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HSG8 Concept Plan Supplementary Planning

Document (SPD)Consultation Statement

April 2020

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HSG8 Concept Plan Supplementary Planning Document (SPD) Consultation Statement

1. Introduction

1.1 This statement is the ‘Consultation Statement’ for the HSG8 Concept Plan

SPD as required by the Town and Country Planning (Local Planning)

(England) Regulations 2012 (as amended). This statement sets out how the

public and other stakeholders were consulted on the SPD, key issues raised

by stakeholders in relation to the SPD and the Council’s responses to those

issues.

2. Background

2.1 The HSG8 Concept Plan SPD provides supplementary guidance to Borough

Plan Policy HSG8 – West of Bulkington. Paragraph 7.6 of the adopted

Borough Plan states that detailed site concept plans will be created for

housing and employment sites and adopted as supplementary planning

documents to sit alongside the Borough Plan. The HSG8 Concept Plan will

therefore help ensure co-ordinated delivery of the allocation and associated

infrastructure. The Concept Plan provides a visual representation of policy

requirements to inform the detailed masterplan to be submitted at the

planning application stage. The Concept Plan therefore shows proposed

locations for residential development, vehicular access points and spine

roads, utility routes, allotments and other key infrastructure.

2.2 The Concept Plan also provides information on the site’s context including the

surrounding area, views, landscape, habitat and biodiversity, highways and

transport, local facilities, heritage, environment and utilities.

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3. Public consultation

3.1 The draft HSG8 Concept Plan SPD was approved for public consultation by

the Council’s Cabinet Member on 27th September 2019. Public consultation

was held from 14th October 2019 to 9th December 2019. All consultees on the

Council’s consultation database were notified of the consultation including

statutory consultees (such as adjoining Local Authorities), and other

consultees (such as individuals, developers and community groups).

3.2 Hard copies of the Draft SPD were made available at Nuneaton Town Hall

and the Bedworth Area Office. A press release was issued, the consultation

was posted on the Council’s Facebook and Twitter accounts and all

information was held on the Council’s dedicated SPD consultation webpage.

3.3 A number of drop in sessions were also held:

Nuneaton Academy: 16 October 2019, 5 pm to 7 pm

CHESS Centre: 24 October 2019, 5 pm to 7 pm

Goodyers End Primary School: 4 November 2019, 5 pm to 7 pm

Whitestone Community Centre: 7 November 2019, 5 pm to 7 pm

Horeston Grange Church: 11 November 2019, 5 pm to 7 pm

Bedworth Civic Hall: 15 November 2019, 3 pm to 5 pm

Nuneaton Academy: 19 November 2019, 5 pm to 7 pm

Hawkesbury Village Meeting Place: 21 November 2019, 5 pm to 7 pm

Bulkington Village Centre: 25 November 2019, 5 pm to 7 pm

St James' Church Hall, Weddington: 28 November 2019, 5 pm to 7 pm

Nuneaton Town Hall: 3 December 2019, 5 pm to 7 pm.

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3.4 Comments could be emailed to

[email protected] or posted to Planning Policy,

Nuneaton and Bedworth Borough Council, Town Hall, Coton Road, Nuneaton

CV11 5AA. A telephone number was also provided for those who wanted to

ask questions or seek further information.

3.5 Comments received during the public consultation along with the Council’s

response to those comments are set out in Table 1 below.

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mailto:[email protected]

Table 1: Comments received on the SPD and the Council’s response to those comments.

Ref. Page no.

Paragraph Comments Suggested modifications

Officer response

101.1 1.2.3 Alternative solutions and land use arrangements may come forward as part of the planning application process, but the concept plans should be viewed as the fundamental principles for the site and any significant differences in approach would need to be justified at the planning application stage.”

Fundamental principles should be reasonable and appropriate and properly reflect the opportunities and constraints applicable to each parcel.

Noted.

101 1.3.1 The concept plan included in the draft SPD has not been the subject of any prior consultation or discussion with us, on behalf of either Seabridge Developments, or Taylor Wimpey North Midlands.

None. The consultation process has resulted in engagement with numerous stakeholders and all responses will be duly considered. NBBC believes that the SPD has been prepared in accordance with legal and procedural requirements.

101 Object to the draft SPD and the associated concept plan for the northern part of HSG8. We consider that the ability of the northern parcel to come forward separately from (and in advance of) the other two (central and southern) parcels, should be formally acknowledged in the SPD.

None. The northern parcel of land forms part of the Strategic Allocation HSG8 and is subject to the related policy requirements. It is logical that the northern parcel of land be included in the concept plan for HSG8.

101 2.5.2 Landscape Character Assessment Should be Policy HSG8 - west of Bulkington

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contains only four recommendations related to the northern parcel.

acknowledged that not all of the recommendations relate to all of the three parcels.

bullet point 26 states, "The site will require a concept framework to ensure the parcels that make up the site come forward in a comprehensive manner and cohesive manner. Development proposals should be in accordance with the concept plan...."

101 2.11.2 A review of the local sewerage network capacity has been undertaken. In terms of the northern parcel, it should be noted that STW has confirmed that it has capacity for our client’s proposals for 188 dwellings.

STW has no objections to the submitted planning application.

Noted.

101 3.1.1 There is reference to stakeholder engagement, which we must point out has not included the landowner, the developer/promoter, Seabridge Developments Limited, or the contracted house-builder for the northern parcel, Taylor Wimpey North Midlands.

The SPD should acknowledge the ability of the northern parcel to come forward separately and in advance of the central and southern parcels.

The consultation process has resulted in engagement with numerous stakeholders and all responses will be duly considered. NBBC believes that the SPD has been prepared in accordance with legal and procedural requirements.The northern parcel of land forms part of the Strategic Allocation HSG8 and is subject to the policy requirements. It is logical that the northern parcel of land be included in the concept plan for HSG8.

101 Figure 6 – HSG8 Site

For the northern parcel, there should be no requirement for a landscape buffer

Concept Plan for the northern

Policy HSG8, criteria 23 states "all site boundaries should be

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Concept along the eastern site boundary with existing housing in Severn Road.

parcel should better reflect the latest scheme promoted by the current planning application which allows for appropriate space about dwellings along the eastern boundary, with a wider landscape buffer along the western boundary with the railway line and also across the northern part of the site.

enhanced through new planting of woodland copses and trees whilst maintaining adequate distances from housing and all veteran hedgerows should be retained and surveyed prior to development. Species rich hedgerows should be incorporated within areas of open space." The eastern buffer reflects this requirement.

101 3.2.1 The broken hedge which separates the two fields in the northern parcel is of poor quality and can be removed to allow for a better layout, with its loss compensated for by new planting

Insertion of the words ‘and appropriate’ after the words ‘where

The wording is consistent with Borough Plan Policy HSG8 - West of Bulkington, bullet point 22 "Conserve and enhance the pattern of small and medium sized fields

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elsewhere around the site. possible’ to allow for some flexibility following an informed and balanced assessment of any particular landscape feature.

bounded by intact hedgerows where possible".

101 3.2.6, 3.2.13 and 3.4.5

The reference to the allotments needs to be modified.

Include the words ‘unless otherwise agreed with…..’ so as to allow appropriate flexibility. - as agreed with the Council's Open Spaces Officer request for a financial payment to improve existing allotments in Bulkington and an alternative to onsite

The wording is consistent with Borough Plan Policy HSG8 - West of Bulkington, bullet point 5. Changes to allotment provision may be considered at the application stage if there is sufficient justification, but the SPD has to be supplementary to the Borough Plan policy.

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provision.101 3.3.3 Consultations we have undertaken have

led to the opinion that Mill Lane should be used for pedestrian and cycleway connectivity and possibly for occasional POS maintenance purposes, but not as a vehicular access to residential development. Likewise, it has been concluded that the potential vehicular access off Severn Road should be reserved for emergency use only, with the main access being secured off Bedworth Road, broadly as indicated.

Amend text accordingly.

Para. 3.3.3 reflects the supplementary text to Policy HSG8 in the Borough Plan. Primary access is shown from Bedworth Road, which reflects the 2016 Strategic Transport Assessment. It is accepted that Severn Road may only be suitable as an emergency access. As Bedworth Road is likely to be the primary access point, it is considered that the Severn Road access should be removed.

101 3.3.6 Strongly object to any suggestion that development of HSG8 and more particularly the northern parcel, should contribute towards ‘road improvement schemes within the Borough.

The SPD should be modified to reflect the requirements that are specific to Bulkington, only.

The reference to road improvements schemes within the Borough is in relation to those required to deliver each site, which will be dictated by what is set out in the Borough Plan, i.e. Policy HSG8, which requires "Any transport improvements/upgrades required along Bedworth Road, Coventry Road and surrounding streets as a result of development".

101 3.4.1 The dwelling per hectare figure is below nationally recognised targets and represents a profligate use of land. The 28dph is arbitrary and the wording should be changed to 'at least 28

Deletion of the word ‘net’ change to ‘at least 28 dwellings per

28dph was accepted as an appropriate basis for determining housing numbers for the allocations, as set out in Policy SA1. Higher housing numbers

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dwellings per hectare'. hectare. would have to be justified at the planning application stage and the Council would consider such a justification having regard to the unique characteristics of the site, any subsequent site assessment and the feedback from technical consultees.

101 3.7.1 Concern over how the proportion of residential to green spaces is formulated and justified.

Suggest the inclusion of the word ‘approximately’ and we consider that any proportions should relate to the overall allocation and not be applied to each individual parcel.

The land use budget is going to be removed from all concept plans, as upon review we have decided that the figures are not needed due to the conceptual nature of the plans.

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101 3.8.2 Contribution for cycle paths to Bulkington Village Centre and Bedworth.

The final bullet point requirement does not appear in Policy HSG8 and ought to be deleted.

The final bullet point refers to Borough Plan Policy HSG 8, bullet point 13 and elaborated in para. 7.95 of the Borough Plan. The final bullet point in the SPD duplicates bullet point 12 in the SPD.

104a 23-32 Concept Plan

Concerns over the location of open space due to land ownership and state of readiness to submit planning application.

It is recommended that the location of the open space be reviewed with a view to shortening and widening it in order to allow the same provision of open space but allowing Bovis Homes to deliver an access to the land to the north east of the finger of open space on

Accepted - the proposed open space may prevent delivery of housing to the east and will be reviewed in consultation with the Council's Parks and Countryside team.

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the northern side of the existing hedgerow or that explicit reference is made to the location of open space being flexible, subject to the necessary standards being met- Illustrative masterplan provided.


It is considered that at present the Concept Plan does not have sufficient regard to the existing vegetation features of the site and the land ownership.

As above. The plan is conceptual and does not represent the detail which might be found in a masterplan.


It is questioned why there is a proposal for a landscape buffer along the southern boundary of the site southern parcel as shown in the below image. This landscape buffer is not a requirement as set out within Policy HSG8. The supporting text for the Concept Plan identifies between at 3.2.3

The practical design and delivery of the site should be considered in this regard: with the potential for

Policy SA requires that landscape features should be incorporated into the scheme design. There look to be trees along the edge of the southern boundary and these should be retained.

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to 3.2.6 the justification for edge treatments which includes green corridors and buffers but makes no comment upon the requirements for a corridor along the southern boundary.

back gardens to back on to other back gardens being a well-established design principle which helps to create secure private spaces.

105 3.4.3/3.4.4 Serious concern that the Concept Plan SPDs exclude any mention of off-site community facilities other than those covered by criteria 3 and 4 of the two respective policies:

“3.4.3 A number of on and off-site community facilities will be created… as part of the strategic housing site.3.4.4 Off-site works include; upgrading the existing sports facilities and teenage play provision at Bulkington Recreation Ground; and

The SPD has to be supplementary to Policy HSG8 and the SPD as drafted is considered to reflect the policy requirements. If there is a clear evidenced need that the development would need to make contributions towards other community facilities beyond those set out in the policy then that would be addressed at the planning application stage and considered in accordance with Policy HS1 - Delivery of Infrastructure. However, all contributions have to meet the strict legal tests.

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improvement of facilities at Miners Welfare Park in Bedworth, a ‘destination park’ within the Council’s Open Space Strategy; and other community facilitieswithin the village itself…”.

106c 28 3.3.3 Concern over proposed access off Coventry Road due recent residential buildings and land ownership. Transport assessment provided.

“Primary access for vehicles will be provided from Bedworth Road for the northern and central parcels of the site. The southern parcel of HSG8 has one potential primary access point from

Access arrangements have been based on the Strategic Transport Assessment produced by Vectos on behalf of Warwickshire County Council. Alternative access arrangements may be possible, but more detailed technical investigation would be required in consultation with Warwickshire County Council's Highways team. It is therefore too early to propose alternative access arrangements but it does not preclude them being pursued if they are determined to

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Coventry Road, and a second potential primary access point via Benn Road and Leyland Road utilising a property falling under the same ownership as the northern part of the southern parcel.Additional secondary vehicular accesses are possible from a second access to the southern parcel off Coventry Road (closer to the centre of Bulkington village than the Primary access

be acceptable in planning terms. It is considered that the wording as proposed captures the potential for alternative access arrangements via Lancing Road.

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referred to above) and from Severn Road and Mill Lane (both northern parcels). Linkages between ….”

202.9 6 1.2.3 It is important that the principles are retained and carried forward to any subsequent masterplans and detailed approvals. There is no clear reference to Policy HSG8 and the policy box setting out the key development principles. There is a risk that the key principles will become watered down, or lost, in documents that follow.

The SPD needs a clear reference to policy HSG8 and its associated key development principles as set out in the Borough Plan. Consideration should be given to replicating them in an appendix to the SPD.

Noted - agree that there is merit in stating that the Concept Plan SPD is supplementary to Policy HSG8 in the Borough Plan. The key development principles are contained within para. 3.8.2.

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202.10 21 2.11.2 The state of the sewerage piped network should have been known before the Borough Plan was consulted on. There is therefore uncertainty over whether the system can accept major new developments. If not, there could be risks to public health.

Whilst sewerage capacity is primarily a matter for STWA, its true condition and capacity should already be known, as it is potentially a show stopper.

As a statutory consultee, Severn Trent were consulted on the Borough Plan and the Infrastructure Delivery Plan (IDP). Their advice shaped the policy wording in Policy HSG8- but there was no objection to the principle of allocating the site. The issue of sewerage would need to be addressed at the planning application stage.

202.11 28 3.3.3 Leyland Rd is not suitable as an access to the southern parcel of HSG8. It would involve the use of the already difficult junction on Bedworth Road, which is in close proximity to the junction with Weston Lane and a minor junction serving The Croft. Bus stops are also present. The development is likely to increase pedestrian movements to/from the bus stops. Access to the southern parcel would be via a tortuous route using existing residential streets. The route is likely to be attractive to cyclists.

None. Leyland Rd is referred to in the supporting text to Policy HSG8. Although other access points may be more likely because they are less constrained, access is nonetheless possible.

A transport assessment would need to be submitted at the planning application stage and Warwickshire County Council would be asked to comment on the proposals in respect of highway capacity and highway safety.

202.12 28 3.3.3 It is well established that the primary access to the northern parcel should be

The Concept Plan needs to

Severn Road is referred to in the supporting text to Policy HSG8 as a

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located on Bedworth Road. Also, it is established that Severn Road is not suitable as a vehicular access. Opening up Severn Road would encourage new traffic into the existing residential area of Severn Road - Tamar Road, rather than using Weston Lane - Bedworth Road. Also traffic from the new development may divert via Severn Road to avoid using the designated primary access on Bedworth Road to avoid using the designated primary access to the development.

make clear that Leyland Road, Severn Road and Mill Lane are unsuitable and not acceptable as vehicular accesses.

possible access point. Access arrangements can only be determined at the planning application stage following the submission of a detailed transport assessment. Again, WCC would be invited to comment in relation to highway capacity and highway safety.

202.13 28 3.3.3 The proposed allotments are most likely to be in demand from the new housing and therefore should be accessed directly from with the new development; and via the primary access on Bedworth Road, for allotment holders who travel to site.

None. Noted, although an access from Severn Road cannot be ruled out at this stage.

202.14 28 3.3.3 Mill Lane is unsuitable for vehicular access to the new development because of its restricted width, particularly on The Stables, and Weston Hall frontages. Also the length of Mill Lane retains the last vestiges of what remains of the Weston-in-Arden, and the setting for Weston Hall. It would be unsuitable and environmentally inappropriate as a

The Concept Plan needs to make clear that Leyland Road, Severn Road and Mill Lane are unsuitable and not acceptable as

Again, Mill Lane is referred to in the supporting text to Policy HSG8 as a possible access point. The concept plan only shows it as a pedestrian/cycle access. Access arrangements can only be determined at the planning application stage following the submission of a detailed transport

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through route to Bedworth Road. Hence the primary junction of Bedworth Road remains the best option from poor choices.

vehicular accesses.

assessment. Again, WCC would be invited to comment in relation to highway capacity and highway safety.

202.15 32 3.7.1 The indicative land use budget states 16.6 ha for residential development. The minimum provision of 495 dwellings at 28 dwellings per hectare consumes 17.7 ha. The gross area is 25.1 ha which leaves a generous 7.4 ha for POS and other uses. The non-resi provision is greater than the area of best and most versatile land taken out, north of Bedworth Road. Cramming 495 dwellings into 16.6 ha would raise the density to 30 dwellings per ha. This is not necessary or justifiable given the excess land for other uses, and it is out of place for what will become edge of settlement.

None. A balance will need to be struck between making efficient use of the land and delivering a development that respects the local character of the area and is deliverable given site constraints. Ultimately, the dwelling numbers are minimum figures based on estimates and so a higher dwelling per hectare figure cannot be ruled out in principle - although clearly any number would need to be acceptable in planning terms. The land allocation budget is aspirational, but final budgets will not be known until detailed site masterplanning work has been undertaken at the planning application stage.

202.16 32 3.7.1 The land to the north of Bedworth Road amounts to 6.4 ha. Proportionately, it would be assigned about 125 dwellings, possibly subject to adjustment depending on the provision of the proposed allotments. This implies 370 dwellings on the land south of Bedworth

None. Noted, although the policy states that the numbers are minimum numbers. Higher numbers may be appropriate if they are demonstrated to be acceptable in planning terms.

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Road. It would be helpful to have notional numbers for the separate land parcels south of Bedworth Road.

202.16 32 3.7.1 The Borough Plan was justified to Council on the grounds that it is necessary to have an approved plan to properly manage how development takes place in the Borough. It is now incumbent on NBBC to ensure that the approved standards are adhered to, so that new development is in keeping with existing properties.

None. Noted. Legislation requires that planning applications are determined in accordance with the policies of the Development Plan, taking account of all material planning considerations.

202.17 33 3.8.2 Policy HSG8 contains ambitious requirements for essential infrastructure, wholly dependent upon funding by developers. Neither the BP, nor the SPD, contain any contingency measures to ensure delivery if funding falls short.

None. Infrastructure requirements and delivery are set out in the Council's Infrastructure Delivery Plan/Schedule. Planning permission is normally conditional on the signing of a s106 agreement.

202.18 33 3.8.2 Timing is another issue. Sustainable travel measures should be in place for first occupations and before travel habits are formed. Also strategic planting needs to be implemented early in the development. It should not be left until the site is developed out. The SPD needs to address all these issues and ensure they will be managed.

Failsafe provisions are needed to guarantee that the identified essential infrastructure, as a consequence of

Noted - sustainable travel measures are normally secured through s106 legal agreements. Sustainable Travel Welcome Packs are normally required to be approved and provided to each dwelling before occupation of any dwelling. Sustainable travel infrastructure like cycle paths, cycle stands etc. are likely to be funded

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development, can be met in full. The relevant authorities need to identify how they will ensure that necessary infrastructure is made available on time, even if developer funding fails. WCC indicated that their works programme is already committed for several years, so there are concerns about the proposed highway and traffic improvements. No major developments in HSG8

through the sale of properties and so there would normally be a trigger point for payment - e.g. payment on construction of X% of properties.

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should be approved until there is a clear commitment from the relevant infrastructure providers.

202.19 34 3.8.3 HSG8 is an amalgam of difference land ownerships with many controlling interests in its delivery. HSG8 cannot be delivered without clear and binding agreements on how the development obligations will be met collectively and equitably between parties involved. These are needed to prevent non-delivery of infrastructure and adverse impacts to local residents.

Any approvals relating to HSG8 must be conditional upon signed clear agreements between all stakeholders being in place and ensuring that all the required development obligations will be met. Note that some major items are funded across both HSG8 and HSG7 -

Noted. It is the purpose of the Concept Plan to provide a visual representation as to the infrastructure to be provided where and by whom. Applications will need to address the requirements set out in the policy - particularly where it affects that land parcel. The Council will use legal agreements where possible to do so.

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presumably these will also have to be shared by some agreed formula.

309.1 6 1.2 The Concept Plan SPDs use an almost identical generic front end. In consequence, they lack specific reference to the policy and its key development principles - in this case HSG8. The role of the SPD is to give further guidance, but it is equally important for readers to consider the relevant part of the Borough Plan as the primary document. The SPD does not achieve this.

A direct reference is needed to the location of policy HSG8, and preferably it should be replicated in the SPD so there is no confusion between documents, and nothing is lost in translation.

Para. 1.2.3 clarifies that the Concept Plan is supplementary to Borough Plan policies. The wording from policy HSG8 is reflected in section 3.8.

309.2 21 2.11 Throughout the public life of the Borough Plan, since Jan 2017, there have been only sparse references to potential for sewerage improvements, and now the SPD advises "…a review of local sewerage network capacity will be required." If there is sufficient capacity,

Full answers are needed now, or the SPD has no value.

As a statutory consultee, Severn Trent were consulted on the Borough Plan and the Infrastructure Delivery Plan (IDP). Their advice shaped the policy wording in Policy HSG8- but there was no objection to the principle of allocating the

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or there are operational deficiencies, these critically effect whether development can proceed, or not. In the latter case the SPD has no meaning. According to the available extracts from record drawings there are storm water overflows on the local sewerage system. It is to be expected that an increase in waste water from new development would adversely affect their operating conditions; but a the moment there is only an acknowledgement there may be a need for improvements.

site. The issue of sewerage would need to be addressed at the planning application stage.

309.3 28 3.3.3 Paragraph 3.3.3 suggests that Mill Lane might be used as a vehicular access. This lane is not suitable for vehicular access to the proposed development. Furthermore, given the proposal to encourage use by cyclists, the introduction of more vehicular traffic would detract from safety, and the attractiveness of the route to cyclists and pedestrians.

1. Amend all relevant references to indicate that Mill Lane is not considered suitable as a vehicular access to any part of HSG8.

2. The proposed allotments to be accessed from a new

The wording aligns with para. 7.98 of the adopted Borough Plan. The Concept Plan does not propose a vehicular access and reflects the recommendations of the Strategic Transport Assessment. However, access could be explored if the other proposed accesses cannot be delivered.

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primary access on Bedworth Road, and from within the new housing development itself. Any problems that may arise from the allotments use should be contained within the site, not spill out into existing residential roads.

309.4 28 3.3.3 Also, note that the strip of land at the end of Mill Lane was occupied and prepared by me 48 years ago in 1971, and I have continuously cared for it since. It is not contained in HSG8.

None. Noted.

309.5 17 2.5.2 I welcome the adoption of the recommendation from the Landscape Character Assessment to "… Conserve and enhance the pattern of small and medium sized fields bounded by intact hedgerows…" Unfortunately, the internal hedgerows of HSG8 are notably absent

The existing internal hedge lines are shown on all the other mappings. They need to be restored to

The Concept Plan does not show internal hedgerows as retention and enhancement of hedgerows is addressed in Policy SA1.

Any hedgerow removal would need to be justified at the planning

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form Figure 6; HSG8 concept. This implies they will be sacrificed in the name of development.

All too often, developers conclude that established hedge lines interfere with efficient development of the site.

Figure 6, to make it clear that there is an established principle to 'conserve and enhance' them. There needs to be a presumption in favour of retaining hedge lines.

application stage.

309.6 26 3.2.3 Para.3.2.3 conflicts with key principle "25. All site boundaries should be enhanced through new planting of woodland copses and trees whilst maintaining adequate distances from housing….. " and the indicative coloured land uses in Figure 6 HSG8 concept. Para 3.2.3 reduces the nature and quality of planting, and undermines the intention. It would only be a matter of time before occupiers start to remove the hedgerows.

Para 3.2.3 needs to be replaced with key principle 25, as identified in comments.

Para. 3.2.3 will be changed from "is encouraged" to "is required".

Incorporating hedgerows into residential gardens will assist with maintenance. Any hedgerow removal would have to be in accordance with legislation.

309.7 32 3.6.6 "3.6.6 Design has a crucial role in delivering a safe and secure environment in residential areas. Natural surveillance should be provided in the

How does this work when there is no street lighting?

Clear and legible refers to the layout of the play areas and so forth being clearly demarked and laid out rather than a reference to

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form of doors and windows to housing overlooking streets and public spaces, with the creation of an environment which is legible to residents and visitors alike. Play areas, footpaths and cycle routes shall be clear and legible to promote their active use".

the areas being lit.

313 The borough plan does not encompass a plan for the infrastructure, to include doctors’ surgeries, hospitals and schools. It is not good enough simply to say there will be some money provided by the developer and given to the NHS under 106, this does not constitute a plan to cope with the possibility of over thirty thousand extra people in the borough.

If this goes ahead I as I am sure it will lots of people will find themselves in a position where they will not be able to see a doctor when required or receive hospital treatment when required.

As the population grows there needs to be a proper plan in place which should form part of the overall plan. Anyone putting a plan together should be looking at the whole situation and not just one part.

If there are any plans in place they have not been presented as part of the

The Borough Plan does encompass a plan for infrastructure, which is set out throughout the document, as well as in the supporting Infrastructure Delivery Plan, which includes plans for doctor’s surgeries, hospitals and schools. The amount of money requested will be set by the service delivery partners, for example by the NHS, and it will be their responsibility to deliver the infrastructure.The Infrastructure Delivery Plan was presented as part of the Borough Plan, and was passed off as fit for purpose by an independent planning inspector.

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borough plan this should be a priority before any plans are passed off as fit for purpose.

315.1 19 and 29

2.7.4 and 3.3

In the new supplementary Planning you have stipulated that:Highway access 2.7.4 Direct vehicular access into HSG8 is possible from a number of routes including; Coventry Road; Leyland Road; Bedworth Road; Severn Road and mill Road.Highway access3.3.3 Primary access for vehicles will be provided from Bedworth Road for the northern and central parcels of the site. The southern parcel of HSG8has two potential access points from Coventry Road. Additionalsecondary vehicular accesses are possible from Leyland Road(southern parcel), Severn Road and Mill Lane (both northern parcels).Linkages between the central and southern parcels should be exploredto ensure a comprehensive and integrated redevelopment of the

To refer back to the original plan having original access from Bedworth Road only.

The secondary access point was never suggested to be Severn Road. As far as the original plan you didn’t have a secondary access road.

Reduce your numbers of the build and have the one access

The Borough Plan states that Severn Road is a potential secondary access point.

NBBC have not proposed Severn Road as an emergency vehicular access road, this was proposed by the developer.

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strategic housing site and to provide permeability through theDevelopment.Nothing was put in the original plans to have Severn Road as a secondary access road. It was planned to be used as a vehicular emergency access road only with a lockable gate. There is no mention of Severn Road Emergency Vehicular access road with the lockable gate in the supplementary planning.I strongly disagree to the new information. This makes the document incorrect.

road in and out from Bedworth road to HSG8 site.

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