Q-I1: Please add any comments you wish to make about the Sustainability Appraisal, indicating clearly which element of the appraisal you are commenting on.
I would be very cautious about building larger scale developments. One criticism is that they lack a community feel. So any large developments must take this into account. Another criticism is that if they are built next to an existing settlement, the existing residents can feel that their identity is disappearing. So this too should be taken into account. With building new houses, this is an ideal opportunity for them to have all the practical energy saving features available. Including solar panels, insulation, etc,. This should be part of the planning permission. Developers make enough money out of building new properties. The least that they can do is to build them responsibly.
While each case must be assessed on its own merits, it is concerning that the Council is having to look disproportionately towards large sites that are hard to integrate into local communities and place significant strain on local services and infrastructure. The CLA would encourage a greater spread of development, especially targeting rural towns and areas. This will allow much needed local houses to be built which keeps prices affordable, supports local business and local services.
The SA should not forget / ignore the the classification of South Warwickshire as an Area of Outstanding natural beauty and sustainability should not be to the detriment of natural beauty.
I would be very cautious about building larger scale developments. One criticism is that they lack a community feel. So any large developments must take this into account. Another criticism is that if they are built next to an existing settlement, the existing residents can feel that their identity is disappearing. So this too should be taken into account. With building new houses, this is an ideal opportunity for them to have all the practical energy saving features available. Including solar panels, insulation, etc,. This should be part of the planning permission. Developers make enough money out of building new properties. The least that they can do is to build them responsibly.
Section 6 evaluation is fundamentally flawed as in the case of A1 there may currently exist railway or GP facilities but the current GPs could not accommodate this increase as they can barely cope and an hourly railway service would not meet the demand. In addition, if the reason for including A1 was access to these facilities then it should be removed from the panel of 7.
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The Sustainability Appraisal seems logical, however the size and scale of allocating housing in existing small villages is harmful. It is proposed to build up to 500 new homes on Green Belt. The village currently consist of about 350 houses, 50% of the population lives on a residential caravan park. The proposal, if implemented would have a devastating effect on the local community, this is in direct conflict to the declared principal of "Supporting vibrant and distinct centres". Wootton will inevitably merge with Henley-in-Arden.
How is it sustainable to build on heritage sites, flood plains and wild countryside?
The SA must consider the impact on infrastructure including the additional pressure on roads, drainage, schools and healthcare, identifying the critical elements that must be delivered as an integral part of the development.
Improved public bus services through the villages like Moreton Morrell are essential in order to deliver sustainability ambitions. Residents in Moreton Morrell are dependent on their cars and usually a minimum of two cars.
Sustainability Appraisal Wiith reference to BROAD LOCATIONS IDENTIFIED FOR HOUSING DEVELOPMENTS IN KENILWORTH - these appear to include parts of Kenilworth Golf Club, Beehive Hill allotments, Parliament Piece nature reserve, the Pavilions field, Gypsy Lane allotments, part of Castle Farm Leisure grounds, the tennis club amongst other areas. While accepting the need for housing development, this exceedingly broad brush is unhelpful in that it threatens highly valued parts of the town. Surely it cannot be wise to build houses on these important locations which contribute so much to the town in their current form.
How can you have a plan for mitigating climate change then want to create a vast amount more CO2 by building so many new houses & industrial buildings..?? These objectives seem to entirely contradict themselves...!!! All infrastructure including (but not limited to) hospitals, doctors surgery's, schools, health centres, shopping hubs etc need to be funded & built before any further expansion in housing is even contemplated. As for transport links, outside of the large towns public transport links are almost non-existent, again these need to be funded & in operation before any further expansion is considered. Long Marston development of a whole new town has virtually zero public transport links which means every family needs several cars to be able to function on a day to day basis. All towns need to be connected by railway & regular bus links. If you want 15 minute towns then you need 15 minute transport links to all the towns & villages where the majority of people live. If I am to reduce my car use then you need to provide fast, reliable, clean & regular (every 15 minutes) public transport system.
As the predictions of future population and energy supplies are so uncertain most of this is guesswork
The assessment of sites at Appendix 3 concludes that the development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. I think this is wrong, it ignores the main purpose of designated Green Belt, particularly in this location.
Sustainability Appraisal - appendix 3 Page B68, B74 Location B12, B13 - These locations meet many of the 5 purposes of green belt land and were assessed to have done so by the Planning Examiner in 2017, including the protection from coalescence of settlements at Old Milverton and Blackdown and between Leamington Spa and Kenilwoth- therefore the conclusions that this would not lead to a coalescence of settlements if factually incorrect. As a local survey and this consultation will show, these locations are heavily used for recreational purposes and are also highly valued by local residents - so development would have a significant impact on the recreational use of local footpaths. These same sites are also high quality agricultural land undermining many of the food security and sustainability objectives of Government policy.
The development in Old Milverton and Blackdown incorrectly concludes that it would not lead to coalescence of settlements and have only a minor negative impact on recreational experience. This is wrong and ignores the main purpose of designated Green Belt.
The assessments of the two proposed development sites in the Green Belt in North Leamington are misleading and inaccurate. In particular, the statement that development at these locations would be “unlikely to lead to coalescence of settlements” is invalid. Any development here would inevitably lead to Old Milverton and Blackdown being absorbed into Leamington, as well as contributing to the growth of the northern boundary of Leamington up to the southern edge of Kenilworth, particularly in view of the already planned developments at Thickthorn and neighbouring sites. This runs directly contrary s precisely what the Green Belt was designed to prevent. Furthermore, the assessments claim that there would be only “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. This is illogical. If the developments go ahead, there will no longer be any recreational experience from using the footpaths as they will either disappear, or (at best) become pavements through housing estates.
The SA report link takes you to two lists of technical papers . I didn't find an SA report? There was also a list of reports still to be completed. I am not sure how a member of the public can possibly find the time read these numerous papers. An SA report summarising the findings would be had been very useful.
The assessment of the sites in appendix 3 conclude that development around Old Milverton would lead to no coalescence of settlements and only a minor impact on recreational experience. I watch numerous people walking across the fields each day. During lockdown this was the only and a valuable open green space in Leamington.
The assessment of sites in Appendix 3 concludes that development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. This is wrong and ignores the main purposes of designated green belt, particularly in this location. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. This green belt is a valued open space.
Details on why Green Belt areas are being considered for development Details on how areas of historical importance will be protected
Issue Ql1 - the issues assessed in appendix 3 relating to blackdown and old milverton says that the plan would result in minor coalescence of settlements and only a minor negative impact on recreational experience which is just totally wrong, it’s the exact opposite. The main purpose of the green belt especially in this area is to avoid the coalescence of these areas and to provide the benefit of outdoor recreation. Please do not take this away.
Growth options should prefer new settlements rather than expanding existing small settlements with little infrastructure, eg Bidford, Wellesbourne, Southam, Shipston
The assessments of the two proposed development sites in the N orth Leamington Green Belt are not transparent. The assessments on page 477 appendix to the Sustainability Appraisal (B68&74)and are not referenced in the main consultation. Both state that the development at these locations would be “unlikely to lead to coalesce of settlements”. However, any development at these locations would subsume Old Milverton and Blackdown into Leamington as well as taking the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the developments at Thickthorn and other sites nearby. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding footpaths “. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably)became pavements through the housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which is a coincidental benefit of the designated actual function of the Green Belt area. The recreational, educational and health benefits to those in the surrounding areas are important for both physical and mental health. The agricultural lands provide rural employment and their continued use for arable, grazing and wildlife refuge helps to preserve the characteristics of the rural area. Further, the farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. The National Planning Policy Framework states “where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”.
The proposal breaches the 5 basic principles of why we have Green Belt area. The Green Belt area is well used and valued by residents. There was a resurgence of use during Lockdown, some of which may have faded but residents are now more aware of such facilities and use them more than pre covid. The proposal will erode valuable agricultural land at a time we should be reviewing our own agricultural resources. The two proposed developments in North Leamington are inaccurate. There are contradictions as between the Appraisal and the Main Consultation. Distinct areas particularly Leamington and Kenilworth would merge, contradicting the main purpose of Green Belts. Recreational locations would be lost.
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The assessments of the two proposed development sites in the North Leamington Green Belt are opaque and inaccurate. These assessments are in a 477 page appendix to the Sustainability Appraisal (pages B68 and B74) and are not referenced in the main consultation. Both state that development at these locations would be “unlikely to lead to coalescence of settlements”. However any development here would subsume Old Milverton and Blackdown into Leamington. It would also take the outskirts of Leamington up to the southern outskirts of Kenilworth, particularly the development at Thickthorn and other sites nearby. This is precisely what the Green Belt is designed to protect against. We are also told to expect “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths”. If these sites are developed there will no longer be any recreational experience to be had from using the footpaths as these will (presumably) become pavements through a housing development. Moreover, this analysis assumes that the only important function that this area serves is recreation which, as we have noted, is a coincidental benefit of the designated actual function of this Green Belt area. We think it is therefore a serious inaccuracy to call this a ‘minor negative impact’ and discloses a strategy which would significantly reduce the need for urban regeneration in favour of greenfield development. The Green Belt around North Leamington fulfils the stated purpose of Green Belt land. The five purposes of Green Belt land are to: ● check the unrestricted sprawl of large built-up areas ● prevent neighbouring towns merging into one another ● assist in safeguarding the countryside from encroachment ● preserve the setting and special character of historic towns ● assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The Green Belt around North Leamington is a valued open space. In surveys residents say that the open Green Belt location is the thing they value most about living in the area, with benefits for both physical and mental health. It is easily accessible on foot from North Leamington so many people can access the public rights of way across the fields. Use of these footpaths increased markedly during lockdown and these high levels of use continue today. The agricultural land continues to provide rural employment and undergo diversification of farming techniques. Its continued use for modern arable, grazing and wildlife refuge helps preserve the characteristics of the rural Victorian village of Old Milverton enjoyed by so many. The recreational, educational and health benefits to those in surrounding urban and suburban areas are important now more than ever. The farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. Recent Government policy has stated that farming and food production make an important contribution to sustainable development. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. The land making up these sites is, therefore, considered to be a scarce resource of high value for sustainable food production. The Government seeks to protect against the loss of such land from non-agricultural development. The National Planning Policy Framework is clear that “Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality”; a policy which will continue to grow in significance as the increasing cost of imported wheat and grain drives up domestic food production needs. The assessment of sites at Appendix 3 concludes that development in Old MIlverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. I think this is wrong and ignores the main purpose of designated Green Belt particularly in this location.
The assessment of sites at Appendix 3 concludes that development in Old Milverton and Blackdown would lead to no coalescence of settlements and only a minor negative impact on recreational experience. I do not agree with this and it ignores the purpose of Green Belt Land - particularly in this location.