We do not consider the Local Plan is sound because modifications 14 and 16 are not justified, effective and consistent with national policy.
We do not believe that modifications 16 and 14 are sound because:
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.
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.
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 North of milverton.
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.
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 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 dependent on a significant increase in car parking charges in Leamington.
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

We believe that in order for Modification 16 and 14 to become sound:
The land North of Milverton should remain 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.