The proposed plan does not give a strong enough justification for alteration of the Green Belt to allow development within this area.

The network of public footpaths across the fields give this area great amenity value. These footpaths are always busy with people walking dogs or running and are paticularly valuable as there are no other easily accessible open areas on the north edge of Leamington and no other public footpaths further to the north which could be used instead if this area was developed.

The nearby road network is also insufficient to support this size of development, particularly if Blackdown is also developed. The A452 north to the A46 and south to the centre of Leamington are regularly jammed and old Milverton road is narrow and would become dangerous with increased levels of traffic. This road passes close to schools and is already subject to traffic calming/safety measures.

Section 7.31 states that "employment areas are currently concentrated in the south of Leamington, leading to many cross town centre trips". Even if as proposed some allocation was made for employment within the development there would not be enough to support a combined total of 1,980 new houses (Milverton and Blackdown). This would therefore lead to an increase in the number of cross town centre trips and increase congestion.

Development to the north of Leamington is also poorly situated for access to both public transport and the to the trunk road network. The A452 to the A46 is always busy and is a long and circuitous route to the M40 and the south. The Milverton and Blackdown options are also two of the furthest from railway stations which would provide a more sustainable transport link.

For these reasons development at Milverton and Blackdown would only be feasible in conjunction with construction of the Northern Relief Road. It is therefore disingenuous not to include the roue of the relief road within any proposals for development on the north side of Leamington.

The Northern Relief Road would require a crossing over the River Avon and its floodplain, possibly the most ecologically valuable feature within the local area. Light, noise and runoff from the road corridor as well as the physical severance could potentially cause significant impacts to the valuable riparian habitat and species present. The River Avon is a Local Wildlife Site as well as supporting Biodiversity Action Plan (BAP) habitats and protected and notable species. Species present and reliant upon the river corridor which would be subject to disturbance could include otter (European protected Species), numerous species of bat (all European Protected Species), Kingfisher (Wildlife & Countryside Act 1981, Schedule 1) as well as numerous other species listed on the UK or Local Biodiversity Action Plan species.

Policy PO15 Green Infrastructure - Green Wedges states - "The Council will identify and protect a network of green wedges important for their ecological, landscape and/or access functions in the setting of differing urban areas and urban rural fringe"
One of the largest areas identified and shown on Map 6 covers the River Avon corridor which would be severed by the Northern Relief Road. Therefore these two policies are directly contradictory. Any severance of the River Avon corridor by a new road would cause signifcant harm to the green infrastructure value of this area.

In addition to potential ecological impacts the Northern Relief Road would cause great disturbance to the current residents of Old Milverton through noise and light spill and significantly alter the character of the area.