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.
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 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.
We feel that it is incorrect that a development in Old Milverton and Blackdown will only lead to minor negative impact on the recreational experience - we feel that this will be majorly impacted. Furthermore, settlements like Old Milverton will be loose its character as village, as it would become part of a bigger settlement - both Blackdown and Old Milverton would become part of Leamington. It is to be expected that the current footpaths around the fields would become nothing more than paved footpaths through settlements. These proposed changes would NOT constitute a minor change to the status quo, but a severe impact of the quality of the environment for recreation and as a living space.
All 5 options promote development in greenbelt based in a very naive and flawed assumption drawn from focus groups (the population of which is not clear). In doing so they ignore the 5 principles of greenbelt as a basis for the proposal. This is contradictory to one of it's main functions. 2.4.4 of the SA warns against the use of greenfield land citing an increase in greenhouse gasses. This approach also contradicts further paragraphs of the SA (2.4.9, 2.6.2, 26.3, 2.6.9 and others) citing the impact on geodiversity and biodiversity and their future importance to managing climate change and in sustainable food production, not to mention the sustainability of recreation and mental health improvements. The ignorance of this approach is further compounded by an admission (2.7.3) that greenbelt purposes have not been considered specifically. There is an assumption that a revision of greenbelt boundaries will be allowed and therefore these options will stand. Given recent discussions locally and ay national government level in the last 20 years, this is unlikely to be approved and will lead to a further prolonged planning consultation where non-greenbelt options may have to be generated, which in effect just creates more unnecessary work and uncertainty for local residents.
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.
4.5 -4.6 Kenilworth Commenting on this as this is where I live . Comment: Are these sites being looked at to develop Kenilworth as part of Warwickshire housing needs or as Coventry Overspill? There is a difference because as a concerned citizen who takes the trouble to read these documents etc I feel that if they are Kenilworth developments we have an input into them, if it is Coventry Overspill we don't. A local plan should be an ownership issue not a dictate from a neighbouring area. Comment: In a number of the points we read good design will mitigate the problems but when you are building 2000+ houses that is the least of the builders considerations. Infact saying that the builders will pay in to various social funds is all well and good until you find the Council and Milverton Homes don't have to pay into this fund so once again the people of Kenilworth do not get any advantage of all this urban development. Comment :It is also unfortunate that so many assumptions are made with out 1) visiting the sites just google maps....2) only now authorising Heritage surveys and 3) Trees ancient woodlands .Surely we have more protection on these areas than just meeting our housing needs. Stopping people from visiting woods ,walking their dogs etc by putting buffer zones? Come on what is happening is the urbanisation of a rural landscape. You only had to see how the Abbey fields (that wonderful green space Kenilworth has) was so used in the Pandemic and even now much more used than it was before the pandemic. Comment: Pollution...2000 more homes leads to more waste /sewage/ light pollution because this rural area will now become urban and that means street lights. I find it very difficult not to see any of these sites other than urban sprawl especially as we have HS2 running through,(noise pollution as yet unknown), but perhaps that development's impact on this town could be considered separately. Comment: Agricultural land this local plan needs to look at farming keeping Warwickshire with a food supply. Events in the last few months show how relevant a local supply chain is. Giving some of our farming land over to solar is not a good idea. Again who gets the profits form solar farms? Do we keep the energy or does it go to the grid and the profits to China or whoever owns the company. Geopolitical issues must be considered in a local plan surely? Comment : Accessibility not to sure how these new developments fit into a 15 min /20 min neighbour hood. New schools and Dr surgeries, shops will all be needed. The walk/cycle to the new secondary school might be doable for young people but older people, young families will need public transport. All new developments must include cycle ways paths car charging points,5G built by the developers not added after wards. For the vision objectives to become a reality KTC and WDC need effective planning regulations in placent, granting permission only to see Construction companies challenging the numbers time and time again.. Green spaces and Green Belt must be protected otherwise the headlines of the C.E.T. 2031 will read" It is now possible to travel from Wellesbourne formerly in South Warwickshire to Wolverhampton with out seeing a field ,or hedgerow or wood as the West Midlands Conurbation has now become the "Greater West Midlands Economic Engine"
The assessment of sites at Appendix 3 says that development at Old Milverton and Blackdown would not lead to coalescence of settlements and would only have a minor negative impact on recreational experience. I think this is wrong. It will inevitably lead to the future merging of Old Milverton and Kenilworth. There will be a loss of much valued open countryside. The main purpose of designated green belt has been ignored, particularly in this location.
One good step for sustainability is to build the infrastructure first, then the housing. An example: in Upper Lighthorne there's no surgery, which means stress on all the local surgeries. Instead for future sites, build the surgery/shops/etc first - THEN the houses. This has two positives: 1) the developer has to commit to creating the service upfront = no wriggling out, and 2) the occupants of the new housing won't have to spend 15 minutes each way in their cars to reach the nearest surgery = green & sustainable.
No answer given
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.
No answer given
A need to increase energy efficiency sustainability standards for new builds will only be achieved with vigorous control of products used in construction (ie/high qualitity building materials/effective insulation, etc) and renewable energy (ie/solar energy/heat recovery pumps,etc). Evaluation of new settlement locations: F1,F2 and F3 do not have good road network, the A425 and A423 are already busy and with Southam being considered in the Broad Location, would over develop the area. The bus service would have to radically increased and all sites would sit close to HS2. The nearby access to GP surgeries: all potential sites, because of their size should include a GP surgery and not rely on current GP availability.
Re sustainability, it is important to consider capacity of existing infrastructure. Whilst it may be perceived as positive to look at existing infrastructure, that existing infrastructure might also be at capacity. Important bottle necks that should not be considered as having scope for further housing are around the m42 corridor and particularly the intersection between M40 and M42 which spends several hours per day at a stand still. In some cases it will be easier and more sustainable from a quality of living perspective to build housing either where entirely new infrastructure is required or where incremental growth can be accommodated within existing settlements
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. I think that this is wrong and ignores the main purpose of the designated Green Belt, particularly in this area.
The Sustainability Appraisal does not focus on the recognised purposes of Green Belt land and contends that the development of Old Milverton and Blackdown would not lead to a coalescence of settlements. This is clearly incorrect as coalescence would be the direct outcome. Any development here would subsume Old Milverton and Blackdown into Leamington. It would be exactly what is happening right now at the other side of Leamington where Leamington has merged with Whitnash, and Whitnash is now merging with Bishops Tachbrook. This is precisely what the five purposes of Green Belt is designed to protect against. We are 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 enjoyed from using the footpaths as these will, no doubt, become pavements through a housing development. The Green Belt around North Leamington is a valued open space, with benefits for both physical and mental health of all who use it. It is easily accessible on foot from many parts of North Leamington so large numbers of people can access the public rights of way across the fields. These footpaths receive high levels of use throughout the year. The agricultural land provides rural employment and benefits from 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. There are clear recreational, educational and health benefits to be derived from use of this green belt land. Furthermore, the farmland is high quality agricultural land and makes an important contribution to sustainability and security of food supply. 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. It is essential that poorer quality land is used and high quality agricultural land is preserved.
argument 9, 1, 2 and 3 The assessment of sites at Appendix 3 concludes that the development in Old Milverton and Blacktown would lead to no coalescence of settlements, and only a minor negative impact on recreational experience. I believe this is wrong, and ignores the main purpose of designated GreenBelt, particularly in this location
This is horrendous to navigate as a general member of the public, as is the whole consultation. The council really needs to consider any lack of response on this as an indication of people not being able to read and understand it, rather than as acceptance or even apathy. I *think* my answer to this is that building on green belt land to the north of Leamington WILL lead to coalescence of settlements (with Kenilworth), which is precisely the purpose of green belt land. It will also have a huge impact on recreation, as this land is used by many for walking (for physical and mental wellbeing).
According to Section 3.5.2 of the Sustainability Appraisal of the South Warwickshire Local Plan, Kingswood as a New Settlement was proposed by the Councils in spite of the fact that it is largely Green Belt. This seems a strange decision in view of the fact that in his consideration of the Warwick District Local Plan in 2017 the Inspector said: "The adverse impacts of development on these sites would outweigh the benefits and exceptional circumstances for further alterations to the Green Belt do not exist."
The following comments are made in respect of the SA for Shipston-on-Stour, and specifically Broad Location B.19 Shipston-on-Stour Southwest. In assessing the four Broad Locations (BL) identified in Shipston-on-Stour against the SA Objectives, the SA concludes that Shipston-on-Stour West performs strongest, however this is strongly disputed as detailed in the following paragraphs. With regard to SA Objective 2: Flood Risk, the SA concludes that Shipston-on-Stour West is the best performing as it is wholly within Flood Zone 1. However, the extent to which the other Broad Locations are within Flood Zones 2 and 3 is described as negligible, and easily avoided. All BLs therefore perform equal, and this should be recognised in the next iteration of the SA. SA Objective 3 considers Biodiversity, Flora, Fauna and Geodiversity, with Shipston-on-Stour East considered to be the best performing Broad Location. However, there is no material difference between East and Southwest as all impacts are minor and easily avoided. East and Southwest BLs therefore perform equal, and this should be recognised in the next iteration of the SA. SA Objective 4 relates to Landscape, with Shipston-on-Stour Southwest and Shipston-on-Stour West considered to be the best performing Broad Locations. For information, initial landscape and visual impact technical work in relation to Land off Furze Hill Road, Shipston-on-Stour indicates that the site is within the lowest area of landscape sensitivity in the town, with impacts on views able to be negated through a landscape-led approach to masterplanning. These findings are also supported by the existing evidence base prepared for the Stratford Site Allocations Plan. SA Objective 5: Cultural Heritage concludes that Shipston-on-Stour West is the best performing Broad Location. Shipston-on-Stour Southwest is identified as having a potential impact on a number of Grade II Listed Buildings, however these are some distance from the Broad Location and any harm easily avoided. The Heritage and Settlement Sensitivity Assessment also finds that land to west and south-west of Shipston-on-Stour has potential for development in recognition of the lack of historic environment constraints. West and Southwest BLs therefore perform equal, and this should be recognised in the next iteration of the SA. With regard to SA Objective 6: Pollution, Shipston-on-Stour West is identified as the best performing Broad Location as it is the only one which does not coincide or fall adjacent to a watercourse. However, the extent to which the other Broad Locations are impacted by watercourses is described as minor, and easily avoided. All BLs therefore perform equal, and this should be recognised in the next iteration of the SA. SA Objective 7 relates to Natural Resources, with Shipston-on-Stour West performing best as it does not coincide with a Minerals Safeguarding Area (MSA), with all other Broad Locations in Shipston-on-Stour wholly or almost entirely being within a MSA. Given the Broad Locations actually perform relatively evenly and the need for future growth, this is considered to be a negligible difference. With regard to SA Objective 10: Health, Shipston-on-Stour North is recognised as the best performing as the majority of Broad Location is within the sustainable target distance to a leisure facility and it is also partly within the target distance for a GP Surgery. The distances from the Southwest are however not materially different, and this is considered to be a negligible difference. SA Objective 11: Accessibility selects Shipston-on-Stour East and North as the best performing Broad Locations. However, they score exactly the same as Southwest and therefore perform equal. This should be recognised in the next iteration of the SA. With regard to SA Objective 12: Education, Shipston-on-Stour North is considered the best performing Broad Location as, whilst all Broad Locations including Shipston-on-Stour Southwest fall within the target distance for primary and secondary education, Shipston North has the largest proportion which does so. The distances from the Southwest are however not materially different, and this is considered to be a negligible difference. Whilst Shipston-on-Stour North is considered to be the best performing Broad Location with relation to SA Objective 13: Economy, the distances from the Southwest are however not materially different. This is considered to be a negligible difference. The SA concludes that West is the least constrained in environmental terms, however this is marginal when compared to the Southwest. However, what is clear from the SA and Heritage Assessment is that areas to the East and Southeast is not suitable as a result of the setting of heritage assets. Further, areas to the North are more sensitive in landscape terms than areas to the West and Southwest. Therefore, whilst areas to the North might be marginally closer to facilities within the settlement, this is outweighed by the greater harm to the landscape. William Davis therefore consider the Southwest as the best performing option overall having regard to the above.
The following comments are made in respect of the SA for Shipston-on-Stour, and specifically Broad Location B.19 Shipston-on-Stour Southwest. In assessing the four Broad Locations (BL) identified in Shipston-on-Stour against the SA Objectives, the SA concludes that Shipston-on-Stour West performs strongest, however this is strongly disputed as detailed in the following paragraphs. With regard to SA Objective 2: Flood Risk, the SA concludes that Shipston-on-Stour West is the best performing as it is wholly within Flood Zone 1. However, the extent to which the other Broad Locations are within Flood Zones 2 and 3 is described as negligible, and easily avoided. All BLs therefore perform equal, and this should be recognised in the next iteration of the SA. SA Objective 3 considers Biodiversity, Flora, Fauna and Geodiversity, with Shipston-on-Stour East considered to be the best performing Broad Location. However, there is no material difference between East and Southwest as all impacts are minor and easily avoided. East and Southwest BLs therefore perform equal, and this should be recognised in the next iteration of the SA. SA Objective 4 relates to Landscape, with Shipston-on-Stour Southwest and Shipston-on-Stour West considered to be the best performing Broad Locations. For information, initial landscape and visual impact technical work in relation to Land off Furze Hill Road, Shipston-on-Stour indicates that the site is within the lowest area of landscape sensitivity in the town, with impacts on views able to be negated through a landscape-led approach to masterplanning. These findings are also supported by the existing evidence base prepared for the Stratford Site Allocations Plan. SA Objective 5: Cultural Heritage concludes that Shipston-on-Stour West is the best performing Broad Location. Shipston-on-Stour Southwest is identified as having a potential impact on a number of Grade II Listed Buildings, however these are some distance from the Broad Location and any harm easily avoided. The Heritage and Settlement Sensitivity Assessment also finds that land to west and south-west of Shipston-on-Stour has potential for development in recognition of the lack of historic environment constraints. West and Southwest BLs therefore perform equal, and this should be recognised in the next iteration of the SA. With regard to SA Objective 6: Pollution, Shipston-on-Stour West is identified as the best performing Broad Location as it is the only one which does not coincide or fall adjacent to a watercourse. However, the extent to which the other Broad Locations are impacted by watercourses is described as minor, and easily avoided. All BLs therefore perform equal, and this should be recognised in the next iteration of the SA. SA Objective 7 relates to Natural Resources, with Shipston-on-Stour West performing best as it does not coincide with a Minerals Safeguarding Area (MSA), with all other Broad Locations in Shipston-on-Stour wholly or almost entirely being within a MSA. Given the Broad Locations actually perform relatively evenly and the need for future growth, this is considered to be a negligible difference. With regard to SA Objective 10: Health, Shipston-on-Stour North is recognised as the best performing as the majority of Broad Location is within the sustainable target distance to a leisure facility and it is also partly within the target distance for a GP Surgery. The distances from the Southwest are however not materially different, and this is considered to be a negligible difference. SA Objective 11: Accessibility selects Shipston-on-Stour East and North as the best performing Broad Locations. However, they score exactly the same as Southwest and therefore perform equal. This should be recognised in the next iteration of the SA. With regard to SA Objective 12: Education, Shipston-on-Stour North is considered the best performing Broad Location as, whilst all Broad Locations including Shipston-on-Stour Southwest fall within the target distance for primary and secondary education, Shipston North has the largest proportion which does so. The distances from the Southwest are however not materially different, and this is considered to be a negligible difference. Whilst Shipston-on-Stour North is considered to be the best performing Broad Location with relation to SA Objective 13: Economy, the distances from the Southwest are however not materially different. This is considered to be a negligible difference. The SA concludes that West is the least constrained in environmental terms, however this is marginal when compared to the Southwest. However, what is clear from the SA and Heritage Assessment is that areas to the East and Southeast is not suitable as a result of the setting of heritage assets. Further, areas to the North are more sensitive in landscape terms than areas to the West and Southwest. Therefore, whilst areas to the North might be marginally closer to facilities within the settlement, this is outweighed by the greater harm to the landscape. William Davis therefore consider the Southwest as the best performing option overall having regard to the above.
Impact of development on the greenbelt is acknowledged but should be given greater weight than it seems to have been given here. NPPF is clear that development in the greenbelt should be avoided unless there are exceptional reasons, and given the extent of land within the area subject to this document which is not greenbelt, there can be no way that the relevant tests are met to establish the basis necessary for development in the greenbelt.
The green belt around North Leamington meets all the purposes of Green Belt land and this seems to be ignored in the Sustainability Appraisal. It clearly prevents the sprawl of Leamington and building on it would result in Old Milverton and Blackdown being subsumed into Leamington. Further to that it would result in the boundaries of Leamington and Kenilworth eventually merging. Development in this location would degrade the countryside and negatively impact on the setting of towns like Warwick whilst removing any incentive for developers to regenerate brownfield urban sites. The Sustainability Appraisal report perversely suggests that development of the North Leamington Green Belt would result in only a minor negative recreational impact. This claim is highly prejudicial since the current readily accessible footpaths would be absorbed by housing and turned effectively into urban streets. This land is used extensively by locals for recreational purposes and they can access it by walking without the need to drive. It provides a major health benefit with no negative environmental costs. The highest concentration of ALC Grade 2 land around Leamington Spa and Warwick is to the north and east of Leamington Spa. This land should be considered an important resource for sustainable food production. The National Planning Policy Framework recognizes this importance and directs local authorities to avoid building on such land. Given recent developments all should be aware of the need to ensure national security in all aspects and in keeping with this, good quality agricultural land should be protected and preserved for food production to ensure food security.
Volume 3, Appendix B of the Sustainability Appraisal is troubling. We have looked closely at the analyses for Royal Leamington Spa North East (B.12) and Royal Leamington Spa North West (B.13) and find a number of statements inaccurate or opaque, for example: B13.4 (page B76) says “This Broad Location is 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. Also at B13.4 we are told “a minor negative impact on the recreational experience associated with these, and surrounding, footpaths could be expected”. If this site is developed, there will no longer be any recreational experience to be had as the footpaths would become pavements through a housing development. We think it is therefore inaccurate to call this a ‘minor negative impact’. All of our concerns about the analysis in this document apply equally to sites B.12 and B.13.
2.6.10 notes that protected species surveys have not been used. 2.7.3 suggests that greenbelt purposes have not been considered. 2.7.8 suggests that landscape sensitivity and capacity studies may be helpful. There does not seem to be any form of evidence used regarding the development in greenbelt as a primary option which stands up to scrutiny. As such the SA seems to have been concocted on a whim and does not actually seem well thought through. The 5 purposes of greenbelt are a well considered and necessary constraint to developments for a variety of reasons; not least of which is to encourage the re-use of already developed land such as brownfield. There is often an inference in planning and development circles that greenbelt is a definition in its own right and that greenbelt land performs no other function that a barrier to development. In reality, greenbelt land is often productive rural land, involved in producing food as well as agricultural produce, leisure space and range of wildlife habitat. These contributions of such land should be considered in direct balance to the inconvenience that the headline designation is often considered to represent when deliberating the economic ease with which it could be developed. Development of greenbelt north of leamington would definitely lead to a future coalescence of the surrounding conurbations and irreversible harm to quality agricultural and rural land.
It is essential that all and any development is suitable for it's location, in size, style and scale. And that the voice of local residents are listened to. Please take into account that developers don't really care about the legacy they leave behind, in any location. Their remit is to build houses, sell them, make a profit and move on to the next! Any development should seek to enhance the locality, not diminish it in any way. And proper consideration needs to be given to the amount of extra traffic that every development will cause. Greenbelt land should be protected wherever possible and brown field sites should be incorporated wherever possible too. The attractiveness of South Warwickshire and its towns and villages must be protected at all costs, from profit hungry developers.
The Sustainability Appraisal/HEDNA for the Shipston on Stour Area is seriously flawed. There are substantial and significant errors, inaccuracies and assumptions in the Sustainability Appraisal/HEDNA for the Shipston on Stour area: B.17 Shipston on Stour East HEDNA Pages 639-644 B17.2, B17.3, B17.4, B17.10, B17.11, B17.12, B17.13 B.18 Shipston on Stour North HEDNA Pages 645-650 B18.3, B18.4, B18.5, B18.9, B18.10, B18.11, B18.12 B.19 Shipston on Stour Southwest HEDNA Pages 651-656 B19.2, B19.3, B19.4, B19.5, B19.6, B19.10, B19.11, B19.11, B19.12, B19.13 B.20 Shipston on Stour West HEDNA Pages 657-662 B20.2, B20.3, B20.4, B20.10, B20.11, B20.12, B20.13
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 neighboring 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.
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 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. 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. 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.
Accessibility in Kineton: why does "railway station" score ++. Your map shows a railway line into Kineton. This was the subject of the Beeching Cuts and parts are now built on. Also the route is via a major MoD location. Health in Kineton: Warwick Hospital is way over capacity given the new housing to the South of Warwick in the past five years and that with existing planning permission. Access to Primary School: why does Kineton score +? The school cannot cater for the needs of existing children in the village, most of who have to travel to Ettington or Tysoe by car producing significant carbon emissions. Climate adaptation appears to be neglected. This is likely to become a more pressing need and land within villages needs to be set aside for community orchards, community renewable energy facilities, etc.
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” (Appendix 3). 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. It is worth noting that the use of the footpaths in Old Milverton greatly increased during and after the pandemic and enable residents of north Leamington gain access to the countryside without using a car. 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. 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.
With respect to the Sustainabilty Appraisal. Appendix 3: pg B68 - location B12 (Blackdown) and pg B74 - location B13 (Old Milverton): 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 here is of 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.