1 Introduction 1

Rugby Local Plan Examination Lodge Farm Policy DS10 Landscape Response on behalf of SALFV, Grandborough Parish Council, Willoughby Parish Council and Barby and Onley Parish Council January 2018 Status: Issue Lodge Farm Policy DS10 Rugby Borough Local Plan Examination Contents Report 1 Introduction 1 2 Response to emerging Local Plan and Evidence Base 3 3 Impact of Lodge Farm Proposals 16 4 Conclusions 24 Appendix 1 Methodology Appendix 2 and Photographs A3 Booklet of Figures Figure 01 Site Location and Views Figure 02 Landscape Character Areas Figure 03 1884 Historic Map Photographs A - M Status: Issue Lodge Farm Policy DS10 Rugby Borough Local Plan Examination 1 INTRODUCTION 1.1 This written statement has been prepared by The Landscape Partnership (TLP) on behalf of Stand Against Lodge Farm Village (SALFV) Grandborough Parish Council, Willoughby Parish Council and Barby and Onley Parish Council in relation to the emerging Rugby Borough Local Plan and in particular landscape matters relating to Policy DS10 (hereafter also referred to as the Site) which is a proposed strategic allocation for 1,500 dwellings in a greenfield location adjacent to the A45 but detached from other settlements. 1.2 TLP have carried out a review of documents relating the area defined by Policy DS10 including the following documents: Rugby Local Plan Examination – Matters, Issue and Questions (December 2017) Rugby Borough Council Local Plan – 2011-2031 Publication Draft (September 2016) The Local Plan Publication Draft Consultation Responses Summary (April 2017) Sustainability Appraisal by LUC (September 2016) Landscape Assessment of the Borough of Rugby Sensitivity and Condition Study (April 2006) Landscape Sensitivity Study (August 2016) and Rainsbrook Valley (January 2017) Lodge Farm Vision Document (June 2106) 1.3 TLP were instructed in November 2017 by SALFV and carried out a Site visit in December 2017 viewing from public locations around the perimeter of the Site, on the public right of way R241 that passes through the Site and from a range of other locations in the locality. Weather was clear/overcast and cold with good visibility. 1.4 The Inspector has set out the various matters, issues and questions that he wishes to consider at the EIP. Those relevant to landscape matters and DS10 include : Issue 3 a) Overall Development Strategy Question 1 g) Is the selection of Lodge Farm justified as the most appropriate location for a new settlement in preference to the preferred option site at Walsgrave Hill Farm or other options? What is the evidence to support this? © The Landscape Partnership January 2017 Page 1 Status: Issue Lodge Farm Policy DS10 Rugby Borough Local Plan Examination Issue 3b) Lodge Farm DS10 Question 1 a) –How was the site at Lodge Farm selected as the most suitable location for a new village? Has the selection of this site been adequately justified against alternative locations within or outside of the Green Belt? Question 1 b) –What is the current planning status of the site? What site specific assessments have been carried out to underpin Policy DS10 and determine the mix of uses proposed, the impacts of the development and the deliverability of the site, its infrastructure and facilities? Question 1 c) - What is the likely impact of the proposed development of the site on the following and what measures are proposed to adequately mitigate those impacts? (Inter alia) • ecology, biodiversity and green infrastructure • landscape quality and character • heritage assets 1.5 In this statement quotations are in italics and are underlined for TLP’s own emphasis. © The Landscape Partnership January 2017 Page 2 Status: Issue Lodge Farm Policy DS10 Rugby Borough Local Plan Examination 2 RESPONSE TO EMERGING LOCAL PLAN AND EVIDENCE BASE 2.1 Following a review of the emerging Local Plan and supporting evidence base material relating to Policy DS10 TLP make the following points that highlight concerns over the soundness of the allocation of Policy DS10 in the emerging Local Plan. LP 34 Landscape Assessment - 2006 2.2 LP 34 is the Landscape Assessment of the Borough of Rugby Sensitivity and Condition Study (SCS). The study was carried out for Rugby Borough Council (RBC) by Warwickshire County Council in conjunction with the Living Landscapes Project. The study divides the authority into landscape character types (although most are specific areas). The Site is located within the Feldon Vale Farmlands character type. The sensitivity of the character type as a whole is noted as Moderate based on a combination of moderate fragility and moderate visibility (see Maps 1, 2 and 3 in the SCS). 2.3 The description of the Feldon Vale Farmlands is provided at Page 16 of the SCS. This provides a fair and accurate description of the existing landscape as follows: This is perhaps the most typical landscape within Feldon – an area of broad, flat, low-lying clay vales with few roads or settlements. It is characterised by a largely intact pattern of medium to large-sized geometric fields, bounded by hawthorn hedges. Tree cover of any kind is sparse, allowing wide views to rising ground and giving a strong impression of sky and space. Despite a significant move towards arable production in recent years, extensive areas of permanent pasture still remain a feature of this landscape, together with well-preserved areas of ridge and furrow. Deserted medieval villages have also survived in places. Villages are typically few and far between, often consisting of small, straggling clusters of farmsteads and dwellings. Most are situated around a cross-road, and many are well off the beaten track. Roads are often single track, with wide grass verges, bounded by a ditch and thick hedge. Sensitivity – Fragility: Cultural sensitivity is generally moderate due to a coherent historic pattern. Ecological sensitivity across the area is low with the exception of an isolated wetland area, giving this pocket a moderate fragility score. Sensitivity – Visibility: Visibility is moderate due to the low-lying, unwooded landscape character. Overall sensitivity: Visibility and cultural sensitivity (coherent cultural pattern) both contribute to a moderate overall sensitivity rating. © The Landscape Partnership January 2017 Page 3 Status: Issue Lodge Farm Policy DS10 Rugby Borough Local Plan Examination Condition: Within the survey area the condition of land to the east of Hillmorton, together with a parcel of land to the south of the Plateau Fringe are both in decline. 2.4 However, it should be noted that the assessment for the Feldon Vale Farmlands is accurate as an overview of the landscape character. Page 1 of the SCS states, This report details the work of a broad scale landscape assessment and sensitivity analysis of the Borough of Rugby, looking in more detail at the countryside around the urban fringe of Rugby itself. …..The aim of the study was to examine the character of the landscape around the town, its sensitivity to change, the condition of the countryside abutting Rugby’s urban fringe and beyond, and to demonstrate how the outcomes could be used as a decision tool in the development planning process. In order to arrive at this level of detail it was necessary to carry out a broad based assessment of the landscape within the Borough as a whole. Landscape character assessment will be an important component in the Local Development Framework for Rugby Borough. A number of LDUs that abut the edge of the town have been sub-divided into land cover parcels (LCPs). These can be defined as discrete areas of land bounded by roads, railways, water courses, parish boundaries or breaks in slope, where similar patterns of land use, field pattern and tree cover are evident. Each LCP nests within an LDU, and reflects changes in ownership and landuse which may influence factors such as landscape condition. They form a useful tool for looking in more detail at the landscape around urban fringes and for enabling specific parcels of land to be assessed for potential development/enhancement. 2.5 The SCS uses the Landscape Description Unit (LDU) as the primary building block. TLP support this method of character assessment which can also be helpful in identifying areas for more detailed sensitivity and capacity studies at a finer level of detail. The LDUs can be sub-divided into Land Cover Parcels (LCPs) e.g. around the urban fringes for a more detailed assessment of the potential for development /enhancement. This process has been carried out for the urban fringes of Rugby and for a number of the larger settlements /villages in the later studies of 2016 (LP35) and 2017 (LP36) as noted below. These later studies identify a proportionally greater number of High sensitivity LCPs around settlements with a more limited number of Medium and Low sensitivity LCPs. The less sensitive locations and LCPs are generally more closely associated with existing urban areas or edges while areas that are more detached and remote are considered to be of higher sensitivity. 2.6 However, a detailed assessment of LCPs has not been carried out for DS10 or the areas close to it. Rather RBC rely on the findings of the ‘inherent character’ and sensitivity of the whole of the Feldon Vale Farmlands from the 2006 SCS. The reasons why this approach is unsound are: © The Landscape Partnership January 2017 Page 4 Status: Issue Lodge Farm Policy DS10 Rugby Borough Local Plan Examination a) The scale of assessment in the SCS (including the Feldon Vale Farmlands) is too large and does not allow for local variations in the sensitivities in the landscape that would be assessed using LCPs. b) The assessment of the sensitivity of the character areas as whole does not consider a sensitivity to any particular type of development. The SCS does not identify the importance of considering the different sensitivity that would be found for different types and scales of development in any location.

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