived on SA 13.

SA14: PROMOTE A SUSTAINABLE TRANSPORT NETWORK
- The score is ‘++’ however given the limited nature of the strategic transport assessment it is not clear what impact the proposed
allocation would have on all surrounding roads and therefore the proposed allocation may not promote a sustainable and accessible
transport network.
- “High quality public transport links” are not detailed anywhere in the Council’s plans, and there is no evidence such transport links will
be delivered. Two bus stops do not constitute a “sustainable and accessible transport network.”
- No access to local services and employment opportunities within walking distance will increase the need to travel by personal vehicle.
Bus services operate Mon-Sat 7AM to 3pm only, excluding Sunday and Bank Holidays.
- The limited strategic transport assessment has already shown an increase in traffic and congestion at the Dunchurch crossroads. This
will not be mitigated by the Spine Road provision because traffic headed into Rugby to access the Post Office, Sainsbury’s, secondary
schooling, or traffic making a left turn toward Southam will not benefit from the spine road.
- The A45 is already a designated “High Crash” route without the additional traffic entering and exiting Lodge Farm.
- Access points into Lodge Farm have not yet been determined, presented into this consultation or agreed with the Local Highway
Authority.
DS10 will have a likely significant negative effect on the transport SA Objective 14.

SA15: REDUCE ALL FORMS OF POLLUTION
- Whilst the assessment correctly identifies the increased air pollution due to the reliance on personal transport to access the site, and
the already unacceptable levels of pollution (AQMA) at the Dunchurch crossroads, the assessment does not describe what sustainable
transport improvements consist of to reduce the “detrimental impacts on local air quality.”
Whilst no plan has been published to reduce pollution through sustainable transport and no evidence exists of it’s deliverability, DS10 will
have a likely significant negative effect on the transport SA Objective 15 and should be rescored as such.

SA16: CONSERVE AND ENHANCE BIODIVERSITY FLORA AND FAUNA
- As outlined in the SA for Objective 16 the overall impact on biodiversity and local wildlife sites is unknown because an environmental
impact assessment has not been carried out, without which it is impossible to guess the true impact of this development.
- No positive impact can be seen from placing a modern village in open green spaces, in particular:
- Will not lead to habitat creation;
- Will not conserve or enhance species diversity.
- Tim Marlow MCIEEM, a respected Ecological Consultant has already objected to this plan on the grounds that:
- “site falls within an area which is significant at county level for the populations of declining farmland birds it supports”
- “Surveys of six farms in Warwickshire undertaken by the author on behalf of Natural England have shown both the breeding and
wintering densities of the former 19 PSA species associated with arable farmland at Toft Farm to be some of the highest in the
county.”
- Critically the site lies at a strategic point where the Dunsmore and Felden NCA connects to the Northamptonshire Uplands NCA
and the Leicstershire Vales NCA. These NCA’s have been identified by Natural England as priority target areas for the
establishment of Countryside Stewardship Agreements. Farmland bird populations in these NCA’s would be isolated from
each other by the proposed development which would act as a dispersal barrier.
Whilst the evidence base does not include a detailed ecological impact assessment, Tim Marlow’s objection shows a net significant
negative impact on Objective 16, and it should be scored accordingly.

OTHER OBJECTIONS

OBJECTIONS OTHER THAN REGARDING SUSTAINABILITY SCORING
1. Meeting Coventry’s Housing Need
• RBC has committed in a MOU to deliver 2800 homes within the plan period to meet Coventry’s housing need;
• Removing the Walsgrave site and introducing Lodge Farm as a direct replacement, delivering 825 homes within the plan period, 15 miles
away from Coventry, and on the South Side of Rugby means the Borough will fail in it’s obligations under the MOU;
• In a recent example Warwick District Council submitted their Local Plan to examination, failing to directly deal with their obligation to
provide for Coventry’s overspill. As a result the examination was paused and the plan sent back to Warwick Council, causing at least 1
year delay in the adoption of the plan. As a direct result Warwick allocated green belt sites near Coventry at King’s Hill and Westwood
Heath.
The local plan is unsound as it does not directly deal with the Council’s obligations under the MOU with Coventry, unless it re-allocates the
Walsgrave site and removes Lodge Farm.
2. Sustainability Appraisal
The NPPF requires the evidence base and sustainability assessment of the sites to be available as part of the Council’s decision making
process. Lodge Farm was substituted for Walsgrave in the beginning part of 2016, when at the time no sustainability appraisal was available.
Surely delivering a sustainability appraisal, after making the decision to include Lodge Farm as a preferred option, begs the question as to
whether the evidence was made to fit the decision, especially when so much of the evidence base is missing. (lack of information on ecology,
Lack of evidence on highways deliverability – no conclusive transport assessment, No phase 1 ecology assessment, No utilities assessment
e.g. sewer capacity/treatment, No landscape assessment, No detail on heritage or archaeology information, No site investigation information,
No agricultural land classification report, no flood risk assessment, lack of evolved master plan/development framework)

3. A Significant increase in housing to the south of Rugby:
• Rugby Council are proposing 12,700 homes to the south west or south east of the town – can this sub-housing market area cope with this
significant level of housing over the next 20 years?
• Housing numbers in the Plan increasing from 558 in 2017-18 to 1,314 & 1,122 in 2020-21 & 2021-22 respectively. All reliant on the SW
Rugby SUE coming forward. The Housing Background Paper calls this target ‘aspirational’.
• If these homes aren’t delivered the Borough will not have a 5 year supply of housing within at least the first 5 years of the Plan.
4. The sustainability & suitability of Lodge Farm:
• Fundamentally it is in an unsustainable location where travel will be predominantly by private car with very little public transport use.
Contrary to the principles of a ‘garden village’.
• The site is remote with no relationship to the Rugby or Coventry main urban areas.
• In terms of landscape character, due to the flat nature of the site the proposed development would result in a major impact on the open
character of the area. The development would be unable to mitigate the impacts within the short to medium term.
• The site has no previous use or merit to set it apart from other locations.
• The site lacks definition, and would be open to infill and expansion. By contrast the Walsgrave site is well defined with Coventry on one
side and the Ansty site to the other acting as a strong urbanising feature. At the south the site is bordered by Coombe Abbey preventing
further spill into the green belt.

5. Lack of local support
• The site is located in the Parish of Grandborough;
• Grandborough Parish Council conducted a survey in relation to it’s neighborhood plan, where 87% of the respondent households were
against the proposal.

HOW TO OBJECT
• Online at: https://www.rugby.gov.uk/forms/form/239/local_plan_-_publication_draft_consultation
• On paper or via a typed consultation form.
Question 3: Policy Nr. DS10
Question 4: Tick “No”
for Legally compliant and Sound
Question 5: Tick all 4 boxes
Question 6: Insert your objection
Question 7:
Remove Lodge Farm policy DS10
from the Local Plan.
Question 8:
Choose if you would like to participate
In at the examination of the plan.
Sign, date and choose to be kept
informed.

Guide to Objecting Against Proposed Lodge Farm Development

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Guide to Objecting Against Proposed Lodge Farm Development