1) The Exceptional Circumstances required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.

2) The proposed development 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.

3) 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.

4) Precedence for releasing land from the Green Belt requires the "value" of potential sites in the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in co-operation 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.

5) The rural gap between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

6) The attractive northern approach to Leamington Spa will be adversely affected.

7) Good farming land will be lost together with long established wild life habitat.

8) The residents of local towns will be deprived of an area which is highly valued and regularly used for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.



9) The proposed park-and-ride scheme is impractical because:-

a) There will be no dedicated buses, so users will have to time arrivals to coincide with the bus timetable.

b) 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.

c) Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers

d) Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington

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



As a solution 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 in a more convenient location for the residents.