Blackdown

I would like to make to following points regarding the proposed
development of the above land.

1) This land marks the separation of Kenilworth and Leamington Spa.
It is good agricultural land that has crops grown on it every year.
With the increasing population and the cost of imporation of food it
is imperative we conserve the land that can feed the generations to come.

2) The land has many public footpaths crossing it which are used by
hundreds of people every day.

3) The development of this land could also be a flood risk with the increase
in tarmac roads and paved front and rear gardens.

4) At the meeting held in Milverton Church the proposal of employment was
mentioned. This was promised when I lived in Coventry in the development
of the A444 and has never been successful with so called employment areas
still being empty and so no jobs were available as the result of this development.

5) The proposed new roads would be a disaster for the area. We already have
many vehicles queing on the A46 and A452 and if the roads and housing were
given the go ahead then Kenilworth and Leamington would be nearly joined
together.

6) There has to be somewhere else that can be developed for necessary housing.
Why wasn't the old Ford factory site used. We do not want or need any more
supermarkets in Leamington. What about using the Heathcote area.

7) Please remember that you were voted into your positions by people who trusted
that you would do the right thing. Please do so by finding another area to
develop.

I wish to object most strongly to the proposal to develop Green Belt Land north of Leamington and I detail below, my reasons for doing so.

1. There is already sufficient land available outside the greenbelt, east of the A451 (Europa Way) and south of Heathcote, towards Bishops Tachbrook. Those sites are already close to existing infrastructure and employment facilities which could also serve the proposed new housing. I believe the council has already identified this land as developable.
2. There is no justification, in my opinion, to develop the greenbelt land at Blackdown and Old Milverton, nor is it sensible to consider spending £28m on a major new relief road which would ruin the village, as well as divert resources from other much needed public investment.
3. In times of a double-dip recession, it should be a priority to save money and make more sensible use of the existing facilities. In my own neighbourhood, it is very noticeable that the housing development on the site of the previous Potterton Factory, has not been a success. More than half of the houses/appartments have never been occupied and the site has a decided air of neglect. It's so close to a natural flood plain, that I cannot understand how that project got underway in the first place.
4. Since the NPPF clearly states that one purpose of Greenbelt protection is to prevent urban sprawl, by spreading the options as the council's current proposals would do, I think rather encourages this sprawl. The land proposed for development to the north of Leamington is necessary for exercise and recreation and prevents this attractive town from losing its decided character which it would do if it were allowed to merge into Kenilworth when each town would then lose its individual identity.
5. With Britain now in a very worrying and prolonged recession, I think it unlikely that so much housing and employment facilities is required for the immediate future. Perhaps councillors should take a walk through the
centre of Leamington and make note of the increasing shop closures and other businesses closing down.

I do hope that commonsense prevails and that a sensible planning policy is offered rather than a misguided political policy which takes no account of the historical heritage of this part of England and how we should all do our utmost to protect and maintain it for future generations.

I object to the proposed development in Old Milverton and Blackdown contained in Warwick District Councils's Preferred Options for the Local Plan.
The National Planning Policy Framework (NPPF) states that the Government attaches great importance to Greenbelts and that the fundamental aim of Greenbelt is to prevent urban sprawl by keeping land permanently open.
The Greenbelt in Old Milverton and Blackdown fulfils the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land for ever. It
* Prevents the unrestricted sprawl of Leamington to the north
* Prevents the merging of Leamington and Kenilworth
* Helps safeguard the countryside from encroachment
* Helps preserve the setting and special character of Leamington (a historic town)
* Helps urban regeneration, by encouraging the recycling of derelict and other urban land
This land has great recreational value to the local community. It is enjoyed by many runners, riders, walkers and cyclists.
There are other sites which can be developed that are not in the Greenbelt. These sites, which are mainly to the south of Leamington, were included in Warwick District Council's previous plan (the 2009 Core Strategy). Employment opportunities and infrastructure already exists here, and this land should be used in preference to the Greenbelt.
The NPPF states that Greenbelt boundaries should only be altered in exceptional circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land.
As you have not been able to provide an explanation of any significant changes that have occurred since your 2009-10 Core Studies, I request that you please reconsider your Preferred Options.

Re: Proposed development of green belt land in North Leamington

I am writing to voice my concerns about and objection to the possibility of developing green belt land and building up to 2200 new houses in north Leamington.

The area under consideration for development is a wonderful amenity for local people, not only for recreation and exercise, but also for its very existence as a green and open space, something which should not be thrown away lightly.

Green belt land should not be used where there is still available other suitable land, such as infilling in existing built-up areas. Moreover, despite the alleged need for more housing, there still seem to be empty properties in the area, such as the residential development on the old Potterton's site, next to the Portobello Bridge.

There must be other options, than destroying this precious area of our countryside. Please do not go ahead with this development.

I would like to register my objection to the new Proposed Development Plans. It would be unforgivable and irresponsible of planners to damage this area of North Leamington, when there are Brown or White field sites in the area that prove much more appropriate for this project. They owe it to the residents of Leamington Spa, Warwick,Kenilworth and all those who appreciate and enjoy the area. As a young person living in this area, I find it deeply disturbing that areas of land like this are not being protected for future generations to enjoy.

I urge you to reconsider your options for development,

I am writing to let you know that I strongly object to the proposed plans to develop the very important, well-used and beloved area of Greenbelt in North Leamington that is designated for development in WDC's Preferred Options for the New Local Plan.
The land around Old Milverton and Blackdown is vastly important as a recreational area for many people living in the area; for runners, riders, walkers and cyclists. It is the only area near by where we can pursue these outdoor recreations, which encourage people to lead more healthy lives in an outdoor environment.
We NEED Greenbelt areas to make us feel that we are part of local communities and not just part of large urban sprawls. If this development goes ahead it will feel like the area between Warwick and Leamington Spa along the Emscote Road. Years ago there were gaps between the urban areas. Now it's one long urban sprawl with, I believe, a consequent loss of identity and feeling of well-being.
There will be very little space between Leamington and Kenilworth - except for the A46!
Surely it benefits us all if Leamington keeps its special character as a beautiful Spa town in the middle of beautiful countryside - not surrounded on all sides by developments.
I understand that land south of Leamington was originally designated for development. Surely with the old Ford's site being developed, the already established large retail development containing Sainsburys and the roads that lead to it from the south, with direct links to the M40, would make a much more financially viable alternative? More out-of-town retail development is surely detrimental to the face of our unique towns. And if this land south of town was previously designated why isn't it being used. Why are the WDC now suddenly changing their focus to an established Greenbelt area north of Leamington?
Living close to the Kenilworth Road I can see no purpose in making the A452 a dual-carriageway. Road improvements are all well and good but the purpose of a road is to get people somewhere quicker. What's the point of making part of the road a dual-carriageway when in essence it leads into 2 town centres where there are no dual-carriageways. There will still be hold-ups at the end of the dual-carriageways - hence still traffic delays.

I beseech you - please reconsider your options.

I am emailing to register my OBJECTION to the proposed development in Old Milverton and Blackdown as set out in Warwick District Council's Preferred Options for the Local Plan.

Whereas I acknowledge that the District Council needs to have a plan for future development I have strong and valid objections for proposed development in the areas of Old Milverton and Blackdown, north to and on the edge of present boundaries of Leamington Spa in designated Green Belt land.

Please read through my points below:

Note:
Apologies if I sometimes refer to the Warwick District Council (wdc) as 'Council' - it is the people in charge of making decisions and who have the responsibility to listen to the views, concerns and objections of residents such as myself to whom I refer.
I know the term 'Green belt land' - but unsure about other - I think 'White land' is land identified for building potential but which is not designated Green belt - as I am unsure I have called such land 'not-green belt land'.

1) PROPOSED NUMBER OF HOMES:

Whereas I acknowledge that the District Council needs to have a plan for future development, I have strong objections for proposed development in the areas of old milverton and Blackdown, north to and on the edge of preasent boundaries of Leamington Spa in designated Green Belt land.

There appears to be an over-provision/over-calculation of proposed housing; most probably as the council have forecast using figures from periods of exceptional growth in the past. Such growth can not be assumed and therefore I would prefer that more realistic figures are applied.

WDC has added nearly 1400 homes to the number that it anticipates will be required so as to 'buffer' its proposals. There does not seem to be firm evidence about numbers of houses needed - and if figures are correct, why would there be a need to add on the 'buffer' of 1400 extra homes - a considerable percentage of the total of homes 'needed' in the WDC plans.

If this 'buffer' is removed from the WDC forecast then there would be NO NEED to include the land noth of Leamington in Old Milverton area and Blacvkdown.

Also, the non- green belt sites already identified by the WDC (and not all listed in the 'Preferred options' plan) for development could still possibly be built upon if the present owners get planning permission/sell to developers, etc - therfore reslting in even more excessive housing.

Change to plan: Remove the 'buffer' (approx. 1400 homes) which would easily allow removal of development plans on Green Belt
land in Old Milverton area and Blackdown.

2) OBJECTION TO DEVELOPMENT OF GREEN BELT LAND:

The government has made it clear that it holds great importance to Green Belts (e.g. in the National Planning Policy Framework - NPPF) and I am aware that Local Plans must adhere to NPPF principles.

One of the NPPF's goals is to protect communities and Green belt and to help local people "to protect local countryside and green space they value" ... I value the Green Belt land outside my front door - and that which I have enjoyed walking through and looking at for the 44 years I have lived in Leamington Spa. WDC has a responsibilty to be accountable to the NPPF with its policies and practice.

The fact that the New Local Plan 'Preferred Options' suggest development on Green Belt land is dreadful considering that there is other non-greenbelt land available on which the proposed number of houses/development could be built and local needs met.

The fundamental aim of Green Belt is to prevent urban sprawl by keeping land permanently open. That should be WDC's priority - to leave designated Green belt land as it is when other sites are avalable.


The Greenbelt in Old Milverton and Blackdown fulfills the the first 4 of the 5 purposes of Greenbelt set out in the NPPF and therefore should remain as open Greenbelt land. It:
- Prevents the unrestricted sprawl of leamington to the North
- prevents the merging of leamington and Kenilworth
- helps to safeguard the countryside from encroachment
- helps preserve the setting and special character of Leamington (a historic spa town amidst beautiful countryside)
If other AVAILABLE non-Green Belt land is developed then the 5th purpose would also be addressed:
- Helps urban regeneration, by encouraging the recycling of derelict and other urban land
... Development of Green Belt land in Old Milverton and Balckdown would be contrary to the NPPF guidelines.

To build on Green Belt land North of Leamington Spa would result in a spread towards Kenilworth and put both towns at risk as the danger would then be that future Councils would encroach further and further across Greenbelt land and result in the towns joining together.

Proposals in the New Local Plan would reduce the "Green Gap" betweeen Leamington and Kenilworth to less than 1 1/2 miles; encouraging the merger of these two towns and their loss of independent identities. The village of Old Milverton would also be at risk of being swallowed up into Leamington and lost as an 'independent' village community.

There are many other non-greenbelt sites that could be developed instead - those areas should take priority above any Green Belt land. As a matter of principle and responsibility the Council needs to develop these non-greenbelt areas instead. Many of these sites, which were includede in warwick district council's previous plan (the 2009 Core Strategy), are south of Leamington Spa. (I will expand upon this issue in a later section).

The NPPF states that greenbelt boundries should only be altered in exceptional/ very special circumstances. As there are alternative sites, there are no exceptional circumstances which outweigh the harm caused by altering the Greenbelt boundaries in Old Milverton and Blackdown and allowing development on this land. Therefore, WDC has not demonstrated the 'exceptional circumstances' correctly.

The Government's NPPF states that development of Greenbelt land should only be allowed if the benefits of development outweigh the harm caused to the Greenbelt. There is no evidence to show that development on Greenbelt land north of Leamington would provide sufficient benefits to the community and Greenbelt land. according to WDC the special circumstances are atht there is nowhere else for the homes to be built. However, as mentioned above, in the '2009 Core Strategy' (a plan which was adpopted by WDC) land south of Leamington (not greenbelt) was identified and IS STILL AVAILABLE for development.

If WDC applies a policy of spreading developments areound the edges of Leamington and Warwick on grounds that it will not cause as many objections from one local area/group of pouplation then that is not a valid 'planning policy' - or one acknowledged by the NPPF - it is more of a political move to please everyone. (Apologies if not termed correctly!) The WDC needs to only apply planning policy to this situation - therefore, build on non-Green Belt land first ... NOT leave non-green belt land 'vacant' and undeveloped and yet take away and develop valued Green Belt land.

The 2009 Core Strategy is sound basis as evidence that there are alternative areas for development other than Green Belt land north of Leamington - it also sustains that the "very special circumstances" put forward by the present WDC are wrong.

WDC had studied the value of Green Belt land north of Leamington (old Milverton and Blackdown) which concluded that these areas had HIGH GREEN BELT VALUE. Therefore, should not be built on.

Change to plan: Develop areas south of Leamington that have already been identified by WDC as apporpriate for development.
Erase any proposals to develop Green Belt land north of Leamington Spa.


3) HEALTH, LEISURE and WELL-BEING:

The land suggested for development in Old Milverton and Blackdown is used by many people - individuals, couples and families; and groups (such as, local scout groups) - for recreational purposes ... walking, dog walking, rambling, cycling, running, bird watching, etc.

Highly valued, cherished and utilised recreational areas need to be protected.

Health and well-being of Leamington Spa's residents is important.

These areas provide Leamington and Warwick residents with easy access to the countryside environment.

For example, the footpaths across Old Milverton (e.g. entered from Bamburgh Grove/allotment area down to Old Milverton and onto the Saxon Mill and beyond) are regularly used by local residents (such as, myself) and also people not from the local area who choose to walk in an area of beauty and tranquility. Having access to outdoor ammenities such as the pathways that cross the Green Belt land is an activity to be enjoyed by all ages; and definitiely an encouragemnet to keep young people busy and away from anti-social behaviour.

Any proposed development on the Green Belt land would encroach on this valuable local asset which encouirages people to visit our lovely town - an area and amenity of which residents and the WDC should be proud.

There is very little publicly open space in the north Leamington area - we need to protect that Green Belt land for future generations and visitors to enjoy.

There are many elderly and infirm residents around the Old Milverton and Blackdown areas - it worries me that developments surrounding their homes will have a harmful affect on their health and well-being caused by worry, stress, noise, light pollution, extra traffic, etc. which could be avoided if the Green belt land is not built upon. Many of our older, long-term Leamington residents will have been unable to lodge their objections with the consultation system having been advertised and completed in the way it is. (Many will not be able to access the internet, read easily, rely on carers, etc.)

To be fair to all of those in our communities - a door-to-door consultation/questionnaire should bge used to ascertain the opinions of all residents. A postal questionnaire could be carried out and then WDC employees call at houses not retur=ned a view/opinion.
Land that has been designated as Green Belt land - and so shown as such in 'searches' when people buy their homes - has had a key affect on people's decisions to purchase their home in present outer edges of Leamington that are earmarked as residential areas. That amenity and privilege is often reflected in house prices (more costly). Local residents have chosen to live where they do because of the positive aspects that living near Green Belt land without affecting the Green Belt land itself (that is, not buying houses built on and destroying designated Green Belt land). If nearby Green Belt land is developed that will have an adverse affect on local residents' enjoyment of their homes, and highly likely, their well-being; totally changing the landscape and area where they have chosen to live. The counil have a responsibility to their present population/rsidents - what is the point of having alegal system (e.g. searches) when the council can then change its boundaries?!! (excuse the pun!)

Change to plan: Omit Green Belt areas in Old Milverton and Blackdown from the Local Plan as they are valued areas for recreation
as the Council has a responsibility to provide areas for recreation - and protect those we already have AND USE!
Ensure that the consultation actually does 'consult' all residents - especially considering the elderly and infirm



4) WILDLIFE:

Any development of the Green Belt land in Old Milverton and Blackdown would obviously have a negative, detrimental effect on the environment and local woildlife - e.g. destroying habitats, increased noise and light pollution, pollution from traffic, etc.

The Green Belt land surounding Old Milverton, North Leamington, Blackdown, is beautiful and home to many varieties of plant, tree and creature.

I see many wild birds from my house and as I walk along the pathways crossing the Green Belt land; including a heron who regularly visits and flies over the field opposite my house. There are newts, etc that live on the land nearby - and woodpeckers nest in trees. Areas such as these are already few and should be protected.

Any development in this area of Old Milverton would have a dramatic and negative impact on the natural environment.

The WDC has a responsibilty to protect Green Belt land that homes such a wealth of wildilfe and plants. The Green Belt land should be a valued resource - not something that can be signed off to developers!

WDC also has a responsibilty to the education of all the young people within our community - without these Green Belt areas - and established pathways and habitats - children and young people will not be able to learn about and value our countryside and wildlife.


Even if proposed developments suggest areas for 'green space' they would be artificial and wildlife would have already 'moved on' when developments are being built.

Change to plan: Erase proposals to develop Green Belt land north of Leamington Spa.
Protect present Green Belt land & wildlife.
WDC should ensure they have a firm policy to only plan to develop non-Green belt land as there is enough of that
available to suit the anticipated growth and need of our community.

5) DEVELOPMENT SOUTH OF LEAMINGTON:

As referred to earlier, there are many sites to the south of Leamington Spa which have been identified as areas which could be developed and are NOT greenbelt land. therefore, these sites should take priority as it is important that Greenbelt land should be protected.

Assessments made by WDC (re. 2009 Core Strategy) identified the sites south of Leamington as land which is easier to develop than land to the north of the town, and the land south of Leamington already has a substantial amount of infrastruicture in place which would support further development and increased population. The Council had identified available land east of the A452 (Europa way) and south of Heathcote towards Bishops tachbrook - these areas are still appropriate sites for development and should be considered in full.

There is factual evidence from SHLAA that enough land exists south of Leamington spa for the development needs of WDC. So this should be built on before any Green belt land is destroyed.

Land south of leamington is close to the M40 and various link roads and the A46 - allowing easy access to roads and rouotes for residents and businesses south of Leamington.
There are existing employment opportunities south of Leamington.
Employment opportunities and infrastructure already exists south of Leamington.
Large shopping facilities (including, major supermarkets) are south of Leamington.
There has also been talk about development of another large supermarket near/on the old Ford foundary site, south of Leamington; the old Oak pub site, etc.

It would therefore, seem better to build more homes south of Leamington as they would have easier access to those shops and not (if developments north of town) cause more grid lock through the town centre, with people trying to get south town to do shopping (and travel to work, and links to M40, etc).

WDC suggests that the land south of Leamington is not as attractive to developers because of coinsideration of development in that area may result in the developers making less profit. May I propose that:
- Developer's financial gain should NOT be a priority (definitely not a "very special circumstance")
- Developer's financial gain is NOT a valid reason to allow development on Greenbelt land
- The financial investment of present leamington residents (e.g. money we have invested in purchasing our homes as they are) is
important - developments on greenbelt land in full view of many homes north of Leamington will affect the house prices of
present loyal local residents - WDC should protect local residents

As far as I am aware, due to the land layout, developments in south of leamington would not have such a visual impact as they would north of leamington - where developments would be more visual to both present local residents (views, lifetsyles, well-being affected) and visitors approaching our lovely town. Therefore, it makes more sense to develop south of Leamington where the developments can suit the land and area more suitably.

There are already good routes laid out for public transport south of leamington which serve the community well and would easily be enhanced if development happens in that area. The restructuring of public transport rourtes and ammenities north of Leamington would be costly, difficult and disruptive.

Change to plan:
WDC should adhere to their proposals from 2009 and make developments in areas south of Leamington Spa.
Prioritise development south of Leamington due to reasons listed above (e.g. present infrastructure, non-greenbelt land, employment and business amenities already in place, large open areas to develop communities which will develop positively)
Remove proposed Green Belt areas north of leamington from the 'Preferred options' plan.



6) PROPOSED NEW ROADS:

Turning the A452 between Leamington and Kenilworth into a dual carriageway will not help traffic flows. at peak times of the day the delays on the A452 result from commuters waiting to access the town centre. With developments north of leamington that will just add to the traffic.

Such a major road will have a detrimental affect on the visual approach to Leamington (and into kenilworth) - the rural aspect is something that people like about our town. To put in a dual carriageway and built up areas north of the town would make Leamington look just like 'urban sprawl' and not attract so many visitors/new residents.

Building hundreds (thousands) of houses north of Leamington willl increase the congestion into the town centre - at peak times and weekends - and also as people try to drive the 'short route' through Leamington town centre, down through town to get to the larger shopping areas (and ammenities - e.g. bowling, restaurants, pubs) south of Leamington.

Without the need to build vast amounts of houses north of Leamington (see earlier reasons) there would be no need for WDC to spend excessive amounts of money (i think budgeted at around £28m; so could be more eventually) in bulding a 'Northern Relief Road'. Residents from north Leamington travel south to south town - not out and around... new home owners would just be encouraged to travel out and away from Leamington and it's shops etc (eg to travel off to Coventry and Birmingham instead). without development in north Leamington the road would not be needed - saving WDC (and ratepayers) lots of money.

Should a 'Northern relief road' be considered it would form a further barrier across Green belt land; and encourage furure developments in Green Belt land as well, resulting in urban sprawl and merging together of Leamington and Kenilworth. It would have an adverse effect on the River Avon area; also valued for wildlife and recreation. The road would be incredibly and excessively costly as would have to be built on what is known to be a flood plain.

if the proposed development is concentrated in the south of Leamington spa then there is already an existing road network that could easily (less costly!) be upgraded to suit local needs. It would also be easier to sustain and enhance the good public transport links and routes south of the town rather than put n lots of new structures to the north.

Change to plan:
Erase proposals to develop Green Belt land north of Leamington Spa and so negate the need to build a 'Northern Relief Road' as detailed in Preferred Options Plan.
Plan to enhance public transport systems south of Leamington

7) PROPOSED OUT OF TOWN SHOPPING AREAS:

Where new out of town shops and stores have beeen proposed, this would have a detrimental affect on the independent retailers within Leamington (and probably kenilworth & Warwick) town centres.

Further 'out of town' shopping complexes will take shoppers out of towns where local, independent traders rely on customers; shops will close (even more than are empty already) and this will have a negative affect on our town - reducing the appeal of the town and the number of visting shoppers who like to visit Leamington for shopping.

A town of empty shops - and few independent retailers will not encourage people to come and live in Leamington Spa.

8) OTHER OPTIONS:

There seems to be a lack of detail in the available documentation about the other options available for development within the present town and residential boundaries.

There are many empty houses and buildings in Leamington which would surely be ripe for developers (and the council) to develop and rennovate. This would look after buildings in the town , helping the town to look better and - most importantly - providing affordable homes for our younger - and older - generations.

There are other places that 'we' hear whispers about being developed - have they been included in your 'preferred options' plans and oropsals? For example, the fire station ... Fords foundary area ... grounds form the old Park and Croft hall schools? all areas need to be fully adveryosed to the public in order for educated opinions to be logged.

Change to plan: WDC to look at developing more buildings and sites within the present residential areas and town centres -
provision especially for affordable housing.
WDC to readvertise where ALL possible sites for development are - not just 'preferred options'


9) OTHER CONCERNS:

The proposals don't seem to make it very clear about WDC projections for the impact of new developments on crime and anti-social behaviour figures. New developments will have an impact on present residential areas.

I object to the term used as 'Preferred Options' to the general public. having attended a council meeting earlier in the process it seems that there could have been a way of ensuring that all sites identified as having development potential could have been advertised more readily to the general public at this tage. this would have includied those poropsed and agreed in the 2009 proposals - those that have been ommitted (or at least not so obviously displayed) to the public gives them an unclear/uneducated view of all possibilities. ALL available sites should be made available for the general public to know about - and so make a more informed decision - including the non-green belt sites south of Leamington.

The proposed 40% affordable housing figure given in the WDC plan concerns me - as there seems to be no firm evidence why this wuld be the percentage of affordable homes needed. More consultation needs to be done on this. There has been no poll of local residents. If too much 'affordable housing' is built it may well stop people wantig to move to certain areas in and artound Leamington - and stop residents wanting to stay in Leamington long term. WDC has a responsibility to its long term residents.

Change to plan:
Investigations/research into impact on social issues, crime statistics etc. needed
WDC to readvertise where ALL possible sites for development are - not just 'preferred options'

CONCLUSION:

Finally, thank you for taking the time to read my lengthy email. As you can tell, i feel very strongly about the valid points I have raised and hope that 'you' (the district council) will reconsider your Preferred Options and NOT develop on the land north of Leamington in Old Milverton and Blackdown areas.

There are clearly areas available for development which would allow the council to meet the needs of the town and their responsibilities without building on such precious and Green Belt land. The WDC has NOT provided adequate evidence for 'very special circumstances' for suggesting Green belt land for future development.

In view of the need for some town growth, the general proposed numbers should also be reduced without the 'buffer' of 1400 homes which most probably won't be needed. This would also erase needs to build on the Green Belt land north of Leamington.

We have examined the above proposals with great interest and we write as residents of the Milverton area of Leamington Spa for over forty years. We, therefore, have some knowledge of local needs and conditions. We are restricting our comments to the proposals for North Leamington although we expect that there will be common ground with a number of the other sites.

We believe that the options as published are flawed on a number of fundamental grounds.

1. PO1. Past performance is no guide to the future. The projections for growth between 2011 and 2029 are overly optimistic and even if achieved there is no need to develop the green belt to the extent proposed.

2. The proposal to develop green belt land to the North of Milverton and at Blackdown is completely contrary to PO4 D. Furthermore, the paper does not provide the evidence required under NPPF to permit development in the green belt. Where are the 'exceptional circumstances'? The study appears to be highly subjective and indeed selective.

3. Insufficient use has been made of available, non-green belt land to the South of the town. This is also the area where the bulk of the potential employment for the new residents is already located.

4. The need for infrastructure development to service the Milverton/Blackdown proposal will be out of all proportion to any possible benefit. £28 million for a Northern Leamington Relief Road would divert scarce resources from other much needed public investment, let alone ruining the amenity value of space around Old Milverton.

5. There appears to be real risk, if these proposals proceed, of North Leamington and Kenilworth coalescing at some point in the future with the consequent loss of identity and in direct contravention of one of the basic tenets of local planning.

In summary, we object in the strongest possible terms to these seriously flawed plans. One of the goals of the NPPF is to protect communities and green belt land from unpopular local plans. The present proposals seem to flout that goal at almost every turn.

A great deal of time, money and energy has already been expended by the Council but that is no reason to proceed along the lines proposed and ruin the future amenity of many local residents.

We are writing to object to Warwick District Council's proposal to build on the green belt in their local plan.

There are other options on non green belt land in the district to the South and East of Leamington that should be exhausted before green belt land is used. Green belt should only be used in exceptional circumstances, which clearly this is not because of the other alternatives. The green belt land to the North of Leamington is particularly precious, as it keeps the division between Leamington and Kenilworth and stops the area turning into one big urban sprawl, and the local towns losing their identity.

In the local papers the independent Councillor for Whitnash, Bernard Kirton has said his area South of Leamington had already had enough development and that non-green belt areas earmarked on previous local plans should not be used, he somehow has managed to influence other Councillors including the Conservative Mike Doody, who has added his voice, with the scaremongering statement that "if people did not accept this plan, developers would build wherever they choose". Last time we checked the elected government was running our country not developers!

Our local Councillors John Hammon and Norman Pratt have been contacted and have pledged to support us in our opposition to building on the green belt. We have also spoken with many of our neighbours and people in our area and are yet to find one person in favour of building in the green belt area North of Leamington.

We would strongly urge the District Council to rethink their plan, before it costs the local taxpayers a lot of money in unnecessary legal fees should the proposed plan go forward.

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I wish register my strong objections to the proposed 1980 new houses proposed to the north of Manor & Milverton Wards at Blackdown & Milverton. This will develop many acres of prime agricultural land in the West Midlands Green Belt, & is totally unacceptable on planning grounds. Furthermore it contravenes Green Belt policy stated on page 19 of the NPPF, recently published in March 2012.
Major changes in the circumstances when the previous Plan was published circa 2 years ago are not evident. The ideal of Garden Suburbs, similar to Beverley Road, Northumberland Road & Woodcote Road, which are shown in the Draft Plan, are, frankly ludicrous & impossible to achieve here in the early 21st Century. Garden suburbs were primarily a feature of the early 20th Century. It is unlikely that they will be sustainable here, due to the land costs (£1M+ per acre), density of dwellings needed to be profitable & the 40% social housing requirement. Add to this the need to dual the A452 & create a Northern Relief Road, near to Old Milverton & eventually joining the A46 By Pass, plus a new Primary School & a local shopping centre. The thought of all this development in our hitherto rural Green Belt would be a planning catastrophe.
I believe we need to look again at locations in & to the south of Leamington. Grove Farm, east of Radford Semele village, south of Bishops Tachbrook & further to the south & east of Whitnash, all are Greenfield sites, with an abundance of open countryside to their south. Nearby are employment areas, supermarkets, schools & major transport links.

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See Attached.

I have recently learnt about your proposed development in the green belt land to the north of Leamington.
I am distressed to hear about this and upon further exploration believes there are valid grounds to object to this:
1. That you have failed to demonstrate the very exceptional circumstances set out in national guidelines to permit the development in the Green Belt
2. This land is an important amenity to the local area providing open area for exercise (walk, run, dog walk etc). We have very little open land locally that is easily accessible from the town centre and away from busy roads.
3. My understanding is that green belt land should not be developed when other land is available for development. There is land available for development east of A452 and South of Heathcote towards Bishops Tachbrook. These sites have not been included in the preferred options sites.
4. The preferred option paper does not provide the evidence required
5. The local plan does not meet with the principals of the NPPF
6. The purpose of greenbelt is to protect urban sprawl. Your proposal encourages this. Leamington, Warwick and Kenilworth will further physically merge with each other which risks loosing their individual identities and communities
7. There appears to be over provision of housing based relying on projections from a period of growth
8. The current infrastructure will not support this growth and would require huge investment and additional land.
In summary I believe the plans to be flawed and strongly object

I write to register my strong objection to the Preferred Options Plan currently in
Community Consultation.
There are three major areas of required process in which Warwick District Council
and its executive need to offer significant improvement:
1 The Preferred Options Plan includes Greenbelt but offers no "very
speCial circumstances" as required in the National Planning Policy
Framework. WOe's apparent reason of "nowhere else to go" is
insufficient and made invalid by their own recent identification of
development land in the Core Strategy 2009.
2 The Preferred Options Plan has not been produced as an evidence
based planning document, despite repeated statements by WDC and
its officers that it has been. Councillor Doody on 16th July at Old
Milverton Parish Council meeting stated clearly that the housing target
figure was "the minimum we could get away with".
3 The Preferred Options Plan does not offer the community any options.
To date the consultative process has shown little listening by WDC and
its officers, and much pressure by them on the community to accept it
as it is. It is unacceptable in our democracy to have the community
consultation process so poorly executed, run apparently only to
achieve a pre-agreed result and therefore only to a level of "going
through the motions."
There are in my opinion six areas of major planning weakness in the Preferred
Options Plan, resulting in it being a meagre and insuffiCient document which does
not propose any thoroughly supported substance.
1 The fundamental aim of Greenbelt policy in the Government's National
Planning Policy Framework is to keep land permanently open to
prevent urban sprawl. The "very special circumstances" required by the
NPPF to use Greenbelt land have not been stated in WOe's Preferred
Options Plan. The NPPF requires the benefit of development to
outweigh the harm caused to the Greenbelt. Where is this case? The
previous Plan (2009 Core Strategy) is direct evidence that there are
alternative areas for development, thus proving the special
circumstances put forward by WDC are wrong. WOe's argument that
the land previously identified to the south of Leamington is less
profitable to developers is not a "very special circumstance" to permit
unnecessary development in the Greenbelt.
2 The WDC study assigns high Greenbelt value to the land at Old
Milverton and Blackdown, but this is ignored in the Preferred Options
Plan. These areas have high Amenity and Recreation use as green
lungs for the populations of Leamington, Warwick, Kenilworth and
further afield in Warwick District, and should not be sacrificed for the
poorly defined "green wedge" approach. Managed parkland is a very
poor substitute for access to fine agricultural countryside.
3 The Northern Relief Road is not required (budget c f28m) since traffic
flows tend to be north to south. It is proposed across a flood plain with
the aSSOCiated high cost, violates the Avon nature corridor, and will if
permitted provide a natural barrier to encourage further encroachment
of the Greenbelt, coalescence of towns, and detract from the
picturesque northern entry to Leamington and the southern entry to
Kenilworth. If built, it will provide the residents of 3000 houses a quick
route to get away from the jobs, shopping and economic well-being of
Leamington, and Kenilworth. The existing road network in south
Leamington could be upgraded at considerably lower cost to meet the
needs of development on the identified land there.
4 The out of town retail operations proposed are an inappropriate blow to
the independent retailers in Leamington, Kenilworth and Warwick who
make the area attractive to live in.
5 The use of a significant quantity of high quality agricultural land which
is currently Greenbelt, is inappropriate in the world of rising food prices
and a requirement to increase the green credentials of the economy.
6 There is a lack of clarity, a paucity of evidence and self inconSistency in
the housing, jobs and homes model used for the Preferred Options
Plan . The 1400 homes added as a buffer by WDC on top of the
modelling are not evidence based. If they are removed, there is no
need to include the land at Old Milverton and Blackdown. I would
expect that a properly drawn plan should be numerically consistent,
and not include a quantity of homes which appears to relate to a
similar population increase ie about one person per home.
In summary, the Preferred Options Plan is a very poor plan. It neither has the
support of the community, nor has it adequate compliance to the National
Planning POlicy Framework. I commend the rapid creation of a suitably sound plan
which has significant community support, to provide a relevant guide for the next
decades of Warwick District.
To do this well, the current consultative process must be seen to be working,
both in the actions of WDC at the conclUSion of the process, and in the revised
Plan which should emerge.

We wish to object very strongly to the proposal to develop Green Belt land to the north of Leamington Spa. We find it astonishing that WDC appears to be ignoring the Government's National Policy Framework which exists to prevent unpopular local plans, especially on Green Belt land. Briefly, our reasons for objecting are:

1. Loss of amenity. The footpaths in this area are used on a daily basis by hundreds of ramblers, dog walkers, cyclists, joggers and even horse riders. There is no other similar amenity in the area, and its loss would be devastating to many people who currently make use of it, including ourselves.

2. Use of Green Belt land. The Government's National Policy Framework requires there to be very special circumstances for there to be development in the Green Belt and for the harm created to the Green Belt to be outweighed by the benefit of the development. WDC say that these special circumstances are that there is no other land to develop - this argument is patently wrong as previous WDC plans have identified suitable alternative non-Green Belt land.

3. Urban sprawl. The proposed development will lead to Leamington, Old Milverton and Kenilworth merging into each other. Again this is would be counter to one of the main purposes of Green Belt land.

4. Infrastructure. It will require further land and huge expense to provide the infrastructure necessary to support the development. The proposed Northern Leamington Relief Road would utterly ruin Old Milverton and the agricultural land surrounding it.

5. Level of Housing Provision. WDC has over-estimated the requirement for new homes in the area, as the number described has been obtained from projections from a period of exceptional growth.

We sincerely hope that WDC reconsider this absurd and very unpopular proposal

I am writing to express by serious and deep-felt objections to the preferred options plan as part of the consultation process that ends on the 27th July. In particular I object to construction on the greenbelt land to the North of Leamington, particularly the area North of Northumberland road, and South of Old Milverton, which seems to be being referred to as "Milverton Gardens." I propose that there are sound and sensible planning reasons not to build on this land, and viable alternatives elsewhere. To build on this land would be to fail to "protect for future generations" an essential part of the National Planning Policy Framework.

SECTION 1: INCORRECT PLAN TO BUILD ON GREENBELT LAND

Development unsuitable on Greenbelt land:

The part of the plan that I am quite simply outraged about is the destruction of valuable greenbelt land. This is not in accordance with national planning policy, for National Planning Policy Framework identifies that greenbelt land should only be built on in exceptional circumstances. The plan the council has put together does not demonstrate exceptional circumstances, not do I believe are there exceptional circumstances within the county for this to be validated (it would be unacceptable for the council to simply take this consultation and find some more evidence that they argue makes greenbelt use warranted, the point of consultation is not to argue with it, but to find out and accept local views). No evidence has been cited by the council explaining the exceptional circumstances, and as this is an evidence based consultation this is unacceptable and the plan to build on greenbelt land must be removed. This is further compounded by the fact that development is proposed also on the South edge of Kenilworth increasing the risk of sprawl as the two towns are being moved closer together. There is already significant established sprawl between Leamington and Warwick, to allow future sprawl risking coalescence with Kenilworth would destroy the local area, the community and result in people not wishing to move to the area and thus prove unsustainable.

Arguments that the need for housing in the area warrant construction on the greenbelt as an exceptional circumstance are false; this is demonstrated by strong evidence for in Cheltenham (a region which like Leamington has a strong need for housing and a large proportion of the county covered by greenbelt land), here the NATIONAL planning inspectorate ruled that these were not sufficiently exceptional circumstances to building on greenbelt land, and it is only right that Warwick District Council take heed of this evidence in their plan and remove the greenbelt from their plans. It has been argued that 80% of the county's land is greenbelt, however this is a misleading statistic for in fact a far smaller percentage of the rural-urban fringe is protected by greenbelt land. It is therefore totally unacceptable to use greenbelt land to build 44% of the housing required under the plan. Furthermore the % of greenbelt bordering the rural urban fringe is there to prevent urban sprawl, this is a nationally stated policy, it is my opinion that building on the greenbelt to the North of Leamington risks sprawl with Kenilworth and Coventry (this is indisputable as an original purpose of the greenbelt is to prevent sprawl with these areas, nothing has changed with regard to these areas, so building on the greenbelt encourages sprawl).

Use of greenbelt land is also unacceptable for there are other suitable areas for housing to be built, which are outlined later in this letter. Early in the consultation process the council discussed the need to "spread the pain" around the county, and for this reason there was construction on the greenbelt. This is not a planning reason for building on the greenbelt and certainly not an exceptional circumstance; as this was mentioned by council members early in the consultation it is only logical this is the logic for construction on the greenbelt land. This logic is unsound and the greenbelt should be removed from the plans. Creating alternative arguments later to counter residents objections that "spreading the pain" or as you have referred to it as in your preferred policy document "spreading development around the district" is not in-keeping with the process of consultation, for this is arguing with the publics views gathered consultation rather than being guided by them.

It is important to note that the National Planning Policy Framework sets out five purposes for Greenbelt land. In summary these are; to prevent urban sprawl of built up areas, to prevent neighbouring towns merging, to protect the country side from encroachment, to preserve the setting and special character of historic towns, and to assist urban regeneration by encouraging the recycling of urban land. Given that the greenbelt land to the North of Leamington Spa and South of Old Milverton fulfils the first 4, and arguable also ensures the 5th of these objectives, this is quite clearly greenbelt of very great importance and therefore its development would be contrary to the National Planning Policy Framework and common sense.

I believe the council have been disingenuous, or certainly at least short sighted in their plans. The land to the North of Northumberland Road that is planned for development leaves no distinct boundary to the greenbelt, particularly to the West of the site. This is in contravention of the NPPF, but would inevitably result in further development of the greenbelt land beyond that currently mapped by the council. This site therefore is inappropriate for development for once the boundary of the greenbelt is breached in this location and housing built upon it, this will create a "slippery slope" of further greenbelt development; a disaster to the region and totally unwanted by residents.


Advantages of focusing building in the South:

I am a young person (23) returning to Leamington Spa to work, the access to rural space and greenbelt land are essential to me choosing in this area to live. These rural spaces and areas of greenbelt are essential to the heritage and character of our town. It is essential we preserve this to encourage future skilled people to live here. However I cannot afford to purchase a house in the area, rather I am forced to live with my parents. As a resident of the area looking to purchase a house I am strongly opposed to construction on the greenbelt land to the North of Leamington, rather I would prefer extensive construction to the South. Housing in North Leamington has always been, and no doubt will continue to be more expensive, this is why developers want to build there (as stated by a senior officer of the council) as developers can then sell the houses for more profit. We are desperately in need of new affordable housing, as stated in your plan, so not only is construction in the greenbelt not warranted as an "exceptional circumstance" but actually contrary to what the district so desperately needs! Allowing more construction in one area (the South) would increase supply and therefore decrease demand for houses there, and with increased supply and decreased demand it is a simple economic argument that housing would be cheaper in that area. A key part of your plan is to ensure affordable housing is available and therefore by persisting with construction on greenbelt land to the North of the Town you fail to provide an adequate and sustainable supply of affordable housing. Again your policy of "spreading development around the district" is not only not based on planning principles and harmful to the district, but in fact prevents you achieving the large stock of affordable housing, which you set out to do.

In the Milvertion Parish Council meeting I attended a senior officer of the council stated that putting all housing in the South would be "more than the market could bare," quite simply this is argument is not valid for justifying construction in the North Leamington Greenbelt. If the market cannot support that level of housing then clearly there is no need to build any more housing in the district for there is no more demand!

Furthermore focusing housing in the South would allow financial saving for the council; this is important in a time of recession with an uncertain future; it is the councils responsibility to spend taxpayers money as effectively as possible and by focusing construction in the South rather than "spreading" development around the town, then the council could benefit from economies of scale whereby new schools and other services could be built singuarly in one area rather than having to spread service provision at increased cost around the county. This would thus allow the council to benefit from an economy of scale.

Health Grounds

As a medically qualified doctor with a special interest in diabetes and obesity I believe it is vital that the council and planners take on-board that Warwickshire is set within the West Midlands, which exhibits the highest rate of obesity in England. Such an epidemiological problem is of tremendous importance to the health, wealth, sustainability and enjoyment of futures generations. The greenbelt land to the North of the Town has an incredibly important exercise resource; the footpath between Leamington and Old Milverton and on to Warwick. I believe this must be one of the most popular footpaths in the region and provides vital exercise and leisure benefits for the local population who walk, cycle, ride horses, jog on it. Destruction of this greenbelt would prevent people using this footpath ( being realistic very few people would use a footpath that runs through the centre of a housing development, even if it is a "garden" one, and this goes for arguments of putting it in a belt of parkland, which also would not give any benefit to the community, and as in many areas can result in foci for crime.

Attempts to recreate this leisure resource would not I believe be successful in a garden town; the footpath is free of charge to use, requires no special equipment to use, is open whenever local residents want to use it (even at night), can accommodate a high volume of people, can be used by those of any age (indeed people who grow up using it as children are likely to continue to use it as adults thus bridging a vital gap in ensuring exercise throughout life), it can be used individually or in groups. It also provides a low resistance, low impact, long duration form of exercise that is vital to older people needing to exercise. It is my opinion that even a combination of play areas, sports grounds, parks and facilities would fail to fulfil these criteria. When canvassing opinions from people using the greenbelt we were amazed at how widely people come from across Leamington to use this resource - it is a benefit for the whole town, and indeed the whole region - this letter, and the strong opposition to the greenbelt destruction cannot be accused of being "NIMBY (Not in My Back Yard). Ensuring the health of the population of Leamington is vital to creating a sustainable development plan, building on this vital local resource fails to meet the needs of today's population but also destroys a vital amenity for our future increasing the risk of heart disease, diabetes, stroke etc and increasing the burden on our health services. Building on the other sites suggested in this letter avoids such problems.

It is of particular importance to myself and local residents to note that the area of highest use, accessibility and therefore greatest amenity and health benefits are the fields closet to Leamington Spa, therefore even the smallest amount of encroachment into the greenbelt would be unacceptable and harmful to the community and it's future sustainability and this is not what the very strong opposition to your plans from local residents have asked for.

The area between Kenilworth and Leamington Spa is subject to air quality management measures due to the high pollution created by surrounding pre-existing infrastructure, not only would new roads create increased levels of air pollution (harmful to the population, and in particular those with respiratory diseases eg asthma) but also the proposed development would reduce the Green Lung between Leamington and Kenilworth to less than 1.5miles reducing the ability of this land to absorb and decrease surrounding levels of air pollution. It is hardly sustainable to future generations to encourage harmful levels of pollutants in the air and therefore building here fails to achieve the plans aims for another reason. The land to the South of the town, does not suffer from the risk of coalescence with other towns, and indeed areas to the East and West not subject to air quality management, and thus would provide far better locations for the construction of new developments.

Wildlife Value

There is considerable wildlife and conservation benefit to the greenbelt between North Leamington and Old Milverton; it is essential we preserve diversity of wildlife for future generations, and this is intrinsic to a sustainable plan. Protected wildlife in the area includes; bats and their flight-paths, gliss gliss mice, great crested newts and badgers and their sets. This is without any study and I'm confident that careful study would elucidate other important species, this is likely to produce significant delays with biodiversity study, and protest questioning the ability of the council to deliver the site in an appropriate timescale if at all. I and many like me believe that we and Warwick District Council have a duty to protect these creatures, attempts to move them are unacceptable.

Employment

The preferred option plan's suggestion of construction of housing in the North Leamington Greenbelt fails to take into account the employment landscape of the district past, present and in future. Myself and other residents have strong objections and concerns that there will not be enough employment in North Leamington. This is a further reason that construction should not occur on the greenbelt. Whilst the plan suggests that some land will be made available for employment there is no thought as to what, where, or who this might be. There is no consideration as to why employers would consider not locating in the South where there is far better access to the M40 and national infrastructure (even with the proposed trunk road) nor why they would leave an area where there is already both competitors and suppliers, both of whom would make South Leamington more attractive. I believe that the only employment you could be confident of having in the North would be employment to service those who live in the new houses there, this would no doubt involve out of town shopping and further damage the centre of Leamington Spa, disastrous for the local economy at. Furthermore there is NO EVIDENCE provided whatsoever as to whether and if so which employers would locate in the North. The vast amount of employment and retail land in the South provides an abundance of EVIDENCE that employers are not only there, but also want to be there and new development/employers continue to locate. You have failed in your consultation document to demonstrate evidence of successful employment opportunities deliverable to the North and as a consequence myself and local residents do not want construction in the North, again this is not an invitation to attempt to justify your decision to put housing in the North, but rather listen to resident's views and act on them by not building in the North.

Housing in the North poses a very serious risk that people would need to commute to South Leamington to work, or alternatively to the M40 both these would involve travelling across the river at peak times when congestion is already unacceptable, this would hardly be sustainable and contribute to air pollution which has already shown to be excessive in the North.

At the Milverton Parish Council meeting it was proposed that the construction of the Coventry Gateway/airport project(s) would provide employment for those living in the North. This is unacceptable for two reasons; the first is that this is construction on greenbelt land seemingly justifying more development on greenbelt land - this is of course poor reasoning for justifying exceptional circumstances for construction on the greenbelt land! Furthermore this employment land abuts and provides significant benefit to Coventry; I do not believe Warwick district should be responsible for providing housing in Leamington for employment that is effectively in Coventry regardless of where historic district borders are drawn, nor will the planning inspectorate. If this land is exceptionally required from the greenbelt to provide housing for employment, that land should be provided near Coventry. Furthermore having people living in North Leamington yet working in Coventry risks turning Leamington into a commuter town - with great disadvantages for our town centre, and those who work there. Finally there is considerable congestion around peak times in journeying to Coventry, the infrastructure is not in place to allow people to commute to Coventry and indeed any improvements that were made have simply begun to tackle the current problems. These highways agency solutions have hardly corrected the problems that currently exist for significant congestion remains at peak times For all these reasons construction on the greenbelt in the North is incorrect and an alternatives strategy should be sought.

This plan goes against almost a century of town planning in Leamington; the 1943 Royal Leamington Spa plan for development identified that employment land had already been focused in the South of the Town, and highlighted the importance of continuing this development this further. Vitally this was seen (and has continued to be seen) as the correct policy when the M40 did not exist, the presence of the M40 only strengthens the desire for business to locate in the South of the town, and therefore it is essential housing locates close to this to prevent further congestion in the town. The 1943 plan further elucidates that construction of housing in the North would serve simply as commuter accommodation for those working in Coventry. The local residents do not want Leamington to develop into a commuter town, nor the demise of the town centre that would result from this, this is a further strong argument for not building on the North Leamington Greenbelt. These are hardly pithy historical notes, but instead provide a firm evidence base tested over 60+ years demonstrating successful location of employment land in the South of the town, and the risks of commuter accommodation in the North. The council have totally failed to provide strong evidence for employment to locate to the North, nor for this to function as successful housing for the town, indeed at the Milverton Parish Council meeting the Deputy CEO couldn't give any significant detail as to what sort of employment would locate to the North. I must repeat again that this letter is not an invitation for the council to now seek this evidence or contest these arguments (supported by petitions, other letters, and record breaking meeting attendance), but to listen to local views and use them to modify their plans to remove construction on the North Leamington Greenbelt - to fail to do this would be to fail to consult properly.

To be sustainable housing should be planned close to proposed employment otherwise it will have adverse impacts on commuting and travel. If for example people end up having to commute to the Coventry Gateway project then and is contrary to a sustainable community and contrary to the declared aims of the Gateway project.

Infastructure

The current infrastructure is completely unable to meet the demands that would be placed upon it by new construction in the greenbelt to the North of Leamington Spa. This means that new land would be needed for a Northern Relief Road. Land that is so unsuitable for development that it requires a £28 million investment to make it suitable - again hardly justification for exceptional circumstances to build on the greenbelt. Professional opinion further suggests that this £28 million is an understatement and costs would be far higher. Furthermore this relief road would destroy the character of Old Milverton, one of Warwickshire's greatest villages. I believe this should not happen, particularly because Old Milverton is a conservation zone an "areas of special architectural or historic interest, the character or appearance of which it is desirable to preserve or enhance." It is therefore unsustainable to destroy such a village's character, and furthermore irresponsible after the residents have spent so many decades preserving their village for the council to destroy it themselves on the basis of inappropriate planning decisions. Additionally this development is a waste of council money, for although the cost of the relief road would be met by the developers if an alternative site was chosen this funding could be spent on other requirements for a new development required by the council, eg schools/cycleways. The problems with infrastructure costs also link back into arguments regarding the cost of housing to consumers; the housing developers are commercial companies and they will pass on the cost of building the relief road to those who go on to purchase the houses. The council has already recognised the importance of building affordable housing and therefore questioning construction in the already expensive North Leamington, but adding to the cost of housing due to the need for a relief road will only make the housing more expensive and inaccessible to the people, who like myself who cannot afford housing.

The recent disastrous modification of infrastructure in Jury Street Warwick demonstrate the poor ability of this country to develop it's infrastructure appropriately, and the public have no faith in the council's ability to successfully deliver such projects, therefore the insertion of a £28 million relief road is of great concern to residents, there is shockingly little evidence in the local plan as to how this would be successfully implemented and local residents can only fear it would be as disastrous as other plans without this evidence base; it is put in we believe as an afterthought to justify construction on the greenbelt land, and must therefore, along with it's concurrent development, be removed from the development plan.

The plan argues that turning the A452 between Leamington and Kenilworth into dual carriageway would be a benefit to the area, however a more thorough assessment by the council would identify that at peak times delays on the A452 result from commuters wishing to access the Town Centres, which a dual carriageway would do very little to improve.

The Northern relief road planned by the council will form an artificial barrier, which will encourage further unacceptable development that will further destroy old Milverton; risking such a development is inconsistent with the NPPF and Regional Spatial Strategy, as Milverton should be protected under policy RR1 of the RSS.

Housing Provision

I personally believe that there is an over-provision of housing in the preferred options plan, this occurs because the Council is relying on projections from a past period of exceptional growth, that is very unlikely to be continued. Furthermore even if the proposed housing demand was accepted then amazingly the preferred options plan could have the housing removed from the greenbelt sites without causing a deficit and this is without other (more suitable) alternative sites, as suggested below being substituted. Quite clearly therefore exceptional circumstances cannot be justified for construction on the greenbelt, and this wouldn't be accepted at later stages of the process if/when such a development was inspected/contested. For this reason I strongly believe that the result of the consultation should be the removal of construction from the greenbelt land, due to overprovision of housing alone (but with the potential for including other sites if the results of the consultation seem necessary). I feel particularly strongly that this argument should be accepted and included in the future plan for it was the leader of the council stated at the Milverton Parish Council meeting that if we thought there was overprovision of housing then we should say so. This must therefore be a valid reason to object and one I expect to be taken onboard.

SECTION 2: Need to consistently align Local Plan with West Midlands Regional Spatial Strategy

When I examine the evidence base for your plan, and in particular the Strategic Housing Land Availability Assessment I note that almost all the suggested rural areas are discounted because they conflict with RSS policy point RR1. It is clear that overwhelming importance has been placed on the policies in this document. This must be balanced with the important policies expressed in the National Planning Policy Framework which rightly protect the vital importance of greenbelt land.

However this RSS document includes policy QE14 that states that "Development plan policies should create and enhance urban greenspace networks by ensuring adequate protection is given to key features such as parks, footpaths and cycleways, rivervalleys, canals and open spaces". It is not recorded in the Strategic Housing Assessment that a footpath crosses the land between Northumberland Road and Old Milverton, but there is most definitely one there, marked on OS maps, and heavily used as a local amenity to people living in urban areas including Leamington Spa; this provides important health and lifestyle benefits. In the Regional Spatial Strategy each policy is given equal standing and therefore this policy is as important as RR1 which you have already used to discount so much other possible development land. It only therefore stands to reason that this greenbelt land too (as QE14 protects more than just the physical path, but also the green land around it) should be removed from the preferred options plan. Indeed the proposed sites L07 and even more so L03 are in my opinion some of the most highly used footpath and recreational natural green space areas in the district and must be protected as such.

The suggestion of ignoring QE14 and building on the greenbelt, yet leaving the footpath is logically unacceptable. The QE14 protects GREENSPACE, therefore there must be GREENSPACE around the footpath. (This is essential to it's use). The policy identifies that footpaths and parks are different and must both be protected. It is therefore unacceptable to put the footpath into parkland as this is entirely different. The footpath and the greenspace around it must be therefore be protected in their current form!

Furthermore the RSS also states in policy QE6 that; "Local authorities and other agencies, in their plans, policies and proposals should conserve, enhance and, where necessary, restore the quality, diversity and distinctiveness of landscape character throughout the Region's urban and rural areas by: protecting and, where possible, enhancing natural, man-made and historic features that contribute to the character of the landscape and townscape, and local distinctiveness." The greenbelt to the North of Leamington is quite clearly a natural feature of the landscape that contributes greatly to the character of North Leamington, Old Milverton and the surrounding area, and is essential to the local distinctiveness of these areas. This is clearly demonstrated in the huge number of signatures in petitions returned to the Council surrounding the proposed construction on these areas.

Furthermore the protection of villages under RR1 is quite inconsistent; land is being used incredibly close to Old Milverton for housing and particularly in the construction of the Northern relief road. It is been ignored that Old Milverton should be protected by RR1: "rural areas which are subject to strong influences from the MUAs and which are relatively prosperous and have generally good access to services. For these, the main priority will be to manage the rate and nature of further development to that which is required to meet local needs, whilst ensuring that local character is protected and enhanced." It is clear that Old Milverton is as strongly influenced as other Warwickshire villages from the key MUAs, it is relatively prosperous and the residents are quite contented with their access to services. Therefore just as development sites, for instance those neighbouring Radford Semele (and still contacting the Leamington Fringe), have been rejected on the basis of RR1 so should the developments between North Leamington and Old Milverton - neither these houses, nor the relief road, nor the infill that would surely follow the construction of these two things are meeting local needs, the character is certainly not protected nor enhanced.

In discussion with Daniel Robinson at Warwick District Council he informed us that the Old Milverton to Northumberland road site is labelled as "an extension of urban land that happens to come close to Old Milverton", not as a rural site in itself, this is not consistent with sites eg R46 which is equally an extension of urban land that happens to come close to Radford Semele but is protected by policy RR1 in the RSS document. These inconsistencies persist throughout the SHLAA.

SECTION 3: More Appropriate Sites

Previously identified viable sites

The quite remarkable problem with the Council's plan is that a previous plan (Core strategy plan 2010) identified ample land within the district without resorting to construction on the greenbelt, this fact alone means that there must be adequate land elsewhere to build on, thus there cannot be exceptional circumstances to justify construction on the greenbelt land, when nothing significant (except the publication of the National Planning Policy Framework stating that greenbelt land should not be built on unless exceptional circumstances) has changed in the district. Indeed during this consultation the council has suggested that people objecting to the greenbelt land use must not just state they don't wish that land to be developed, but suggest alternatives; I propose to you that at least one valid alternative has already been part validated is the Core Strategy Plan and this can be used as a solution to ALL THOSE PEOPLE who are objecting to the greenbelt. At the Milverton Parish meeting the a senior officer of the council suggested changes had been made to the Core Strategy Plan's of building in the South due to infrastructure problems, however this is hardly sufficient to justify building in the North; a significant infrastructure investment in the South (akin to the Milverton relief road proposed for the North) could sort out the infrastructure problems there, and whilst significant investigation has gone into the South's infrastructure and congestion problems woefully little has gone into examining the North. In short selective investigations have been completed to rule out land the council has decided not to build on, whilst no such investigation has gone into land they do wish to build on. A carefully examination of current and future congestion in the North should have been completed before the plan was decided on (not after), it is now impossible to complete a post-hoc analysis without bias creeping in to favour development in the North. It is very clear from the congestion currently in the North that already exists that further development would only exacerbate this, whilst the South is already better placed with easy access to the M40.

Warwick District Council have argued that land in South Leamington is not as attractive to developers because concentration of development in that area may result in developers making less profit - financial gain quite clearly cannot be expressed as a "very special circumstance" to permit unnecessary development in the Geenbelt land.

Radford Semele

There is ample room to move a significant number of the greenbelt housing allocation into and around Radford Semele. This preferred options allows for 500 houses in Category 1 villages, this a low proportion relative the total requirement and across the Category 1 villages which are not in greenbelt land there should be a significantly more houses planned for there. The preferred options document does not identify those specific sites surrounding villages that are suitable to meet the 500 houses target, not only should this be done but it is very likely these villages could absorb more accommodation, potentially even a doubling and this would be preferable to current plans to build on the greenbelt.

Whilst at Radford Semele there is a possible argument against coalescence significant sites still remain; R67 and R41 total 11.16 acres, and seem to have been excluded due to the presence of gas mains, these gas mains require a 100m exclusion zone, however both sites could in fact be extended towards the gas main and remain outside the exclusion zone. Indeed the garden town approach to development would easily allow these exclusion zones to be incorporated into the required green space and cycle-ways that the council is so keen to provide. Professional advice suggests there is significantly more housing that could be built in this area near the gas mains and still conform to planning law, it is essential the council reconsider this and identify how to extend the provision in this non-greenbelt land. Furthermore the site boundary of R41 does not seem to follow and fence or hedge line and could therefore be extended significantly, even if there is a fence/hedge line the site could still be extended to include more land to boundaries further out, or boundaries could be completed. Flooding risk to the Warwickshire Exhibition Centre is stated as a risk, but this is over a km away and is of negligible import - this needs to be reconsidered and potentially simple flood alleviation methods installed. Furthermore site R56 to the West of Radford Semele was also identified as being suitable subject to alleviation of flooding issues and is an excellent site given that it would not contribute to coalescence, again the garden town approach to the development would allow the incorporation of flood alleviation schemes, and thus these schemes and this site (potentially also enlarged) would be far preferable to construction on the greenbelt. Any risk of coalescence between Radford Semele and Leamington is dwarfed in comparison to the consequences of risking coalescence between Leamington and Kenilworth/Coventry as produced by building on the Northern Greenbelt and it is far preferable to build here; indeed almost all towns across the UK have grown by inclusion of local villages and there is little reason why the open space between Radford Semele and Bishop's Tachbrook should not be used such given this is not greenbelt land.

Grove Farm

Grove farm also could provide additional housing, removing the need to build on the greenbelt; L09 we are told by David Barber (via Councillor Bill Gifford) has not been developed for the main reason of coalescence, but even if this site was developed there would still be 1km between built up areas, this would provide a suitable green wedge, though personally I believe building on this wedge would be preferable to building on greenbelt land. Indeed significant areas of land have been discounted as they would result in coalescence or the destruction of a greenwedge; however discounting these sites whilst building on greenbelt land is contradictory to the national government policy outlined in "Strategic gap and green wedge policies in structure plans: main report." The document states "There would be significant problems in giving strategic spaces and green wedges the status of greenbelts. Strategic gaps as greenbelts would reduce peripheral land development options on the edge of large settlements, often in sustainable locations. Problem over the interpretation of prominence and the possible need for safeguarding land would also occur. If green wedges were given Green Belt status then the area covered by a strong presumption against development would be more closely drawn into cities and large towns". This demonstrates that the status of greenbelt is above that greenwedges, so the wedges should be built on fir
Other Sites

Site L09 should be reassessed as it is more suitable than the greenbelt suggested to be built on, the problems outlined in the SHLAA are less than the problems with building on the North Leamington greenbelt. Site L09 is not in greenbelt land, objections that the land would need employment and infrastructure are no different to the problems identified with the greenbelt land the council intends to build on, and the development of the countryside is not an serious reason not to build on the land when in contrast you want to build on the greenbelt. The topography would not provent sensibly designed/developed housing.

It is quite simply idiotic that site W07 is not being built on, currently the council propose building on greenbelt land rather than improving the county by building on slurry contaminated land, which is in my opinion effectively brownfield land. Indeed the council even identify it as suitable for development once ground remediation work is completed.

W03 is exactly the same - it slurry contaminated land, identified as suitable for development after ground remediation works should be built on prior to brownfield sites. The arguements in the SHLAA regarding whether the market could support it is bizarre - if the market cannot support such land then certainly land to the North Greenbelt requiring a £28 million+ relief road isn't needed because there wouldn't be demand!

Furthermore considerable research and indeed I believe actual inclusion in the plan should go into the development of a new village(s) to the South of the district in the extensive non-greenbelt land there, such virgin land would be hugely attractive to developers, and there is ample space to build such a site without contacting existing rural settlements and therefore avoiding harming their character. Indeed I issue it as a challenge to the council and the planners to include such a site, using imagination to create a garden village, which would be a true innovation in our district and one of which all local residents could be proud.

Whilst it is clear that a plan such as the Preferred Options plan produced by the council cannot be expected to please every resident in every area of the town, it is the council's responsibility to listen to arguments that are based on clear planning policy and supported in numbers. The arguments produced against development of the North Leamington greenbelt are backed by a substantial number of residents and backed by firm planning policy either National (eg the National Planning Policy Framework), Regional (The Regional Spatial Strategy for the West Midlands), or Local (ensuring development is in accords with WDC's aims as stated in the consultation document). Opposition in the South from my experience is centred around a lack of infrastructure, schools, and an over-burdening of development there. None of these are firm planning reasons; the council have very clearly identified that local infrastructure can be put in place by developers and the M40 provides an excellent foundation for this countering that argument, wherever there is new development there will be new schools and the council must do more to persuade residents that this will be the case, and finally the concerns of overdevelopment are a "NIMBY (not in my back yard) argument backed up by no sound planning arguments - indeed there are plans to build a New Mildland City in the Meridian Gap is supported by national planners and shows that this region has the need and ability to support a substantial amount of housing in one area, and whilst nothing of this size is proposed for Warwickshire it quite clearly demonstrates that whatever the council proposes it would not be an overburden in an area that in now way risks coalescence with another town.

SECTION 4: National context

It is vital that all those involved in the consultation process do not become blinkered in their view, but respect the national context within which this plan stands. The importance of the "National Planning Policy Framework's" AND "Strategic gap and green wedge policies in structure plans: main report protection of the greenbelt land" have already been highlighted, as well as the failure of the current plan to take account of these - which I imagine will be a major problem when the plan is submitted to the inspectorate. There is however even more evidence of the importance of greenbelt land, which should be considered with regards to this plan.

The government's original proposals for planning policy (the draft national planning policy framework) provided very little protection to the greenbelt land, however it was immense public opposition to this with nearly a quarter of a million people signing a petition organised by the national trust (a scale unprecedented for a planning policy document) that resulted in greenbelt land being protected as per the final document, and as ignored by the preferred options plan. This clearly shows however the immense value the nation place in greenbelt land, and in the protection provided for it by the National Planning Policy Framework. The preferred options plan fails to take account of this and residents in the North, myself included feel it is of national importance to ensure the NPPF's protection are not ignored, particularly by an executive committee of the same political party as the government who instituted the plan, and we believe we would have national support if our arguments were to be wrongly ignored during the consultation. It is afterall the people of the nation that we wish to attract to Warwick District to live, work and play!

SECTION 5: The consultation process

Omissions from Consultation

Whilst trying to understand the Council's reasoning for what seems to be a highly unusual plan it has come to my attention that there are two key omissions from the consultation that are either being used as justification for the plans submitted, or used to contradict local residents views and arguments, this does not make for a fair consultation and produces the view held by many that the council are determined to build on greenbelt land to the North, and then find any planning evidence/arguments that justify their desires. This is not a sound grounds for consultation and it can only be made fair if such arguments are ignored. My chief concerns are listed below.

Senior individuals within the council have stated that previous opposition to development in South Leamington, particularly around Bishop's Itchington have prompted the need to force development on the greenbelt in this plan. If this were to be a valid basis for planning then it is of vital importance that such information is included in the consultation document - yet it is not. The absence of discussion on this matter within the consultation document, as well as the fact that this would result in a plan based on a popularity contest/political pandering rather than sound planning principles means that additional development in the South should not be excluded with resultant development on the Northern greenbelt. There has been tremendous resident opposition in the North (see submitted petitions of over 2000 individuals) alongside strong planning arguments dictated by National Planning Policy, which the council are compelled to follow, and on which basis the plan will be judged when sent to the inspectorate. It may not be possible to please all residents with the subsequent plan to develop the town, but the council's responsibility is to listen to the views of this consultation and build their plans based on the views of local residents that are supported by sound planning arguments.

Another senior member of the council has stated that the need to develop on the Northern Greenbelt stems from a need to provide worker accommodation for subsequent employment land at the Coventry airport site. However it is not identified in the consultation that such land has been allocated for this purpose and it would be impossible to allocate such land at the stage for which the consultation document was written (and the greenbelt land assigned to development land) as the document states with regards to the Coventry gateway site that "It has the potential to provide in the region of 14,000 jobs as well as facilitate major improvements to the transport network. The Council is supportive in principle but considers that further work is needed to justify the identification of this site." The (very senior) officers justification of such a site for Coventry housing is therefore an afterthought, not explained in the consultation document with no evidence base to suit such a project and a major omission from the consultation document. Furthermore such a claim that the land is to be used for commuter land with respect for Coventry is inconsistent as land closer to Coventry has been identified as suitable for development, yet not included as suitable land for the construction of housing. Additionally there is a huge expanse of greenbelt land between the proposed North Leamington greenbelt site and Coventry which would be closer, with reduced environmental/congestion impact that would be suitable for that housing. It is totally impossible to justify exceptional circumstances to build on the greenbelt to the North of Leamington for such a development in Coventry without a detailed analysis of the situation, which should be provided with evidence.

A further key omission from the document is that despite Warwick District council performing a study of greenbelt land between Old Milverton and Blackdown, which concluded that these areas had high greenbelt value, this information was consequently rejected from the consultation document, or if it exists and I cannot find it - then it certainly has not been used to sufficient extent.

Expectation that resident views/submissions to consultation will be ignored

I am deeply concerned about the nature of this consultation process, and I like very many other residents feel that our views will be ignored despite strong objections by letters submitted to yourselves, petitions, and exceptional attendance at public meetings such as the North Leamington Community Forum and Milverton Parish Council. Indeed we have been told one member of the council explicitly stated that residents should get used to the plan as it would go through regardless - quite clearly bringing into question the fairness of the consultation. National government policy states the importance of localism to ensure that the views of local people not ignored and I believe the council must take the views of North Leamington residents on board, and act on them.

The consultation process has asked for the views of local residents, which I believe have been strongly voiced in terms of not building on the greenbelt land to the North of the town. I believe it is the councils responsibility to listen to these views as part of the consultation, take them on board and change their plans accordingly. It is not the councils responsibility to argue with these views, cite counter evidence, or employ professionals to create reasons/argument to ignore such views. Indeed the council's documentation for the consultation has not provided all evidence that was used to create their plans, therefore limiting residents to only being able to provide their views and not assess and counter all the evidence. All residents could therefore do is provide their views, which must then, in my opinion by listened to and acted on, as there is nothing else they could provide. Furthermore the document is referred to as the "preferred options plan" however there are NO options as to which land could be built on, therefore as local residents have objected to construction to land on the greenbelt the council must then seek alternative land and submit this to the second consultation round with the greenbelt land removed. The council must not ignore over 2000 residents views resisting construction on the greenbelt because the residents (who are not planners) have not all identified land elsewhere, there is as demonstrated here alternative land, and it is the councils responsibility to search an alternative option.

The strength of opposition I have seen from local residents to not building on the North Leamington greenbelt demonstrates that if the council fails to take on board views of the residents as a result of this consultation then I firmly believe those views will only be expressed more strongly in the second period of consultation and stronger still following that if our views continue to be ignored. I and others would have no hesitation in involving national groups and media attention in opposing these plans, which I and others so strongly object to. It is irresponsible of the council to risk a failed plan. The council have repeatedly told us that if a plan is not submitted and accepted then developers will be free to build wherever they want and there will be a lottery of developments (this sounds remarkably like a threat to residents not to submit their views and oppose the plans), however in fact it is the councils responsibility to ensure that we are not left in this situation by taking on board, and acting on the locals views. It will be their fault, not ours if we are left without a plan. Furthermore it would be foolhardy of the council to risk the phenomenal cost in fighting local residents legally, on which I believe the council would have little no grounds to proceed, there are many far better things to spend money on. From the strength of opposition I have witnessed I have little doubt that if the council ignored North resident views then there is the demand and resources to pursue this fight further.

At a recent Milverton Parish Council meeting the chairman of the council announced to the approximately 150 people there who opposed the plans that they should not write to their local MPs. The people at the meeting had widely expressed their view that the council had failed to put in place National Policies developed by their MPs' government. I, and everyone else there saw it as entirely appropriate to write to our MPs, but again the Council seemed determined to allow nothing to influence their views and seemingly politically motivated plans for the county. This is furthered by the title of the consultation document - "Local Plan Preferred Options" for a plan that does not contain a single option as to the provision of housing land.



Online Submission Form and Information Provision

The online submission form that Warwick District Council has as the main way to register submissions to the consultation is not fit for purpose. Firstly the system is incredibly complex, with the need to register to even access the system, and once there a bizarre system that took me a considerable amount of time for me to fathom, once completed you must object on particularly items/sites - this is despite the repeated messages from the council that they do not wish people just to object but to provide solutions and say where they would like to build. The system is not fit for this purpose. In fact I have not before seen such a poorly designed online data collection tool. Furthermore a considerable number (of intelligent computer literate) people have failed to access they system and to understand how it operates. These points suggest to me that the council is less than interested in the views of the local population, for it would not have been difficult to design a far simpler, user friendly system, accessible to the young/old alike.

Leamington library has been advertised as a location of consultation information; however this could only be viewed once asking at the desk, from whence a box containing the information was produced. If the council genuinely respected the views of local residents an eye-catching display could be simply and cost-effectively be erected to attract attention. Similarly when visiting Warwickshire College to view the information, reception at the College did not in fact know that the information provision existed, it was only after ringing the council that the information became apparent.

These points are not intended to be taken as a "moan" but rather when taken together they demonstrate that it is not surprising that residents of North Leamington feel that their views will be ignored, and it is essential that the petitions and letters such as the one above are taken onboard and acted upon by the council to ensure the North Leamington Greenbelt is protected.

Concluding Remarks

The plans as they stand are totally unacceptable in that they involve greenbelt on the land to the North of Leamington Spa. In particular the land to the North of Northumberland Road and South of Old Milverton is one of the most used pieces of greenbelt in the whole district, with immense amenity and health benefits. The planned construction in the greenbelt is contrary to the national policies of the "NPPF" and "Strategic gap and green wedge policies in structure plans: main report." The immense local opposition to this plan and the National Policy of Localism mean the greenbelt sites to the North of the town should be excluded permanently from the plan.

The council has a choice; they can devastate the character and attractiveness of a unique Royal Spa town, that has been cherished and lovingly developed for centuries OR the council can seek an alternative option. The alternative option will need their imagination and determination to build on the views of the populous, but it will build a town of which we can be rightfully proud for decades to come.

See Attached Letter

See Attached Letter.

I am writing in response to the above publication issued by the council to object to what seems to be ill thought out scheme. It would appear that the aim is the development to provide a vibrant and thriving town where people want to live, work and relax which at first glance seems to be a good idea but in the current economic climate (which I see extending well into 2015 and beyond) I think this could be misguided when money is tight. We need to extract maximum gain for minimum outlay.
You aim is for 555 home per year but there is little information contained within as to where this figure has come from and what the make of the proposed resident taking up these homes? When I'm out and about in Leamington it seems to me that the population is aging or old judging by the number of care homes in the district, has your proposal considered this and their requirements as it's a well-known fact that we are all living longer? With the on-going lack of finance to purchase these properties is the council proposing some sort of assistance? Or are we going to end up with ghost estates? The old Potterton site has been re-developed and a good proportion of that is still empty and unsold from what I can see.
Following on from this as a landlord I know in certain areas these empty properties are been taken on by housing association to provide affordable housing but depending on the number this could result in a highly desirable estate being tainted and the home owners losing out big time as a result. So again this could deter people from relocating to Leamington
You say that you want 40% of the housing to be affordable but go into no detail on how you intend to achieve this as this is one of the most expensive areas to buy property? And more importantly keep them affordable long term? Will you ensure all such residents have covenants that prevent tenant ownership and if so how would you enforce it?
Is the council intention to ensure that these new developments have been designed to promote a safe environment and reduce any policy costs going forward?
What steps have the council taken to assess the effects that the proposed Milverton development would have on the water levels in the area considering this area is surrounded to the north and west by the river?
Going by the contents of the summary I do not see any exceptional circumstance to warrant the destruction of the green belt, which once gone cannot be replaced and is conytrary to the National Planning Policy Framework. To the north of Leamington these is limited local amenities. And I know from my daily walks with my dog the vast range of wild life that exist in the proposed Milverton area from bats, newt to a vast array of birdsong which lifts my heart every time I hear it regardless of the weather. I also know the vast number of dog walkers, runners, cyclists and ramblers from around the district that make use of and enjoy these limited facilities
Also by the fact that you have identified non Green Belt land that could be used, and that developers probably already have options on, and that you have discounted then I am certain that owners of this land in conjunction with developers will gain planning permission on appeal resulting in a vast over provision of land to the detriment of the town and its residents
You state that you want to ensure that people who work in the district have the opportunity to live here but what has this decision be based on as I suspect judging by the morning jam that the majority of residents actually work in the surrounding district or further afield judging by the station platforms for the rush hour trains to Birmingham and London
You state that you want to reduce through town traffic, this I am sure is of concern to existing traders in the town centre and likely to deter any new venue looking for a location as this is likely to reduce footfall and likely income
What is the situation with empty properties within the district? What percentage are empty? What steps are being taken to get them back in to use, is the council using any incentives?
To my mind from the above points the starting point in developing a local plan would be to look at the logistical issues inherent in the district which I see as
* Leamington is split in half with a band that covers the river, canal and railway line - with only 4 historic crossing points
* The vast majority of the Leamington trading and industrial estates, that will form the majority of the employers locally are south of this divide
* To the west Leamington butt up against Warwick so the scope for doing anything in this area is limited, especially as the division is again reinforced by the river
* The ultimate boundary to the north is fixed by the A46
* The ultimate boundary to the south is fixed by the M40
* The vast majority of the out skirts of the town to the north and east areas are bound by green belt
* There are only two routes between Leamington and Warwick that are divided by the river

Bearing the above points in mind any plan should to my way of thinking:
* Be geared to address the bottle neck in getting around in the district so to this end it should be to improve the means of negotiating the river/canal/railway line with consideration to
o introducing a crossing to the east of the town and a ring road joining Heathcote Whitnash and Cubbington and improving the West Hill Road out to where it joing the A452
o introducing a link across the river to link the two roads between Leamington and Warwick to provide more travel flexibility
o improving the capacity of the fossway to provide an alternative transport path with the introduction of roundabouts at dangerous crossing point
o improving the A452 so that it provides a main transport path as it "A" rating denotes rather than being controlled by feed from minor roads at Shires Park and Chesford Bridge
o improving transport paths in Kenilworth to provide ring road to the west
* improving the local rail infrastructure to provide an alternative means of getting between Leamington, Warwick and Kenilworth say the introduction of minor stations at milverton, sydenham, whitnash, emscote, hospital/race course with regular service supporting these stops are peak hours
* Improving bus service by proving circular routes rather than the usual star systems
* Ensuring that it does not exacerbate current transport aspects within the district developing north of the river when industrial and trading estates are south of the river is simply not logical
I my view the proposed introduction of a northern relief road through Old Miverton will not achieve the desired result as it will simply put more loading on the Old Milverton Road (which is not included in your proposal for upgrade).and the A445. Also are residents going to take a 5 mile roundabout route when they only want to go 0.5 mile up the road?. The introduction of this road will also result in the destruction of Old Milverton and be the start of the coalescence of the urban area between Leamington and Kenilworth.
I'm not convinced either that a park and ride scheme is the right way forward and would like to see what basis the council has for this and its cost effectiveness. I know when I pass the one in Stratford (which is a location with far greater attractions and hence visitors) always seems to be empty.
The first time I used the A46 after the M40 junction was modified to improve traffic flow I was elated until I arrived at the roundabout which to my mind will simply backup the congestion to that point . Why this roundabout wasn't situated below the road with slip roads to it I simply can't understand. So let's try and do better going forward.
Finally one area that I see as missing from you plan is an ECO goal, I know that you mention climate change, reducing carbon emissions and the like but I think the council should be championing measures well beyond anything given in national sustainable construction. There are a number of developments around the country when innovative design has been applied providing high density housing whilst still providing tenants with the same levels of outlook on a normal estate. Again I was excited when it was announced that the old Potterton site was to be redeveloped but I am ashamed every time I drive past as it could have be used to provide an indication of a forward thinking council.

I came to live at my present address mainly because of the pleasant views acoss the green belt countryside close by,which I was assured would not be built on. I am now informed that there are plans to do this even though there is non green belt land available elswhere in the Leamington Spa area.
I stongly oppose the the planned developement for the Milverton and Blackdown area as it will be further encroachment on the countryside and will be another step towards linking up with Kenilworth and destroying the pleasant character of Leamington Spa.
For the last few years I have lived under the threat of increased air traffic from Baginton airport, the theat of HS2 in the area and now the threat of green belt developement. Am I glad I moved to live in North Leamington ?

I am writing to express my concern regarding the development proposals on green belt land to the north of Leamington.

My first concern is the proposed road across this area. If it is built we all know that the next phase will be to build right up to this road and then the complete green belt between this road and the north of Leamington Spa is destined to disappear.............

This brings me to my second concern which is the village of Old Milverton. The road will ruin one of the last remaining villages near to the town, by its proximity and resulting visual and noise pollution. This small, ancient settlement is a local beauty spot used by many locals and visitors to the area via walking routes and the path to and from the Saxon Mill. Its facilities ( church, hall and fields ) are enjoyed by many individuals, associations and the general public. A busy (fast) road nearby will ruin this very little corner of old Warwickshire.......

My third concern is that this proposed road will not really ease the congestion into Leamington from the North. Most (all?) business are in either central or south Leamington, so traffic will remain to be funnelled through Leamington as once Northumberland road is reached then these same problems will continue. People will still prefer to sit in their cars for longer than get out and do a park and ride .........

Fourthly, following on from my third point, building homes in this area will only add to the congestion on this route as more people will need to get into work ( more than likely to central and southern Leamington ) via this route......

Fifthly, our housing need is for simpler, affordable homes. This means cheaper land costs. This will not be to the north of Leamington. We need to take the security of our future generations into account and a survey out a couple of days ago highlighted the need for young families to feel secure, and own, or have secure tenancies, in their homes. We need to enable this fairness as much as we possibly can. Simple homes for families are crucial to the health of our community and our country.......

These are my main concerns and objections to the development proposals. Please take them into consideration. The historic triangle of Old Milverton, The Saxon Mill and Guy's Cliff should remain on the boundaries of Warwick and Leamington, undisturbed, for as long as we, the guardians of our heritage, can allow.

With many hopes and wishes for a decision against these green belt proposals.

1. BLACKDOWN / WESTHILL: The Joint Green Belt Study you yourselves commissioned in 2009 to form part of the evidence base to inform the respective authorities Core Strategies assessed the relative "value" of a number of parcels of Green Belt land around Warwick and Leamington.
The study concluded that the parcel of Green Belt land WL7 (Blackdown/West Hill) when measured against the five criteria for the purposes of Green Belt land as set out in Planning Policy Guidance 2 : Green Belts ('PPG2') was of such high value in terms of its contribution to the purpose of Green Belt that it should be retained as Green Belt land.
2. The Joint Green Belt Study 2009 also referenced the Planning Policy Guidance 2 : Green Belts ('PPG2') in para 2.3.5 where it states in relation to the uses of the land within Green Belts that:
"the extent to which the use of land fulfils these objectives is however not itself a material factor in the inclusion of land within a Green Belt, or in its continued protection. For example, although Green Belts often contain areas of attractive landscape, the quality of the landscape is not relevant to the inclusion of land within a Green Belt or to its continued protection. The purposes of including land in Green Belts are of paramount importance to their continued protection, and should take precedence over the land use objectives". And further in para 2.3.7" Once land has been identified and allocated as Green Belt land, the boundary of the land should only be altered in exceptional circumstances and when all opportunities for development within urban areas contained by the Green Belt has been explored."
The recommendation that WL7 remain Green Belt was made on the basis of the purposes of Green Belt land.
3. The New Local Plan Preferred Options May 2012 in para 7.32 states:
"Assessment of Green Belt land to the north of Warwick and Leamington in the Joint Green Belt Study concluded that the land bounded by the A46 in the west, the River Avon to the north and Sandy Lane to the east was worthy of further study. This was largely because there were no other towns to the north, from which the Green Belt would provide protection from encroachment, but also because there were other physical barriers to the wider open countryside. The Green Belt assessment suggested that the land at Blackdown was not suitable for further study. However, the land has similar characteristics to land to the west in that there are no towns to the north, from which the Green Belt would provide protection from encroachment, and there are clear boundaries to the site to protect the open countryside beyond."
The above paragraph is not correct. It misrepresents what was reported in the Joint.Study The New Local Plan states "The Green Belt assessment suggested that the land at Blackdown was not suitable for further study" in fact the study concluded: "We recommend WL7 is wholly retained within the Green Belt." The study then went on to exclude WL7 (which is the area of Blackdown/West Hill) from any further consideration.
This was not the case with the parcels of land bounded by the A46 in the west, the River Avon to the north and Sandy Lane to the east (includes WL6A and WL6B) where the study concluded "We recommend that this area is considered for further detailed study, but that the majority of it is retained within the Green Belt."
Further the last sentence "However, the land has similar characteristics to land to the west in that there are no towns to the north, from which the Green Belt would provide protection from encroachment, and there are clear boundaries to the site to protect the open countryside beyond." Is not supported by the finding of the Joint Green Belt Study 2009. which concludes in the case of Blackdown/Westhill WL 7 "Our view is that the existing road system strongly defines the existing settlement pattern and urban expansion into this area would be difficult to justify. We recommend WL7 is wholly retained within the Green Belt."
Study Area WL 7
Study Area
Description An area known as Blackdown Hill and West Hill to the north of Leamington, bounded by Sandy Lane to the west, the A4113 to the
northwest, field boundaries beyond West Hill road to the north east
and the A445 Leicester Lane (the urban edge) to the south.
Landscape
Character The area lies within the Arden character area and the Arden
Parklands character type. The area is principally arable agriculture,
but there are some substantial (former?) residential premises - most notably West Hill house.
Visual Issues Visually diverse due to local topography, trees and hedges. The
housing along Leicester Lane is quite visibly prominent and creates a strong edge to Leamington.
Historic and
Cultural Issues No historical information gathered. Some declining estate parkland
noted. The manor of Blackdown held by the eminent royal gardener, Henry Wise, in the early eighteenth century. One footpath - to West Hill house.
Ecological
Features Woodland, hedges, hedge trees, permanent pasture.
Landscape
Condition Reasonably good.
Conclusion /
Recommendation Our view is that the existing road system strongly defines the existing settlement pattern and urban expansion into this area would be difficult to justify. We recommend WL7 is wholly retained within the Green Belt.
Score for
Landscape Value WL7 - 3 (High Value)
Study Area WL 6A and 6B
Study Area
Description WL6a and 6b lie north of Leamington and are defined by the rail line to Kenilworth to the west, and Sandy Lane to the east, the urban edge to the south and the river Avon to the north. 6a and 6b are split by Kenilworth Road (A452).
Landscape
Character The area lies within the Arden character area and the Arden
Parklands character type. The area is principally arable agriculture,
but there are a variety of urban fringe land uses.
Visual Issues The principal route through the area is Sandy Lane and from this road there is a fair level of enclosure from hedges and hedge trees. It is easy to miss that the Avon valley lies just over a crest. The existing urban edge seems well defined.
Historic and
Cultural Issues No historical information gathered.
One east-west footpath noted north of the suburb of Milverton
Ecological
Features River valley, hedges, hedge trees, some pasture.
Landscape
Condition Some urban fringe degradation. A 'disc golf' course (Sandy Lane)
may be on the remains of an area of parkland. Some 'horsiculture'.
Arable agriculture quite intensive. Some new hedge and tree planting would benefit landscape character.
Conclusion /
Recommendation In general the transition from urban to rural is successful - with
schools, playing fields and allotment gardens helping to create a
successful transition to arable based agriculture. At Blackdown,
adjacent Kenilworth Road, there is the Nuffield Hospital, 'Woodland
Grange' conference centre and other large commercial premises -
and there could be opportunities for additional development of this
kind. We recommend that this area is considered for further detailed study, but that the majority of it is retained within the Green Belt. Public access routes might be improved.
Score for
Landscape Value WL6a - 2 (Medium Value)
WL6b - 2 (Medium Value)
4. The Council's own reports and studies show that the case for WL7 Blackdown/West Hill Green Belt remaining as Green Belt is fully made out.
5. GREEN BELT
There is overwhelming support from the local public consultations for Green Belt land to be protected. Extracts from Warwick District Local Plan Key Issues Report, Report of public consultation September 2002 found:
3.3.3 Managing our growing district
* We should strongly resist building on countryside and on open space within our towns.
There was a very strong consensus that we should make best use of land with our towns before using green field land on the edge of towns. In the leaflet questionnaire, 91% of respondents either agreed or strongly agreed we should do this, and 89% said we should not build on Green Belt land or high quality farmland. Support was also given to protecting all green open spaces within towns (91%) and avoiding building on areas of wildlife value (92%).
Respondents to the Key Issues Report were asked which of the major landscape designations in the present local plan (Green Belt, Areas of Restraint, Special Landscape Areas and open countryside) are most important for defending the countryside. Whilst several respondents felt all to be equally important, and several others highlighted more than one, Green Belt came out as the most important, followed by open countryside.
3.3.6 Employment
* Protecting the countryside and open spaces should also be a high priority The Key Issues Report asked respondents whether they agreed that we should protect certain types of land from employment use. There was strong support for all the types suggested; Green Belt land, high quality farmland, open spaces within the towns and areas of wildlife value.
6. The Councils own policy documents and national policy documents all require non Green Belt land to be fully utilized before Green Belt land is considered. The New Local Plan Preferred Options May 2012 in para 7.29 states
"7.29 In the case of meeting the housing needs of Warwick, Leamington and Whitnash, the SHLAA identifies a potential capacity within the urban area of 650 dwellings on sites of 50 or more. Outside of the built up area, and outside of the Green Belt, the SHLAA identified a capacity of 7,200 dwellings. These sites are concentrated in the area around Europa Way, Gallows Hill and Harbury Lane as well as to the south and east of Whitnash."
Given the Council has identified sufficient space to meet its development requirement, outside the use of the Green Belt land, the Council's own policy documents and National policy documents require the use of that non-Green Belt land before the use of Green Belt land.
The New Local Plan Preferred Options May 2012 in para 7.27 further states:
"7.27 Exceptional circumstances can include the need to accommodate housing and employment growth to meet the needs of a community where there are insufficient suitable and available sites outside of the Green Belt. Where it can be justified to review the Green Belt boundary in order to accommodate development, it is necessary to assess Green Belt land in terms of its contribution towards the five "purposes" of including land in the Green Belt (NPPF Para 80). The Joint Green Belt Study carried out such an assessment of parcels of Green Belt land on the edge of Warwick, Leamington, Kenilworth and Coventry..... "
In the event the Council seeks to establish exceptional circumstances then the Joint Green Belt Study 2009 identified on the basis of "purposes" that WL7 (Blackdown/West Hill) should remain as Green Belt.
6. The New Local Plan Preferred Options May 2012 in para 7.22 states:
" 7.22 The sites/ locations which have been identified would allow for the development of 8,360 new dwellings. This is over and above the balance of the requirement of 6,986 so would give an element of flexibility of about 1,370 dwellings. This flexibility allows for two potential courses of action:

* To enable some sites to be removed from the allocation proposed in the draft Plan depending on consultation and any further evidence that is provided, and/or
* To provide housing to support a Regional Investment Site in the vicinity of the A45/A46 Junction close to Coventry Airport (the Coventry and Warwickshire Gateway) if further research demonstrates that this is a suitable location (see section 8)."
The over allocation of the development requirement, gives the Council the flexibility to protect areas of the Green Belt and enable WL7 (Blackdown/West Hill) to remain as Green Belt without adversely impacting the Council's Local Plan.