Dear Friends,

Urgent – Please object to this planning application next to Bunsons Wood in Keresley by Sunday evening 8 May 2022.  Bullet points below.  

Richborough Estates
290 Homes
between Fivefield Road and Bennetts Road

send your response to
Planning@coventry.gov.uk and emma.spandley@coventry.gov.uk

On the website, the council show Saturday as the deadline but they have confirmed they will accept comments received up to Monday morning first thing.

Some suggestions below 

Objection to OUT/2022/0712 –

Homes between Bennetts Rd and Fivefield Rd, Richborough Estates

I wish to object to this development on the following grounds

  1. There is grave doubt about the population forecasts for Coventry, and any need for this housing. On the precautionary principle it would be reckless to make decisions now, on bad data, ahead of the census, which will very shortly resolve the matter.
  2. The Ancient Woodlands are insufficiently protected. A 30m buffer is inadequate. The Woodland Trust recommends at least 50m and preferably 100m. A narrow buffer will enable fly tipping, littering, and cats and dogs disturbing wildlife.
  3. the Transport modelling systematically underestimates future traffic. Major sources of traffic growth are omitted. Local junctions are currently over capacity and likely to get worse even with mitigation, if the true scale of traffic growth is assessed.
  4. [your own personal reasons – how important open countryside is to you for recreation, exercise, your dog, mental health, historic setting of Coventry, the last best unspoiled piece of Warwickshire Ancient Arden landscape (CCC’s own words in 1995).

Lack of need: The Precautionary Principle
There is abundant evidence that the population forecasts for Coventry are wrong. On the Precautionary Principle, which is law in the UK under the Aarhus convention, it would be reckless to make planning decisions on the basis of highly questionable figures, when authoritative data from the latest census, will be published in just a month or two – ONS have promised results by “early summer”.

The sole reason which the inspector gave for removing land from greenbelt was alleged exceptional population growth. Coventry Council is well aware of expert evidence, previously submitted, that the claimed extraordinary growth has not happened. As such, there is no reason for building unneeded homes on land which Coventry Council described as the bests remaining piece of unspoiled landscape in Warwickshire (in the 1995 Coventry Arden Design Guidelines, which remain in effect).

In May 2021 a lengthy investigation from the Office of Statistics Regulation (the official regulator of government statistics) cast considerable doubt over the ONS population forecasts for Coventry, finding “the population estimates for some cities such as Coventry, did seem to be inconsistent with, and potentially higher than, local evidence would suggest. This also appeared to be the case in a number of smaller cities with large student populations.”

Coventry Council responded, in May 2021 that the findings were “not definitive”. While the findings did not give a precise number for the current population of Coventry, this does not remove the regulator’s strong doubts about the improbability of the existing ONS population figures. They wrote “it is disappointing to hear that our findings are not being considered sufficiently within the council discussions. While it may not feel like it, I would echo Ed’s sentiment that our report was one of our more hard hitting pieces…… we are convinced that there is an issue with Coventry’s figures and that local sources of data are clearly inconsistent with the ONS figures”  – email of Elise Baseley, Statistics Regulator, OSR, 2 June 2021

The regulators first draft of their report, obtained through FOI, was even stronger – “fixes have not done enough to address the overestimation of these groups in some areas. This has led to an over reliance on insufficiently robust data to inform local planning decisions such as the need to build additional schools and housing.”


  1. The plans call for Fivefield Road to be blocked, but no detail is given on where this will occur, nor the mechanism for the closure. Residents who rely on this popular rural connection, should be given the opportunity to comment on the full details of the matter before reserved matters are considered.
  2. The Traffic modelling systematically underestimates future traffic
    1. Traffic on the Tamworth Road and Bennetts Road is already bad, with long queues in the mornings. The cumulative effect of the SUE, including this development, will make it worse. Even with mitigation, the Hub study still shows traffic over 100% capacity at some junctions.
    2. The baseline Automatic Traffic Counts in the HUB study for this development (the latest iteration of the traffic modelling ) were done in June July 2021, when traffic was suppressed by covid and people working from home – around 10% below previous levels1. If the baseline is too low, then all future forecasts of growth, using Tempro and NTEM, will also be too low. The traffic modelling needs to be redone, with traffic counts from a normal time.
    3. The modelling failed to include major sources of traffic:
      1. the new HS2 station, which will have 7,500 parking spaces, 100,000 new jobs, and 4,000 new homes – in 2014, Coventry Council complained in a petition to Parliament about the damaging effect of HS2 traffic on Coventry roads2.
      2. Passenger growth at the airport – forecast to more than double, from 11m/year to 27m/yr. DfT TAG M4 guidance on traffic modelling requires airports to be included in the modelling, in addition to the use of NTEM and TEMPRO.

        “Adjusting NTEM data to take account of surface transport for air passengers”

        7.3.9 “Surface travel demand for airports should be considered for all schemes, but where there is no major airport within or near to the study area, it may be sufficient to assume that such travel is minimal and make a case to the Department for not analysing it explicitly.”3
      3. A new corridor from the A45 to the M6.
        Highways England anticipated that the Keresley link road could open up a whole new traffic profile
        “In summary, Highways England has recommended that consideration should be given to other planned growth including Local Plan allocated development (with the Eastern Green SUE being the most prominent), as well as the inclusion of the proposed Keresley SUE Link Road. The introduction of this would provide a new corridor for traffic to the west of the city and could potentially affect the strategic traffic profile for the whole of Coventry.”

The traffic impacts need to be re-evaluated. The traffic studies use invalid and misleading standards:, the 1993 IEMA guidance. Relying on it, the studies ignore impacts less than 30% . This is misleading. The report itself states that this rule is not applicable to matters of highways “capacity” or “operation”. Current guidance in both Northern Ireland and Scotland states that a 5% impact is significant and on busy roads, even a 1% change can be significant.

“3.18. It should be noted that the Department of Environment suggests in Planning Policy Note 13 (DOE 1988) that increases of traffic of 5% are likely to be considered as significant by the Dept of Transport. The context of such a statement relates to the operational and capacity criteria of a highway and not its environmental impacts. It is suggested that the criteria set out in these paragraphs are more relevant to assessment of the environmental impacts and hence the higher thresholds are more relevant” [from the 1993 IEMA guidance]

It is not assured that the Keresley Link Road will ever be built in full. Highways England has expressed doubts. “the purpose of the additional modelling is to ensure that, from an SRN perspective, we are not committing to a position that relies upon on a final stage of a Link Road scheme that may not come forward but had been demonstrated to be necessary in traffic terms.”4

If this came to pass, traffic skirting the north west of Coventry, could end up rat running through the streets of Keresley and Holbrooks to get to Junction 3, M6

Forecast Traffic at the junction of Exhall Rd and Bennetts Rd, without mitigation – way over capacity
from the HUB Transport Assessment for OUT/2022/0712 Richborough Estates.

Traffic Forecast, Bennetts Rd Exhall Rd [J2], with mitigation – still over 100%, with no spare capacity, More than 0.85 ratio of flow to capacity (RFC) is considered undesirable by traffic engineers. Coventry Council, in their Connecting Coventry paper of 2017, point to the chaos on Coventry Roads caused by regular closures of the M6 – having recognised such events, there is a mandatory need for reserve capacity on the roads, not to run them at 100% of normal capacity.

Provide greater resilience to the motorway and trunk road network: when problems occur on the M6 the A45 and other routes around Coventry are frequently brought to a standstill and this undermines the attraction of the city as a place in which to invest;. [from Connecting Coventry Jan 2017]
The TA did not consider large new developments at Hospital Lane and School Lane which are likely to feed traffic into Exhall Rd, especially if the Keresley Link Rd is not completed as far as Prologis Park. In so far as the TA systematically underestimates future traffic, the future situation is very likely to be worse than forecast even with mitigation.

Many thanks


1 https://www.creds.ac.uk/publications/less-is-more-changing-travel-in-a-post-pandemic-society/

2 https://www.coventry.gov.uk/downloads/file/15168/coventry_city_council_hs2_petition

3 TAG UNIT M4 Forecasting and Uncertainty May 2019

4 Highways England to CCC 4 Jul 2019 [our doc 20]

Planning Applications

The first of 7 applications regarding 550 Dwellings on Fivefield/Tamworth Road has the cut-off date for objections coming up soon. This will be the first of the objections for applications with various cut-off dates in May.

  • RMM/2022/0680 Buffer to Ancient Woods. Comments no later 13.5.22
  • RMM/2022/0636 37 Dwellings off Keresley Link Road. Comments no later 13.5.22
  • RMM/2022/0679 18 Dwellings Tamworth Road. Comments no later 13.5.22
  • RMM/2022/0678 205 Dwellings Fivefield Road. Comments no later 13.5.22
  • RMM/2022/0678 284 Dwellings Tamworth Road. Comments no latter 13.5.22
  • OUT/2022/0712 290 Dwellings Fivefield/Bennetts Road. Comments no latter 7.5.22
  • OUT/2022/0713 260 Manor Farm. Comments no later 14.5.22

Ref. RMM/2022/0680 please send comments no later than 13th May 2022 to planning@coventry.gov.uk. Quoting reference. Please see a suggested text below, but please amend to your own words:

I wish to object to the planning proposal of 20m buffer to Ancient Woods.

The 20m buffer is insufficient. Please be guided by the advice given by experts, namely Woodland Trust, Warwickshire Wildlife and Warwickshire Biodiversity Team who all say a minimum 50m buffer is needed to secure the future of these very important and unique woods. These can never be replaced. The wildlife within these woods require foraging distances in order to survive. Please also refer to the Warwickshire Biodiversity survey of this area as part of their LWS audits. THESE WOODS REMAIN THE MOST BIODIVERSE  POCKETS OF LAND WITHIN COVENTRY. LARGE SCALE HOUSING IN THE AREA WOULD BE DETRIMENTAL TO THE SITE. THIS AREA INCLUDES HABITATS SCARCE IN WARWICKSHIRE AND PARTICULARLY RARE IN COVENTRY. THE SITES HOLD MANY OF WARWICKSHIRES NOTEABLE AND UNCOMMON PLANTS, FIVE RED LISTED BREEDING BIRDS AND THE ONLY SITE LEFT IN COVENTRY FOR BREEDING CUCKOO.

Noise and pollution both air and soil, increases in lighting associated with building works and at the occupancy stage will all effect wildlife, flora and fauna.

The developers, surveyors and Warwickshire Biodiversity have expressed concerns regarding the effects of large scale housing and how changes to hydrology and drainage will effect the woods and habitats. The woods are sited on a slope cumulating into a valley and the Hall Brook. Changes in natural water flow could cause serious long term destruction.

The Developers list 124 trees and over half a mile of Ancient Hedgerows  planned to be destroyed with the comment ‘This may change when the final layout is determined.’

The aim of a developer is to maximise an area and include as many houses as possible. THIS SHOULD NOT BE AT THE EXPENSE OF A UNIQUE, IMPORTANT AND HISTORICAL AREA.

Tamworth Road/Fivefield Road Site

On 7th February Coventry Council agreed the application for 550 houses on the Tamworth Road/Fivefield Road site subject to Reserved Matters and 106 payment agreements.

We have argued the reasons why this application should not proceed:-

Traffic surveys do not include all the sites within the area, they calculate the traffic from only three sites for a total of 1850 houses. They have not included Eastern Green (2,500 houses + industrial) Meggitts Burnaby Road (500 houses + industrial) Penny Park Lane (444 houses) and Scoping Plans for 300 houses in Allesley and a further 600 houses in Fivefield Road.
The traffic surveys conducted for the Amazon warehouse site drastically underestimate the number of HGV’s accessing Lyons Park, planning has since been passed for additional warehousing and a lorry park.

They have refused to increase the buffer zones surrounding the Ancient Woods contrary to advice from the Woodland Trust and Warwickshire Wildlife who have asked for a minimum 50m buffer.

The Ecological surveys conducted by the Developers underestimate the Ecological importance and content of the area and differs in content from the Warwickshire Biodiversity report (they survey this area every 3/4 years) and state “ The LWS remains one of the most biodiverse and attractive pockets of land within Coventry, with the wet woodlands among the best in Warwickshire. The habitats have changed very little and the LWS status remains intact. Large scale housing in the area would be detrimental to the site.”

Thompsons Farm Development

The Council meeting on 25th November mentioned the Thompsons Farm development. The Phase 2 development for the Wimpey site was passed, this was originally deferred in October due to problems associated with parking. A planner office mentioned in the meeting “discussions are taking place for finalising 106 payments for Thompsons Farm Development”.

Once these payments are agreed (106 payments are the Developers contribution to the Council for infrastructure costs), there is a small window of six weeks until the Planning application is approved.

Save the Green Belt!

Save our Meriden Gap

The beautiful Warwickshire countryside, all around Coventry, is in grave danger of being covered over with thousands of houses – at Kings Hill, Eastern Green, Keresley, Allesley, Cromwell Lane, Westwood Heath, and more. Our green lungs and farmland are at risk. During the 2016 Local Plan process Coventry Council took this land out of Green Belt, and allocated it for housing, on the basis of population figures now being questioned by the Office of Statistics Regulation. We are monitoring the OSR very closely and will use the reports to influence future housing policy.

Our first legal battle has commenced in the Planning Court 15 July.


The Crowdfunding Page

In June Coventry granted planning consent for mixed use housing at Eastern Green and urgent action is now needed to fund legal proceedings to halt development from proceeding. The claim was brought by The Campaign to Protect Rural England Warwickshire.

Continue reading

Scoping Applications

Two new scoping application have been accepted by Coventry City Council around Fivefield Road and Bennetts Road. Outline planning applications will follow, when this happens we will have an opportunity to raise our objections. Although the developers have invited comments the link on their website is currently broken.

This file shows the area they intended to develop.

More precious green land and biodiversity lost for ever

This article was written by Ann Wilson, Objector on behalf of Coventry Tree Wardens.

Having sacrificed the beautiful Windmill golf course to housing at their last meeting, the Planning Committee has now given over the last bit of important open green space on London Road to developers.

On 2 September they completely ignored the pleas of 3 local councillors and 6 residents, including local tree wardens, who were desperate to retain this land as public open space for the health and well-being of local people as well as all the wildlife that lives there. Trees, hedges, shrubbery and a wildflower meadow, all of which take up water, absorb pollution, store carbon and help prevent climate change will now be lost, including a woodland planted by the Council.

The biodiversity on this site is irreplaceable.

Many issues in the officers reports were questioned. All the objectors stated that the housing numbers exceeded those in the Local Plan, but were told they were not maximum figures. Air quality and biodiversity questions remained unanswered and flooding also was of little concern, even thought the proposed building is on a flood plain. Extra traffic, it was said, would not affect one of the worst congested roundabouts in Coventry.

So, the Council will make a bit of money destroying this beautiful land, but at what cost to the health of local people and the health of our planet?

And to quote one of the other objectors, “They seem to be in complete denial of climate change.”

Tamworth Road/Fivefield Road

A reminder that residents have received notification from Bellway Homes representatives Marrons Planning telling them they propose to apply to Coventry City Council later this year for full planning approval for 550 houses in Tamworth Road/Fivefield Road.

They are asking for comments on their proposals via the website www.landatkeresley.co.uk or by e-mailing keresley@marrons-planning.co.uk before the closing date of 23rd August.

Please lodge your comments before then, some points to consider:

  • Traffic assessments were undertaken in 2016 prior to Amazon/Lyons Park opening in late 2018. The traffic assessments only take into account 1250 dwellings of the 3200 planned for Keresley. They do not include 3200 dwellings planned for the neighbouring Eastern Green development either. The accident report states ‘No Major incidents’. In 2020 there were five major incidents on the Tamworth Road alone requiring the emergency services including two fatalities.
  • As yet no school provider is approved for the Free school. No plans are approved or submitted for the building of this school either. It is of paramount importance that residents have a school provided and this should be in place prior to occupation (which commences with the Wimpey development).
  • Final route and plans for the Link Road have yet to be completed. There is also no indication this link road is as yet fully funded and no start date or completion date planned. Similarly with the proposed junction in Sandpits Lane.
  • Guidelines state that bus stops should be located within 400m of a dwelling. There are no plans for a bus route into the Fivefield Road development and no assurances of proposed implementation of a bus service for Tamworth Road (currently 3 buses per day and no Sunday service). Distances to local amenities, G.P. service, school and shops are not within walking distance.
  • Public Footpaths were proposed to be re-routed. Footpath M315 cuts through the intended Link Road. To ensure safety of cyclists and pedestrians there should be a bridge constructed.
  • Ancient Woods are a fragile area that will not survive heavy disturbance. The Warwickshire Biodiversity Team assessment states ‘Large scale housing in the area would be detrimental to the site. This remains one of the most biodiverse and attractive pockets of land within Coventry, with the woodland habitat among the best in Warwickshire.’ The developers have proposed a 15m buffer to the woods, CCC have suggested a further 10m with planting. The Warwickshire Wildlife recommends 50m and the Woodland Trust a minimum of 50m and preferably 100m.
  • Both the developers experts, Sylvan and White Peak, have expressed concerns over the change in water flow to the woods which they say could have a detrimental effect. The Warwickshire Diversity Team have also expressed concerns over drainage which could seriously damage the health of the woods. Developers are planning a balance pool between the woods which could further restrict the water flow.

Do we need all these extra houses – NO

Do we need housing on the perimeter of a city which will necessitate car usage – NO

Do we need expensive executive housing in lieu of housing for young families – NO

Do we consider the designs for the houses on the proposed Bellway development in keeping with the Arden landscape design criteria –NO

Are we prepared to stand for the disrespect the developers have shown to the importance of the ancient woods and trees they are prepared to sacrifice – NO