Object
Preferred Options
Representation ID: 46782
Received: 23/07/2012
Respondent: Mrs Louise Wilks
Proposed development of Milverton site is non-compliant against three aspects of the NPPF.
(i) exceptional circumstances - not justified by WDC's own evidence base
(ii) well defined boundary - does not exist on western edge and thus enables future coalesence with Old Milverton
(iii) development of agriculture and land based business in rural areas - loss of Grade 2 agricultural land covering the site.
Documents within WDC's evidence base (e.g. SHLAA, JGBS, ISA and STAOR) clearly demonstrate there are more suitable and less environmentally sensitive alternative sites on non-Green Belt and lesser valued Green Belt not yet in the Local Plan.
Milverton site is not justified for development on three aspects of non-compliance with the NPPF.
Level of Green Belt development in Local Plan is not consistent with "exceptional circumstances" as (a) total development (8400) exceeds 7000 SHMA deems is required; (b) there is less development of non-Green Belt land than the SHLAA identifies as viable and two options the STAOR shows have equal impact on transport mitigation costs and outcomes.
East Milverton site identified in Map 2 of the Local Pkan consultation has no well defined boundary on western edge - if extended to include West Milverton it coalesces Old Milverton. Each is non-compliant with NPPF requirements for GreenBelt development.
Also in the NPPF it states development of rural areas should promote development of agricultural and/or land based business. However development of the Milverton site would destroy Grade 2 agricultural land which forms the ast majority of the site.
The development of the Milverton site risks major detrimental environmental impact as (a) part of the site is classed as a category 3A Flood Risk Zone; (b) the site is within a Water Source Protection Zone and (c) the site cxontains an area of Groundwater Vulnerability. Each of these classification introduces the oversight of the Environment Agency. Given the seriousness with which the Environment Agency viewed a previous pollution incident on the site, we would expect them to have very strong concerns to development of the site; but in generla from a nenvironm,ental and sustainability perspective it is clearly more appropriate to develop other less environmentally sensitive sites.
Finally, it is also clear from the Evidence Base e.g. JGBS, SHLAA, STAOR Landscape assessment for South Leamington & Warwick, that there are alternative site on both non-Green Belt (South of Harbury Lane) and lesser value and more NPPF compliant Green Belt (Glasshouse Lane/Crewe Lane, Woodside Management Centre) which are more suitable against WDC's own stated objectives for the Local Plan (e.g. on distribution of growth, and sustainability) and NPPF guidance.