North of Milverton, Leamington Spa

Continuing urban development on green belt for the sake of economic growth, is not sustainable. The argument that to grow the local economy you must enlarge towns and build on greenbelt land is clearly at odds with itself because to grow would require building on greenbelt in to the future. As population increases, so more greenbelt is taken up by development. The cycle goes on and on until there is no greenbelt left.

Having managed a commercial town centre property for two and a half years, in town development must be the focus. The high street is going through huge changes as internet shopping and out of town retail parks make town centre shopping expensive, difficult and time consuming in comparison. Town centre development would help to regenerate urban areas and possibly kick start an otherwise failing high street as competition from e-commerce, supermarket development and out-of-town retail parks increases. The further out of town you build, the less likely it is that inhabitants are to travel to the town centre because it's easier to go on line, to a large supermarket or to an out of town retail park. The local authority loses out because town centre properties will remain void and void rates will continue to climb. Redeveloping old properties in to habitable dwellings makes a lot more sense despite being more problematic - and should be in addition to developing new property on derelict or brown field sites. More should be done to investigate these options.

In addition to all of this, oil prices mean that the cost of owning and driving a car will become even more expensive, despite the recent drop in oil prices. Therefore, any affordable housing should be centrally located for links to public transport. Better provision for cycle lanes and footpaths would lower the number of cross town trips as mentioned in the planning document, thereby reducing the volume of traffic.

The Local Plan proposes to develop green belt land when alternative locations are available that will not encroach on green belt land.

The infrastructure is currently not capable of supporting additional development without the need for further improvements which themselves will require development on green belt land.

Over development of green belt land in an area lacking sufficient infrastructure to deal with projected population. Northern relief road would not properly address the transport problems which would result, and cause grtidlocking of Kenilworth Rd, Rugby Rd, Emscote Rd etc.
Loss of valuable amenity land in an area lacking public open space.

This site is in Green Belt!
The National Planning Policy Framework makes clear that inappropriate development is harmful to the Green Belt and 'should not be approved except in very special circumstances'. It goes on to say that construction of new buildings should be regarded as inappropriate with a list of exceptions that do not include new housing!
The Council has not demonstrated 'very special circumstances'; indeed the authority's own documents show ample suitable land is available without the need to violate the Green Belt.

Paving over of viable farm-land in this manner is counter productive, both in terms of rural productivity and amenity to residents bordering the land. The traffic would mainly head south, accross town, up sandly lane to the rugby road or down the relief road to J15 - through a village and housing estates with a pedestrian route feeding 2 schools. Very few of the houses proposed here would service the enterprise areas north of leamington.

This development is not only greenbelt it is the narrow strip of greenbelt which prevents urban sprawl. This area must be protected. We do not want to see Leamington sprawl into Kenilworth absorbing the small villages into a mass of development. This area of greenbelt already provides easily accessible walking and cycling opportunity for the residents in a natural rural setting. It is astonishing that it could ever be considered reasonable to consider developing this area.

This proposed site is on "protected" Green Belt.

The National Planning Policy Framework makes it clear that inappropriate development is harmful to the Green Belt and 'should not be approved except in very special circumstances'.

The Council has not demonstrated 'very special circumstances'; indeed the authority's own documents show ample suitable land is available without the need to violate the Green Belt.

The Green Belt land to the North of Leamington Spa is a useful amenity to both me and my young children and provides useful recreational space to enable them and me to get an appreciation of the outdoors and the benefits of exercise

This is a great area enjoyed by many for a variety of activities. Walkers, riders, cyclists, bird watchers etc. There effects on the wild life in this area are not explained adequately. NPPF states if proposing a new Green Belt, local planning authorities should demonstrate why normal planning and development management policies would not be adequate and the exceptional circumstances that are required to change the existing green belt.
The Council can use the normal planning policies which are adequate and they have not shown the exceptional circumstances that are required to change the existing green belt.

This is not sustainable development because the sites are not big enough to sustain their own schools, shopping and community facilities. There is no sustainable transport option, the Northern Relief Road proposed is contrary to sustainable travel.

I strongly object to the proposal to develop north of Milverton because it does not comply with the Government's National Planning Policy Framework for development in the Green Belt. The plan is unsound for numerous reasons, not least because the council itself, in 2009, identified that there were alternatives to developing the Green Belt. So far it has failed to explain what exactly has changed in order to justify this significant about-turn.
This land has enormous physical and visual amenity value, as well as high agricultural value. It should be accorded a higher priority than brownfield and white belt sites.

It Wouk spoil the green belt & distinction between Leamington & Kenikworth.

The proposed development to the north of Warwick and Leamington is wrong in principle. The location doesn't have the infrastructure to support it, and will require the building of a new road and bridge over the Avon. An infrastructure project on this scale will then be used to justify further development, leading to the coalesence of communities - Warwick and Leek Wootton, Leamington, Hill Wootton and Kenilworth.
This flies in the face of national Green Belt policy and the declared aims of the Preferred Options. It also looks to be unsustainable with regards to transport.

I wish to object to the prop0sed development. It is wrong to destroy a rural community when there must be plenty of brownfield sites and out of date housing estates that could be redeveloped. The area around Old Milverton is a delightful area of old english countryside that should be protected and cherished, not sacrificed for the sake of quick profit. Please do not develop here. Although I live in South Yorkshire I visit Old Milverton and have family there.

Both a letter setting out our representation, and a supporting document providing detailed arguments and supporting evidence is provided as part of this representation. However, for the purpose of this online submission we outline our major points below:

(1) Unsubstantiated housing requirements:

The level of housing identified in the plan is in excess of need, and fails to fully take into account windfall sites. Whilst flexibility is required, the assumptions within the housing model sufficiently cater for this at this stage.

(2) Exceptional circumstances and planning conditions for development on Green Belt have not been met.

The development of east Milverton does not comply with the National Planning Policy Framework (ch9, para 85), with failure to identify clearly defined permanent boundaries. Development is likely to lead to the coalesence of Old Milverton Village

The plan should seek to develop non green belt land first such as land south of Harbury Lane identified in the 2010 local plan.

Any use of green belt land should be in order of lowest landscape value first. East Milverton has been identified as having a higher landscape value than the Kenilworth sites bordered by Crewe Lane and Glasshouse Lane for example. These sites are not included in the Local Plan which brings into question the validity of the selection of areas/sites for housing development.

(3) Failure to ensure new developments are appropriately distributed across the district

Re-balancing growth towards Kenilworth, South Harbury Lane offers significant benefits to that of East Milverton. Kenilworth development is consistent with the identified need to greater diversify the demographics, better geographical housing distribution, allows for the development of clearly bounded green belt, and forms a key part of any sustainable solution to deliver jobs at the University of Warwick and the Gateway.

South Harbury Lane is non green belt land, allows for better sustainable travel options, more favourable access to facilities, no adverse impact on transport options and recognises that growth in employment will also occur outside of Leamington - Jaguar Landrover, Birmingham - allowing for easier access to M40.

Concentrated development south of Leamington Spa is unlikely to result in issues with respect to resources, timings and ability to deliver. This is an issue of scale rather than location. Delivery of the identified housing need is contingent on the availability of builders and not their location per se. WDC has presented no evidence in their LP consultation document nor in any other document within the Evidence Base to support its assertions in para 7.30

(4) Development of East Milverton is inconsistent with NLP objective - help public to enjoy and access public spaces ....reduce risk of flooding (4.12.4)

The East Milverton site is enjoyed by a broad cross section of the community - walkers, runners, cyclists - supporting healthly lifestyles. The same level of use is not evident in other sites within Leamington - South Harbury Lane for example. The land is also Grade 2 agricutlural land which not only provides the landscape with its character but also should be recognised as a key part of a sustainable local economy.

The site also falls within the flood zone 3a, and contains both a water source protection zone and an area of groundwater vulnerability which from past experience of a pollution incident the Environment Agency view with utmost seriousness.

Milverton site is not justified for development on three aspects of non-compliance with the NPPF.

Level of Green Belt development in Local Plan is not consistent with "exceptional circumstances" as (a) total development (8400) exceeds 7000 SHMA deems is required; (b) there is less development of non-Green Belt land than the SHLAA identifies as viable and two options the STAOR shows have equal impact on transport mitigation costs and outcomes.

East Milverton site identified in Map 2 of the Local Pkan consultation has no well defined boundary on western edge - if extended to include West Milverton it coalesces Old Milverton. Each is non-compliant with NPPF requirements for GreenBelt development.

Also in the NPPF it states development of rural areas should promote development of agricultural and/or land based business. However development of the Milverton site would destroy Grade 2 agricultural land which forms the ast majority of the site.

The development of the Milverton site risks major detrimental environmental impact as (a) part of the site is classed as a category 3A Flood Risk Zone; (b) the site is within a Water Source Protection Zone and (c) the site cxontains an area of Groundwater Vulnerability. Each of these classification introduces the oversight of the Environment Agency. Given the seriousness with which the Environment Agency viewed a previous pollution incident on the site, we would expect them to have very strong concerns to development of the site; but in generla from a nenvironm,ental and sustainability perspective it is clearly more appropriate to develop other less environmentally sensitive sites.

Finally, it is also clear from the Evidence Base e.g. JGBS, SHLAA, STAOR Landscape assessment for South Leamington & Warwick, that there are alternative site on both non-Green Belt (South of Harbury Lane) and lesser value and more NPPF compliant Green Belt (Glasshouse Lane/Crewe Lane, Woodside Management Centre) which are more suitable against WDC's own stated objectives for the Local Plan (e.g. on distribution of growth, and sustainability) and NPPF guidance.

* We believe that 'exceptional circumstance' justifying the proposal to build on Green Belt land in this area has not been proven - there are other suitable/available sites outside the Green Belt which do accord with the principles of the NPPF.
* We believe that the proposed plans relating to the northern entrance to Leamington Spa will exacerbate rather than reduce transport issues, encourage urban sprawl (which, according to the NPPF, Green Belt protection is designed to prevent), and that the proposals will impact negatively on the affected communities, the wider district and on the general aspect when entering Leamington Spa.

The proposed plan does not give a strong enough justification for alteration of the Green Belt to allow development within this area.

The network of public footpaths across the fields give this area great amenity value. These footpaths are always busy with people walking dogs or running and are paticularly valuable as there are no other easily accessible open areas on the north edge of Leamington and no other public footpaths further to the north which could be used instead if this area was developed.

The nearby road network is also insufficient to support this size of development, particularly if Blackdown is also developed. The A452 north to the A46 and south to the centre of Leamington are regularly jammed and old Milverton road is narrow and would become dangerous with increased levels of traffic. This road passes close to schools and is already subject to traffic calming/safety measures.

Section 7.31 states that "employment areas are currently concentrated in the south of Leamington, leading to many cross town centre trips". Even if as proposed some allocation was made for employment within the development there would not be enough to support a combined total of 1,980 new houses (Milverton and Blackdown). This would therefore lead to an increase in the number of cross town centre trips and increase congestion.

Development to the north of Leamington is also poorly situated for access to both public transport and the to the trunk road network. The A452 to the A46 is always busy and is a long and circuitous route to the M40 and the south. The Milverton and Blackdown options are also two of the furthest from railway stations which would provide a more sustainable transport link.

For these reasons development at Milverton and Blackdown would only be feasible in conjunction with construction of the Northern Relief Road. It is therefore disingenuous not to include the roue of the relief road within any proposals for development on the north side of Leamington.

The Northern Relief Road would require a crossing over the River Avon and its floodplain, possibly the most ecologically valuable feature within the local area. Light, noise and runoff from the road corridor as well as the physical severance could potentially cause significant impacts to the valuable riparian habitat and species present. The River Avon is a Local Wildlife Site as well as supporting Biodiversity Action Plan (BAP) habitats and protected and notable species. Species present and reliant upon the river corridor which would be subject to disturbance could include otter (European protected Species), numerous species of bat (all European Protected Species), Kingfisher (Wildlife & Countryside Act 1981, Schedule 1) as well as numerous other species listed on the UK or Local Biodiversity Action Plan species.

Policy PO15 Green Infrastructure - Green Wedges states - "The Council will identify and protect a network of green wedges important for their ecological, landscape and/or access functions in the setting of differing urban areas and urban rural fringe"
One of the largest areas identified and shown on Map 6 covers the River Avon corridor which would be severed by the Northern Relief Road. Therefore these two policies are directly contradictory. Any severance of the River Avon corridor by a new road would cause signifcant harm to the green infrastructure value of this area.

In addition to potential ecological impacts the Northern Relief Road would cause great disturbance to the current residents of Old Milverton through noise and light spill and significantly alter the character of the area.

This is precious green belt land and there are no exceptional circumstances demonstrated that would justify building on it. The level of growth proposed is not backed up with facts (jobs and housing supposedly needed) or the views of local people.
It is wonderful accessible amenity land for walking, jogging, cycling, bird watching, agriculture, and allows children to appreciate the beauty of the local Warwickshire countryside quickly and easily.
It would be such a great loss to see houses built on it. I cannot express how much I want to see it saved for future generations.

Although the areas to north of Leamington will be nearer to the planned Gateway Zone around Coventry Airport so having easier access to employment these sites are on Green Belt land and many of the other sites are on Farmland. As there is no need for so many new houses the numbers on each site should be reduced.

exceptional circumstances required to build on green belt have not been evidenced

This land is in the Green Belt. I object to any development in the Green Belt in preference to development elsewhere on the basis that there is no economic case for such development;

I object to this land being allocated for development because it jeopardises the value of nearby land and dwellings. The Council must accept liability for any resulting reduction in land or property values arising from the date of Plan consultation or adoption.

This area of growth goes into Greenbelt and should not be justified. The whole point of greenbelt is to stop urban sprawl, to stop settlement areas joining up. The previous policy in this document states: "avoid development in locations which could potentially lead to the coalescence of settlements"
This is what Greenbelt is for, keep on building north out of Leamington and Warwick and south out of Kenilworth and you will do exactly what you are trying to avoid. Do not build on Greenbelt!

I am personally greatly concerned and strongly oppose the proposed location of new housing in the Green belt land to the north of Leamington, either on the west or east side of the town. This has for very many years provided a buffer at the edge of and a well-defined boundary to the town. Breaking into this will both destroy a local amenity and threaten that the expansion of the town will allow Leamington, Kenilworth and the intervening villages to merge. It should be a firm policy that designated Green Belt areas are retained. Should it be impossible within the stated growth proposals to achieve these without encroaching on the Green Belt, then the planned growth should be curtailed as necessary. However, it is my belief that sufficient brown-field land exists to accommodate any likely growth over the period of validity of the plan.

this erodes into some important greenbelt land and effectivelt ends of creating a major conurbation instead of dividing warwick and leamington. The traffic problems in coummting in this area are already severe and it is hard to see how such a development could be supported

I am writing to add my voice to those of the many objectors to the new local plan.

Having attended the recent meeting at Trinity School and subsequently studied the plan, I am mystified and appalled, in equal measure, by the council's plan to sacrifice Green Belt land in Old Milverton and Blackdown. What is the point of designating an area as Green Belt, if it can so easily be released for housing development? Surely our local council should be protecting residents' interests, rather than kow-towing to the demands of developers, for whom this is a prime building spot? Furthermore, once the Milverton/Blackdown area has been built on, there is nothing to stop further development to the South of Leamington. The whole area risks becoming one huge urban sprawl.

Please listen to the voices of local people and review this ill-conceived plan.

I believe that 'exceptional circumstance' justifying the proposal to build on Green Belt land in this area have not been proven - there are other suitable/available sites outside the Green Belt.
I believe that the plans relating to the northern entrance to Leamington Spa will exacerbate transport issues, encourage urban sprawl and that the proposals will negatively impact local communities.
The new plan stresses the importance of green areas, and talks of creating country parks but by moving the green belt boundaries, the green belt will no longer be accessible on foot to the North of Milverton.

The proposal will lead to a significant reduction in open space available for exercise and recreation with a concomitant adverse effect on quality of life for all citizens in Warwick district.
Projections for future demand are exaggerated, being based on a period of exceptional growth that is unlikely to be sustained.
Current infrastructure is inadequate to sustain any new development: achievable and affordable essential infrastructure (as described in the plan) for the excessive proposed no. of dwellings is unforeseeable; development of infrastructure will inevitably and irrevocably damage the character and ecosystems of the local environment, without genuine and lasting benefit.

If the land north of Old Milverton Lane is developed it could spoil the rural character of Old Milverton Lane and generate more traffic on a road that is a popular route for walkers, runners and cyclists. This would be detrimental to the recreational use, and increase the risk of accidents. Cars are loathe to slow down to the speed of joggers or cyclists and yet there are many stetches where overtaking is dangerous due to lack of visibility.

Before this site can be finally allocated, there needs to be a thorough review of the requirement for new housing and another analysis of how housing can be distributed, as per my representations against 7.1 and 7.2.
If Greenfield sites are required, this site helps to balance new development across the district and provides homes near proposed new employment land at Coventry airport. Green belt legislation was put in place to prevent the urban sprawl of cities towards smaller communities and therefore, regrettable as it is to have to build on any rural land there should be no special sensitivity to building on this rural land as opposed other non green belt rural land of a similar quality