I wish to take advantage of the opportunity being offered to local residents to comment on the Local Plan Preferred Options that are currently under consideration by Warwick District Council.
I am a member of Cubbington Parish Council, representing Cubbington North Ward where aspects of the proposal are causing great concern. I should make it clear that, while I am commenting in my capacity as a councillor representing a ward which is directly affected by the proposal, the views expressed below are my own and are not made on behalf of Cubbington Parish Council.
I wish to comment upon Preferred Option PO16 "Green Belt" and, in particular, proposals for two large housing developments on Green Belt land, identified as Milverton Gardens and Blackdown, and to make, as yet unspecified, changes to the Green Belt boundaries around Cubbington in order to allow further housing development around the village. The Blackdown development would extend into Cubbington North Ward and is, accordingly, a direct concern, as is the redrawing of our Green Belt boundaries. The Milverton development would also be likely to have indirect impacts on residents of Cubbington North Ward, in particular in increased traffic flows on roads in the general area.
"For the last fifty years, green belts have acted as one of the best known and most popular planning tools for protecting our countryside. They still command widespread public support. Although we can never know for certain what would have happened in the West Midlands without them it is likely that the geography of the region would be very different - and not for the better. They have preserved sharp distinctions between urban and rural areas, encouraged development in cities and towns instead of allowing it to sprawl outwards, and prevented towns and cities from coalescing and losing their separate identities."
This is the judgement of CPRE West Midlands, as expressed in the Introduction to its June 2007 publication What Price West Midlands Green Belts? (http://www.cprewm.org.uk/GreenBelt%2002.07.07.pdf).
That the CPRE is right in its assumption that the green belt concept "still commands widespread public support" is evident from the reaction that the Council's plans have engendered in the communities of Old Milverton, Blackdown and Cubbington.
Up until now the general presumption has been that new housing development within the Green Belt was "inappropriate" and, as far as I understand it, this policy has been enforced by Warwick District Council. However, the proposals in the May 2012 WDC publication Local Plan Preferred Options appear to signal a total departure from this principle and risk undoing much of the good work of the last fifty years.
Paragraph 80 of national Planning Policy Framework (NPPF) lists one of the five purposes of Green Belt as "to check the unrestricted sprawl of large built-up areas". Map 4 that is appended to the May 2012 document Local Plan Preferred Options shows the proposed housing development sites as ringing the Leamington Spa/Warwick urban area in what appears to be a "text book" illustration of urban sprawl.
Paragraph 80 of the NPPF identifies another purpose of the Green Belt as "to prevent neighbouring towns merging into one another". The Green Belt north-west of Cubbington provides such a buffer between Leamington Spa and Kenilworth. The proposed Milverton Gardens and Blackdown developments will eat significantly into the green strip dividing these two towns.
Paragraph 85 of the NPPF requires local authorities to "define boundaries clearly, using physical features that are readily recognisable and likely to be permanent". The current Green Belt boundary in Cubbington North Ward is the A445, and this seems an appropriate demarcation line being, at this point, a town road with extensive urban development on one side. If the Blackdown development takes place, this demarcation line will become the B4113, which is clearly a country road currently unsullied by development.
Paragraphs 87 and 88 of the NPPF warn against the damage that "inappropriate development" can cause to the Green Belt and that development in Green Belt should only be approved "in very special circumstances". Such special circumstances, we are told, "will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations". With the exception of certain types of building, which are listed in paragraph 89 of the NPPF, we are told that "a local planning authority should regard the construction of new buildings as inappropriate in Green Belt". New housing is not one of the exceptions permitted by the NPPF.
I have read carefully the "justification" in chapter 7 of Local Plan Preferred Options and feel that this document signally fails to demonstrate the existence of "very special circumstances" that justify large-scale building on the Green Belt. In particular, paragraph 7.29 indicates that sufficient land to satisfy the identified housing needs can be provided without any incursion into the Green Belt. The unique status of the Green Belt should protect it from development when there is an alternative, and this alternative clearly exists.
Also, paragraph 7.32 of Local Plan Preferred Options appears to indicate that an earlier study (Joint Green Belt Study) suggested that the site of the proposed Blackdown development was "not suitable for further study". Why then has it been included in the Preferred Options?
I find it particularly inappropriate to propose the construction of a Park and Ride car park on Green Belt land.
The NPPF defines "sustainable development" as that which meets "the needs of the present without compromising the ability of future generations to meet their own needs". The proposed developments at Milverton Gardens and Blackdown clearly fail this test, as their realisation would clearly deprive future generations of a significant part of the Green Belt protection that the present residents of Cubbington North Ward enjoy.
In conclusion, I find it particularly ironic that Warwick District Council has responded to the threat to our countryside posed by HS2 by rigorously opposing it, taking a prominent role in the 51m alliance of local authorities. Yet this same authority is proposing to inflict damage on Green Belt land that lies within a kilometre or so of the Green Belt land that HS2 will consume. Surely, this is irrational and inconsistent behaviour.