I would argue that the decision to remove the land to the North of Milverton from the Green Belt for development is not justified, is not effective and is not consistent with the National Planning Policy Framework.
It is not justified because removing the land to the north of Milverton from the Green Belt and developing 250 dwellings and "Safeguarding" further land for future development does not meet Coventry's Housing Need. Clearly, the most sustainable locations to meet Coventry's Housing Need will be those closest to Coventry and with easy access to that city.
It is clear that Coventry City Council acknowledges this within its own emerging Local Plan, when it states: "The Council is committed to continued and constructive engagement, through the Duty to Cooperate, with its Warwickshire neighbours to secure the most appropriate and sustainable locations for housing growth across the HMA. In reflection of the Warwickshire authorities supporting the delivery of the city's wider housing need, where it is shown to be desirable, appropriate, sustainable and deliverable the Council will support its Warwickshire neighbours in bringing forward land for housing and employment that sits adjacent to the city's existing administrative boundaries [my italics]. This will ensure infrastructure needs are met in full across administrative boundaries (where necessary and as appropriate) and support the continued growth of the city as the central point of the sub-region." Clearly, the land to the North of Milverton is not adjacent to the City's existing boundaries.
For reasons of sustainability, and to improve air quality, Coventry City Council in its emerging Local Plan states it is keen to cut down on car journeys to work. Of the relatively small percentage (12.3%) of Milverton residents who work in Coventry, the overwhelming majority (88.72%) commute by car and none by train. It is clear that developing the land to the north of Milverton will do nothing to meet Coventry's housing need and does not meet the City Council's requirements for sustainable development. In DS New 1 of Coventry City Council's Local Plan they state: "A reduced need to travel will promote increased levels of walking, cycling and use of public transport. This will contribute towards reduced carbon emissions and improve the urban environment. This will have a positive effect on public health and wellbeing." I have to agree with this statement. The proposal by Warwick District Council for the land to the North of Milverton would increase car journeys with all the adverse effects that implies.
As for the economic growth that Coventry wishes to pursue, the removal of land from the Green Belt to the north of Milverton will not help Coventry's needs. Indeed in DS1 New of Coventry City Council's Local Plan it states there is a risk of development beyond its boundaries: "There is a risk that new homes, employment, retail and leisure opportunities will be developed outside of the city. This could see investment diverted elsewhere and put at risk the city centre regeneration strategy." Building to the north of Milverton does nothing to alleviate that risk to Coventry. Indeed, given the competing nature of Leamington's town centre, it increases that risk.
Warwick District Council claims that it has used a three-stage approach to decide on the Exceptional Circumstances on any particular site in the Green Belt:

1. Is there an essential need that has to be met? If yes,
2. are there any suitable sites outside the Green Belt that can meet this need? If no,
3. is this the best site within the Green Belt to meet the need (taking account of the Green Belt study as well as other aspects of the site assessments)? If yes, then there are exceptional circumstances to release a site from the Green Belt and allocate it in the Local Plan.
Given Coventry's housing need, Warwick District Council has to show there is an essential need that has to be met. Given that all the land to the north of Leamington and Warwick is in the Green Belt, it is difficult to see how Coventry's identified housing needs can be met without using some Green Belt land within Coventry's own boundaries or within Warwick District. But the vital question is the third one, are there exceptional circumstances to release a particular site from the Green Belt and allocate it to the Local Plan? The District Council does not provide evidence that it has assessed the sites in order of their contribution to the Green Belt.
Warwick District Council appears to rely on deliverability as an argument as to why less than half of Coventry's Housing Need that it is taking within Warwick District's boundaries is to be built adjacent to Coventry. WDC argues that although the King's Hill site can take more than 4,000 dwellings in land adjacent to Coventry, developers cannot deliver more than 1,800 there within the time frame. Given that the most of the land to the north of Milverton that is to be removed from the Green Belt is to be safeguarded and possibly used after the 5-year review, that would suggest it is basically being held in reserve should Coventry's housing need be greater than expected. That would suggest that, as elsewhere in the country, it should be possible in that case to deliver quite considerably more than 200 dwellings per annum on a site such as King's Hill that is adjacent to Coventry. Indeed in other parts of the country on sites of 3,000 or more as many as 500 houses a year have been deliverable.
Warwick District Council does not provide significant evidence to back up its claim that there are not sufficient deliverable sites on the edge of Coventry. In essence it makes a statement without backing that up with the evidence.
The proposed park-and-ride scheme to the North of Milverton does not appear to be evidence based. A senior Council officer at Warwick District has stated in public at a recent joint meeting of the Overview and Scrutiny Committee and the Finance and Audit Committee that: "In the Local Plan there is possible provision for Park and Ride. For Park and Ride to be viable you have to take out car parking capacity from the town centre." This was a meeting in which a major proposal was the replacing of an existing car park with a new and enlarged car park. Leamington Spa is not an old medieval town with narrow streets and little on-street car parking. It is a town built on a grid pattern with wide streets and plenty of on-street car parking. I would suggest that the proposed Park & Ride is not viable. I would also suggest that any attempt to try and make it viable by a substantial increase in car parking fees or closing of car parks would have serious effects on the economic success of the town's economy.
Warwick District Council has failed to provide the "Exceptional Circumstances" required to remove the land to the north of Milverton from the Green Belt and is therefore not consistent with the National Planning Policy Framework. It is also neither effective nor justified.
Warwick District Council claims that it has used a three-stage approach to decide on the Exceptional Circumstances on any particular site in the Green Belt:

4. Is there an essential need that has to be met? If yes,
5. are there any suitable sites outside the Green Belt that can meet this need? If no,
6. is this the best site within the Green Belt to meet the need (taking account of the Green Belt study as well as other aspects of the site assessments)? If yes, then there are exceptional circumstances to release a site from the Green Belt and allocate it in the Local Plan.
Given Coventry's housing need, Warwick District Council has to show there is an essential need that has to be met. Given that all the land to the north of Leamington and Warwick is in the Green Belt, it is difficult to see how Coventry's identified housing needs can be met without using some Green Belt land within Coventry's own boundaries or within Warwick District. But the vital question is the third one, are there exceptional circumstances to release a particular site from the Green Belt and allocate it to the Local Plan? The District Council does not provide evidence that it has assessed the sites in order of their contribution to the Green Belt.
Warwick District Council appears to rely on deliverability as an argument as to why less than half of Coventry's Housing Need that it is taking within Warwick District's boundaries is to be built adjacent to Coventry. WDC argues that although the King's Hill site can take more than 4,000 dwellings in land adjacent to Coventry, developers cannot deliver more than 1,800 there within the time frame. Given that the most of the land to the north of Milverton that is to be removed from the Green Belt is to be safeguarded and possibly used after the 5-year review, that would suggest it is basically being held in reserve should Coventry's housing need be greater than expected. That would suggest that, as elsewhere in the country, it should be possible in that case to deliver quite considerably more than 200 dwellings per annum on a site such as King's Hill that is adjacent to Coventry. Indeed in other parts of the country on sites of 3,000 or more as many as 500 houses a year have been deliverable.
Warwick District Council does not provide significant evidence to back up its claim that there are not sufficient deliverable sites on the edge of Coventry. In essence it makes a statement without backing that up with the evidence.
Within the Local Plan it mentions that a railway station could be built at Old Milverton. This seems to have been chosen without any meaningful discussion with the County Council that has for some time been working on the 'Knuckle' project. A new station is being built at Kenilworth but no suggestion has been made about a station at Old Milverton. The evidence that is available suggests that nobody in Milverton uses the train at the moment to commute to Coventry. In all my years as a District and County Councillor, no resident has suggested opening a new station at Old Milverton. A railway station is also unviable because the railway line is in a deep cutting in Old Milverton, making construction impractical.
District Council has also failed to provide the "Exceptional Circumstances" required to remove the safeguarded land to the north of Milverton from the Green Belt and is therefore again not consistent with the National Planning Policy Framework. It is also neither effective nor justified.
In summary, in order for Modifications 14 and 16 of Warwick District's Local Plan to be sound, the land to the north of Milverton would have to remain in the Green Belt. Warwick District Council has not provided the evidence of Exceptional Circumstances to justify removing the land to the north of Milverton from the Green Belt. There are sites adjacent to Coventry that could meet Coventry's Housing need and are deliverable.