The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt and to permit the proposed development have not been demonstrated by Warwick District Council ("WDC").

The proposed development of 250 is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton. Therefore this development will not support Coventry's housing need.

250 houses equates to an annual additional build requirement of only 19.2 houses over the remaining 13 years of the plan period. This is a very small number of houses which could be accommodated on other sites. Therefore, the harm caused to the green belt by this development by reason of inappropriateness outweighs any potential benefit.

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.
* The proposal is predicated on a significant increase in car parking charges as an attempt to change behaviour and will have a detrimental effect on the Leamington as a Town Centre.

The "safeguarding" of additional land, North of Milverton, for the development of a further 1100 is also to support Coventry's housing need in the future. Again there are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

Again, in practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

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


WDC has also stated that the "safeguarded land" North of Milverton could be used in the future to support Leamington's housing need. Warwick District Council has previously accepted that the Exceptional Circumstances necessary to remove this land from the Green Belt to support Leamington's housing need do not exist. There are other green field sites that are available, and deliverable which should be used in preference.

The modifications to the Local Plan do not fully address the Planning Inspector's concerns set out in his letter dated 1st June 2015 which include:
* the importance of considering commuting;
* the need to maximise effectiveness;
* a lack of detailed analysis;
* an absence of a clear strateg
* insufficient justification; and
* the overall conclusion that he Local Plan is not positively prepared, justified, effective or consistent with national policy


The land North of Milverton has enormous amenity value. If used for development the residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.

The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.

Highly productive farming land will be lost together with long established wild life habitat.

In total Warwick District Council has agreed to provide land for 6000 houses to meet Coventry's housing need. However the modifications propose that only 2245 of these houses will be close to Coventry. The remaining houses will be located in Kenilworth, Warwick and Leamington. WDC's proposal to encourage commuting (most of which will be by road) on this scale is irresponsible and bad planning.