Both a letter setting out our representation, and a supporting document providing detailed arguments and supporting evidence is provided as part of this representation. However, for the purpose of this online submission we outline our major points below:

(1) Unsubstantiated housing requirements:

The level of housing identified in the plan is in excess of need, and fails to fully take into account windfall sites. Whilst flexibility is required, the assumptions within the housing model sufficiently cater for this at this stage.

(2) Exceptional circumstances and planning conditions for development on Green Belt have not been met.

The development of east Milverton does not comply with the National Planning Policy Framework (ch9, para 85), with failure to identify clearly defined permanent boundaries. Development is likely to lead to the coalesence of Old Milverton Village

The plan should seek to develop non green belt land first such as land south of Harbury Lane identified in the 2010 local plan.

Any use of green belt land should be in order of lowest landscape value first. East Milverton has been identified as having a higher landscape value than the Kenilworth sites bordered by Crewe Lane and Glasshouse Lane for example. These sites are not included in the Local Plan which brings into question the validity of the selection of areas/sites for housing development.

(3) Failure to ensure new developments are appropriately distributed across the district

Re-balancing growth towards Kenilworth, South Harbury Lane offers significant benefits to that of East Milverton. Kenilworth development is consistent with the identified need to greater diversify the demographics, better geographical housing distribution, allows for the development of clearly bounded green belt, and forms a key part of any sustainable solution to deliver jobs at the University of Warwick and the Gateway.

South Harbury Lane is non green belt land, allows for better sustainable travel options, more favourable access to facilities, no adverse impact on transport options and recognises that growth in employment will also occur outside of Leamington - Jaguar Landrover, Birmingham - allowing for easier access to M40.

Concentrated development south of Leamington Spa is unlikely to result in issues with respect to resources, timings and ability to deliver. This is an issue of scale rather than location. Delivery of the identified housing need is contingent on the availability of builders and not their location per se. WDC has presented no evidence in their LP consultation document nor in any other document within the Evidence Base to support its assertions in para 7.30

(4) Development of East Milverton is inconsistent with NLP objective - help public to enjoy and access public spaces ....reduce risk of flooding (4.12.4)

The East Milverton site is enjoyed by a broad cross section of the community - walkers, runners, cyclists - supporting healthly lifestyles. The same level of use is not evident in other sites within Leamington - South Harbury Lane for example. The land is also Grade 2 agricutlural land which not only provides the landscape with its character but also should be recognised as a key part of a sustainable local economy.

The site also falls within the flood zone 3a, and contains both a water source protection zone and an area of groundwater vulnerability which from past experience of a pollution incident the Environment Agency view with utmost seriousness.