Whilst acknowledging the need for additional housing during the period 2014-2029 the proposed modifications in their current form, does not meet the Planning Inspectorates instruction regarding HMA cooperation ii) ignores national planning policy guidelines for development of Green Belt, and (iii) does not recognise other development opportunities that are better suited to development and more consistent with sustainable growth objectives and evidence base.

Mod 14 Objections

Objection 1: Planning Inspectorate Instruction Correspondence Ref PIN/T3725/429/5 regarding Duty to Cooperate has not been met.
The engagement between the six different councils comprising the wider Coventry and Warwickshire Housing Market Area cannot be considered constructive. Specifically Warwick District Council and Coventry Council have not taken sufficient account of available and lower value Green Belt. Doing so would negate the need to remove Miverton from the Green Belt

Objection 2 A lack of consistent approach by Coventry City Council and Warwick District Council shows a lack of strategic cooperation
The Coventry Local Plan states
It should be clarified however that at the current time some of these sites are within the Coventry Green Belt and as such remain constrained by Green Belt policy until such time as the Local Plan is adopted. As such, these sites will not be considered readily available until such time as the land is removed from the Green Belt.
If WDC were to adopt a consistent approach with Coventry City Council then either Milverton would remain outside any consideration for removal from Green Belt, or Green Belt land within Coventry would be included and adopted into the Coventry Local Plan. In any event Milverton should be logically excluded from development if a consistent and cooperative approach were adopted.

The Joint Green Belt Study identifies Parcel RL1 (Milverton) as being of significantly higher value than other Green Belt land. More appropriate Green Belt land including BU3, BE1, BE4, BE5 and N6 in Nuneaton and Bedworth, C6 and LL2 in Rugby, KG3 in Warwick is identified by the JGB as being effectively 'infill' and would be well contained by existing significant features and the landscape.

Objection 3 Exceptional circumstances and planning conditions for developing the Green Belt at Milverton have not been met
As identified in Objection 1, the Coventry City Council has not taken into account available suitable Green Belt land when making its housing availability assessment. The Coventry City SLAA LP53 January 2016 identifies 29 different sites suitable for housing schemes greater than100 units which could provide 10,424 housing units in Coventry alone if taken into account. Considerable evidence exists to show that exceptional circumstances to remove Milverton from the Green Belt not been met and any attempt to do so would risk rejection of the modified Local Plan by the Planning Inspectorate.

Table 1: Potential additional housing availability in Coventry
Reference Hectares Housing potential (units)
Bab 2 9.38 247
Bab 8, 33 10.39 228




Bab 16 47.23 800
Bab 19 19.57 430
Bab 29
8.26
198

Bab 51a
10.0 225
Bab 51b 9.6 230
Bab 54 4.46 107
Bab 57 12.96 330
Bab 67 5.06 129
Bab 68 21.58 491
Bab 70 18.7 2250
Bab 29
8.26 198
BW 38 4.5 108
F54 18.25 450
H 8a and b 4.15 150
HE 14a, b, c 6 900
Ho10 30.1 790
Bab 29
8.26 198
L30 8.6 206
S4 2.96 110
S5 2.19 100
STM 27 1.56 300
STM 61 0.75 143
STM 64 1.99 440
STM 65 0.79 150
STM 41 0.75 143
WE 28 11.59 230
STM 41 0.75 143
TOTAL 10,424

Objection 4. The Joint memorandum of addressing unmet housing need of 14,000 homes in Coventry is unsound.
Coventry City Council's aspiration to improve the provision of the right quality housing to meet the needs of Coventry City's population (Local Plan Policy H1,H2, H3) and sustainable development (Policy DS3) would be better served by taking into account available low grade Green Belt and Green Field land shown in
table 1 and reducing the burden on inappropriate development in more distant neighbouring areas. Doing so would sustain the functional link between housing and work thereby contributing to the wider aspirations of health and well-being of the population detailed in the Coventry's Local Plan.

Objection 5. Proposed building of houses in Leamington to meet the needs of Coventry people does not meet National Planning Policy Framework Guidance note 49
Whilst accepting the need to cooperate to meet unfulfilled housing need in the wider housing Market area, (modification 2, 15 Para 2.6) proposals must also comply with NPPF. The proposal to build at Milverton does not stand up to the test of presumption of sustainable development particularly when other more suitable sites exists. (See table 1).


Objection 6 Enroachment/Coalescence of Leamington Spa and Old Milverton
The development of East Milverton does not comply with National Planning Policy Framework March 2012 guideline chapter 9, Paragraph 85, point 6 and Planning Practise Guidance Section 9 note 80 as it its fails to provide clearly defined permanent boundaries for Green Belt and would enable and likely lead to the future coalescence of Milverton village, which would be in direct contravention of three of the five stated purposes of Green Belt. This view is upheld by the Joint Green Belt Study January 2016 which states:

The parcel RL1 prevents Leamington Spa adjacent to the southern edge of the parcel from merging with the small village of Old Milverton adjacent to the western edge of the parcel on the other side of the railway line which runs along this edge of the parcel. Although the railway line plays a separating role development along the eastern side of the line up to Sandy Lane would effectively merge these two settlements.


Objection 7 Developing East Milverton is not consistent with NLP objective (4.12.4). help the public access and enjoy open spaces...reduce the risk of flooding; keep the effects of climate change (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles.

The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies North Milverton (L07) is a Green Belt site of medium value. Other assessment referred to within the Landscape Character Assessment for Land South of Leamington and Warwick show the North Milverton Green Belt as being of high value, in contrast, for example, to part of the Blackdown site adjacent to Sandy Lane (referred to as WL6a/b in this document and shown to be of medium value). The Milverton site is enjoyed by a wide section of the community, it is an important asset in supporting healthy lifestyles for residents and visitors of all ages - whether it be walking, running or cycling. The public footpath that transverses the site provides a valuable access point from Leamington to the Warwickshire country side and should be protected.


There are strong grounds for environmental concern regarding proposed development of the site.
The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies that:
* a part of the site falls within a flood zone 3A and implicitly should not be developed;
* it contains a Water Source Protection Zone and an area of Groundwater Vulnerability, which would require consultation with and permission from the Environment Agency before any encroaching development. We know from a past pollution incident from the Nuffield Hospital, and related correspondence, that the Environmental Agency view this Zone/area with extreme seriousness.
* it would result in the extensive loss of Grade 2 agricultural land which both contributes to a sustainable economy and to the character of the landscape.

Other opportunities to meet HMA requirement
In the event that Green Field/Green Belt land should be required, then the 269.2 hectares of land at Kings Hill Lane (Warwick District Council SHLAA Ref C06 should be planned to best meet the needs of Coventry's housing. This approach combined with Green Belt land identified in the Coventry SHLAA offers a more sustainable approach to meeting housing need and protects valuable agricultural land without the requirement for expensive and unsound transport infrastructure projects.

Hopefully from the objections and suggestions I have made, coupled with a further review of the WDC, Coventry City Council HMA and Joint Green Belt Study evidence base, you will recognise that there is no justification for developing Milverton and should flexibility in the plan be required, other more suitable sites for development exist within the District.

Mod 16 Objections
The proposed park-and-ride scheme is unsustainable because:
There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The land North of Milverton should remain in the Green Belt
The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.