Preferred Option: Provision of Transport infrastructure

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
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.

Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.

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.

A "Northern Relief Road" (budgeted cost £28m) is not required. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns. If the development does not go ahead the road will not be required.
It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost.

This land has great recreational value to the local and wider community. These proposed developments would devastate the setting and special character of Leamington Spa

Please reconsider your Preferred Options.

Although I am in favor of more cycle ways throughout the county, I am very disturbed at the thought of one going right across the middle of Kenilworth Abbey Fields. It is illegal at present to ride a bicycle there and the reason is obvious. Abbey Fields was planned to be a safe relaxing place away from the noise and bustle of the town.

It is young children's safety I am particularly concerned about - how can you guarantee they won't run onto the cycle way and get knocked over. Is there any way the cycle way could be fenced off? The route on the map seems to show it going close by the children's play area, the swimming pool and the lake - all heavily populated areas of the park.

Lots more consultation needs to be given to this idea.

I have submitted several objections via the new local plan website , but further to this is a summary below of my objections.

National Planning Policy Framework requires "Very Special Circumstances"
* * The fundamental aim of Greenbelt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.
* * The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built.
* * However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), was identified and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.
* * Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong.
* * Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.
The Green Belt
* * The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value
* * The National Planning Policy Framework (NPPF) 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. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.
* * The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1⁄2 miles encouraging the merger of these two towns and their loss of independent identities.
Recreation Value of Old Milverton and Blackdown
* * The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, riders, and cyclists. It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to be enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park land would detract from, rather than enhance its value.
* * Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.


* Proposed New Roads
o * Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
o * Building nearly 3000 houses north of Leamington will simply increase the congestion.
o * The dual carriage way will have a detrimental effect on the picturesque northern gateway to Leamington and
southern gateway to Kenilworth.
o * A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns. If the development does not go ahead the road will not be required.
o * A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
o * If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".
o * New Out of Town Stores
o * The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live. Further "out of town" shopping will take trade away from the Towns.
Loss of Agricultural Land
* * There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton
* Number of Homes included in the Forecasts
* * Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

I have submitted several objections via the new local plan website , but further to this is a summary below of my objections.

National Planning Policy Framework requires "Very Special Circumstances"
* * The fundamental aim of Greenbelt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.
* * The Government's National Planning Policy Framework requires there to be "very special circumstances" for development in the Green Belt. It also requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the special circumstances are that there is nowhere else for the homes to be built.
* * However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), was identified and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.
* * Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong.
* * Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.
The Green Belt
* * The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value
* * The National Planning Policy Framework (NPPF) 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. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.
* * The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1⁄2 miles encouraging the merger of these two towns and their loss of independent identities.
Recreation Value of Old Milverton and Blackdown
* * The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, riders, and cyclists. It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to be enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park land would detract from, rather than enhance its value.
* * Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.


* Proposed New Roads
o * Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
o * Building nearly 3000 houses north of Leamington will simply increase the congestion.
o * The dual carriage way will have a detrimental effect on the picturesque northern gateway to Leamington and
southern gateway to Kenilworth.
o * A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns. If the development does not go ahead the road will not be required.
o * A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
o * If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".
o * New Out of Town Stores
o * The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live. Further "out of town" shopping will take trade away from the Towns.
Loss of Agricultural Land
* * There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton
* Number of Homes included in the Forecasts
* * Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

I am writing to you to lodge my objection against the development of housing on Green Belt land in North Leamington Spa.

The land proposed to be developed to the North of Leamington, in the area of Old Milverton, is an important amenity to local people for exercise and recreation, as there is very little other publicly accessible space in this area. It is vital to the health and wellbeing of the residents of this area that they have continued access to such existing amenities.

Additionally, this designated Green Belt should not, in my opinion, be developed, the very nature of established Green Belt Land is to identify important areas where development would be detrimental to the surrounding population and the area as a whole. This proposal is not inline with the National Planning Policy Framework (NPPF) and I do not believe that Warwick District Council have demonstrated sufficient 'exceptional circumstances' to gain an exemption to build on this Green Belt Land. The Preferred Options paper does not, in my opinion, provide sufficient evidence under NPPF to permit this development.

The council has identified land to the east of Europa Way (A452) and south of Heathcote towards Bishops Tachbrook that would provide suitable alternatives and I ask why these have not been included in the Preferred Options paper? The current Preferred Options policy of 'distributing development around the District' is not part of the NPPF.

I also believe that development in this area will represent 'the thin end of the wedge' towards coalescence of the urban areas of Leamington Spa and Kenilworth. It is recognised good planning policy to avoid such coalescence. I also believe that the development of a Northern Relief road in these current financial circumstances is a necessary but expensive byproduct of this proposed development and such a level of public money could be spent better on the redevelopment of existing Brownfield Sites and change of use.

Overall, I strongly object to this proposed development.

as local residents, living in the Milverton area of Leamington Spa since 1982, we appreciate, and are privileged to enjoy, the amenity of the Green Belt land which the council propose to develop North of Leamington.

We would like to express our extreme objection to the proposed new Local Plan to destroy this Green Belt land. Whilst we understand there may be a need for development, although little reliable evidence for this has been presented, we strongly object to the proposed development for the following reasons:

a) The National Planning Policy Framework requires "Very Special Circumstances" before such development should be considered, However, the fundamental aim of Green Belt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.

b) The Government's National Planning Policy Framework requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development. According to Warwick District Council the "special circumstances" are that there is nowhere else for the homes to be built. However, in the "2009 Core Strategy" (the previous plan adopted by Warwick District Council) land south of Leamington (not in Green Belt), was identified and is still available, for development. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure (roads etc) to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the town centres.

c) Therefore, the previous plan (the 2009 Core Strategy) is direct evidence that there are alternative areas for development other than the Green Belt and that the "special circumstances" put forward by Warwick District Council are wrong. It is not clear what has changed since 2009.

d) Warwick District Council argues that the land in the South of Leamington is not as attractive to developers because concentration of development in that area may result in the developers making less profit. Consideration of the developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt, and indeed calls into question the motives and modelling assumptions used to underpin the argument for new development. The public has a right to be reassured that those in local government with the power to drastically alter the fabric of a community are truly independent, and have no interest, direct or indirect, personal or professional, in who the developers are, or how much profit they might make.

e) The proposals ignore Warwick District Council's study of the Green Belt land at Old Milverton and Blackdown, which concluded that these areas had high Green Belt value

f) 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 countryside from encroachment, to preserve the setting and special character of historic towns and to assist urban regeneration by encouraging the recycling of urban land. The Greenbelt land identified for development in the Preferred Option does carry out these purposes and its development would therefore be contrary to the NPPF.

g) The proposals will reduce the" Green Lung" between Leamington and Kenilworth to less than 1 1/2 miles encouraging the merger of these two towns and their loss of independent identities.

h) The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, riders, and cyclists, ourselves included. It provides a countryside environment close to the centres of Leamington and Warwick.
Both the proposed building development and the "Northern Relief Road"
would substantially reduce the amount of land that is available to be enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park land would detract from, rather than enhance its value.

i) Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. It contributes greatly to the character of the area. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.

j) Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. No matter what the planners say, and no matter what 'modelling technique' or assumptions they use, A452 traffic will be a nightmare at peak times

k) Building nearly 3000 houses north of Leamington will simply increase the congestion.

l) The dual carriageway will have a detrimental effect on the picturesque northern gateway to Leamington and southern gateway to Kenilworth.

m) A "Northern Relief Road" (budgeted cost £28m) is not required.
Traffic flows tend to be north to south rather than east to west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns.
If the development does not go ahead the road will not be required.

n) A "Northern Relief Road" will form a natural barrier and encourage further development in the green belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.

o) If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road".

p) The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick who make the area an attractive place to live, deliver diversity and make it possible to shop without owning a car. Further "out of town" shopping will take trade away from the Towns.

q) There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton at a time when the nation's future food policy is questionable

r) Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.

s) Warwick District Council has presented a preferred plan rather than consulting on options, making a mockery of the 'consultation process'.
No options have been presented for consultation, and it would appear that some of those involved have already made up their minds, at a time when they are supposed to be listening to residents' concerns. Are developers' concerns about profits more important?

Please will you ensure that our objections are noted and considered during this period of consultation, and addressed specifically during your deliberations on the future shape of this historic area. We are trusting you to make the right decision for the area, the residents, the community and the local environment. A bad decision will be impossible to put right and all of our children and grandchildren will pay the price.

An era of austerity dictates that profligacy can no longer be tolerated. Spending constraints are a
necessity with budgets at all levels. The following comments are submitted to address this particular
aspect.
Significant development opportunities have been neglected in favour of a financially wasteful
scheme. It has been nigh impossible to find the logic for the planning decisions made. Glossaries
and Source References in the published material appear to have been 'lost in translation'; and public
access to detailed Planning and Survey documents is limited.
No objective audit of Housing Need (quality and quantity), appears to have taken place. Equally
lacking is an audit of Existing Development Opportunity, including canvassing and incentives for
Windfall Sites offered up for consideration now or for release within the next 15 years. If demand
for these new houses is a fiction, then they will blight the area and depress market values generally
for the whole of the District. Added to which Employment Opportunities cannot be guaranteed for
the budgeted influx of additional people.
In South Leamington, we have the near perfect basis for a 'Transport Hub', based on the existing
Railway Station. Similarly, there is a 'Commercial Hub' already in existence immediately adjacent
to the 'Transport Hub' extending to the Warwick Gates development, just begging to be extended
and developed. So why have Planners shied away from exploiting these remarkable assets and
advantages ?
The selection and use of large areas of Greenbelt land for development is irresponsible, being
contrary to accepted National and Local policy. 'Very Exceptional Circumstances' have not been
demonstrated, nor can they. Once this land has been developed it is lost to all for ever, depriving
those living in the District, of a much loved green lung and offering opportunity for quiet, peaceful
recreation in an attractive environment close to Leamington Spa. This unacceptable sense of
impending loss is not confined to those living in the two parishes or those adjacent to them !
Large areas of the best local Agricultural Land, in a very sensitive area, have been selected for
development regardless of the ultimate consequences, they include :
a)
The loss of land devoted to Food Production.
b)
Irreparable damage to the local ecosystem, comprising the watershed to this loop of the Avon.
c)
Reduced separation between Leamington Spa & Kenilworth and the loss of separate identity.
d)
The present attractive gateway to North Leamington Spa will be significantly diminished.
The Social, Economic & Environmental losses incurred by developing this land far outweigh the
gains, particularly when it is perfectly clear that there are realistic and preferable alternative
development options, - but see later.
It is generally acknowledged that World demand for food fast approaches the tipping point, where
demand is set to exceed supply. This can only accelerate under the influence of Global Warming,
Climate change and the detrimental effect on Weather Systems. This in turn introduces the
circumstances leading to significant international conflict. It follows that UK food production must
be stepped up and be geared towards greater self-sufficiency. This is the only way to avoid serious
food shortages the like of which most cannot contemplate and which few UK residents, alive today,
have experienced.
At least one thriving Farming Business will be seriously damaged and its viability put at risk.
Further loss of Greenbelt land is threatened, as the planned development unfolds identifying sites
for the supporting commercial development, new road systems and infill. This is only hinted at in
the Local Plan, but it is an inevitable consequence. This further encroachment on Greenbelt land
could destroy as much Greenbelt land again.
Two road developments are contemplated, both of which are unnecessary and will achieve little.
The dual carriageway proposed for the A452, can only transfer congestion from one place to
another, slightly more quickly. The proposed new Northern relief road (additional to the A46 ), can
only realistically be used preferentially by those living in the houses comprising the proposed new
development in Blackdown and South of Old Milverton Lane.
Although the planners state the cost of this exercise will fall to the developers, an ambiguity is
apparent signifying there will be a cost over-and-above that met by the developers, which can only
fall ultimately on Rate Payers; this element has not been quantified. The allowance for the Northern
Relief road of £28m seems unduly small bearing in mind the problems faced in driving a road
through a large area prone to flooding, together with the construction of a new bridge over the
Avon and probably a new bridge over the Railway (or significant re-enforcement of the existing
bridge). The additional unknown costs will inevitably fall to Rate Payers.
The most important financial/economic consideration is that despite the recently established
comprehensive infrastructure South of Leamington; it is now proposed to develop North of
Leamington which will involve the construction of new roads and a whole new infrastructure to
cater specifically for the 1,980 houses intended. This is an extravagance which cannot be justified.
Infrastructure includes the major services, Water, Gas & Electricity, Sewers, Roads, Rail, Canal,
Recreational & Faith facilities, Schools, Supermarkets, Restaurants, Public Houses, etc. All are
successful and well established in South Leamington and in many cases lend themselves to
expansion and development. How can it be sensible to duplicate much of this North of the town,
only to exacerbate the existing traffic and parking congestion by encouraging unnecessary cross
town interaction ?
Access to major road and public transport networks seems to have been largely ignored in deciding
where to develop. Access to the M40 and Rail Network looms large in any sensible planning
decision. The Mainline Rail Stations and Coach Services have seemingly been ignored. Housing
and Workplaces (requiring large work forces) ought to have been considered for location within
walking/cycling distance of Leamington, Warwick, Warwick Parkway and Hatton Railway Stations.
All this emphasises the imperative to develop South, East and/or West of Leamington, even if solely
for the one consideration of access.
It will not have escaped notice that Windfall Development opportunities within the towns and
villages have been ignored. They appear to have been 'airbrushed' out of existence. There are
significant areas of Whitefield & Brownfield sites available. There are areas of prime redevelopment
opportunity constantly offered up. The old Fire Station, the old Ford Foundry,
redundant schools, the many empty shops constantly referred to in the local newspaper as a disgrace
and a blight on local communities. Past Planning decisions in this and other towns have resulted in
most town shopping centres becoming a ghost of a previous existence through the enabling of 'out
of town shopping centres'. So why not re-populate town centres, at basement, ground and above
ground level ? Flats over shops have long had an appeal for the young and those relying on public
transport. This way of living is accepted as 'normal' in London and other major towns and cities.
If it is seen as particularly desirable to have the major part of the new development largely in one
piece, for community identity, sharing infrastructure costs, services etc. The Prince Charles inspired
'Poundbury Development' urban extension to Dorchester offers a useful model. What is wrong with
building a 'Royal Poundbury' style extension' to Royal Leamington Spa ?
There are two natural sites for such a development. One to the East, between Radford Semele and
Cubbington; another to the West, between Warwick Parkway and Hatton Stations. Achieving this
requires the application of objective contemporary problem solving for planning decisions fit for the
longer term; and with the Environment, People & Communities, for once, given the consideration
they deserve, rather than pandering to the wishes of Developers, Architects, Planners and Politicians
who so rarely live in the houses they cause to be constructed for others to inhabit.

I write to register my views on Warwick District Council's Preferred Options for its Local Plan published for public consultation on 1 June 2012. In particular I wish to record my objection to the proposal to redraw the green belt north of Leamington to permit the construction of:
 1980 dwellings,
 out of town shopping facilities,
 light industrial units,
 schools
 park and ride facilities
 changes to the road network to cope with the increased traffic resulting from this development including the proposal for a "Northern Relief Road"
in the parishes of Old Milverton and Blackdown.
I have no doubt that there is a shortage of housing in the Country and that Warwick District will continue to expand, creating further need for housing and employment. However the current proposals are ill conceived and have no regard for the Council's previous planning policy. This policy was to direct expansion to the south of Leamington and Warwick where it has already invested in the necessary infrastructure and employment opportunities to support growth.
The elected Tory party majority has stated that its political ambition is to "spread the pain" of growth around our Towns. Such an ambition cannot be supported by sound planning policies and contravenes the National Planning Policy Framework which requires there to be "very special circumstances" to permit the development in the Green Belt proposed in the Preferred Option for the Local Plan.
National Planning Policy Framework requires "Very Special Circumstances"
 The fundamental aim of Green Belt policy as set out in the Government's National Planning Policy Framework is to prevent urban sprawl by keeping land permanently open.
 As well as "very special circumstances" The Government's National Planning Policy Framework requires the harm caused to the Green Belt by the development to be outweighed by the benefit of the development.
Holly Cottage
Old Milverton
Leamington Spa
Warwickshire
CV32 6SA
Email Jmlander@aol.com
Telephone 01926339112
 From the various public meetings that I have attended, Warwick District Council's argument appears to be that the "very special circumstances" are that there is nowhere else for the homes to be built.
 However, in the "2009 Core Strategy" Warwick District Council identified land south of Leamington (not in the Green Belt), as being suitable for development. This land is still available. The assessment performed by Warwick District Council shows that this land is easier to develop and already has a substantial amount of infrastructure to support the development, and the new residents who will live there. It is close to the M40 and there are existing employment opportunities South of Leamington as well as existing out of town shopping facilities and good access to the Town centres.
 The 2009 Core Strategy is direct evidence that there are alternative areas for development other than the Green Belt and that the "very special circumstances" put forward by Warwick District Council are invalid.
 Warwick District Council argues that if the development is concentrated in a few geographical areas (for example to the south of Leamington) that lack of choice will depress demand for the houses. No evidence is offered for this statement. I have spoken to developers who do not support this argument. They point out that similar sized developments have been delivered in the past. They also state that in practice the development will be phased over 15 years, it will not be delivered by a single construction company (land will be on sold to different developers) and that competition, choice and demand will be created by different areas of the sites having different characteristics.
 Warwick District Council's argument about very special circumstances also ignores a fundamental economic fact that need for houses and demand for houses can be equalised by price. If the new houses are priced correctly demand will satisfy the need for houses. In taking the decision to create demand for house by building in the Green Belt north of Leamington, Warwick District Council is helping to maintain land owners' and developers' profits. Consideration of the land owners' and developers' financial gain is not a "very special circumstance" to permit unnecessary development in the Green Belt.
 The Preferred Options quite correctly makes much of the need to provide affordable housing and sets the requirement for 40% of the homes on new developments to meet the need for affordable housing. The Preferred Option is to build 45% of the new homes in the Green Belt. This land will probably be more expensive to acquire and together with the probable higher demand for houses in the Green Belt will result in these homes costing more. The Preferred Option to build in the Green Belt does not therefore support the preferred option for 40% of the new homes to meet the need for affordable housing.
The Green Belt
 The National Planning Policy Framework sets out five purposes for Green Belt 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.
 The proposal to develop in the Green Belt in Blackdown and Old Milverton contravenes each of these five purposes:
o It encourages urban sprawl
o It reduces the "green lung" between Leamington and Kenilworth to less than 11/2 miles encouraging the merging of these two towns
o It encourages encroachment the countryside
o It will destroy the setting and the special characteristics of Kenilworth and Leamington each of which has great historic interest
 The Preferred Options ignore Warwick District Council's Joint Green Belt Study of the land at Old Milverton and Blackdown. The Study concluded that the land at Blackdown was not suitable for development and that the land at Old Milverton was only worthy of further study because "there were no other towns to the north, from which the Green Belt would provide protection from encroachment [and] there were other physical barriers to the wider open countryside." This conclusion on the land at Old Milverton has ignored the resulting coalescence with Leek Wooton and Kenilworth.
Recreation Value of Old Milverton and Blackdown
 The land at Old Milverton and Blackdown is enjoyed by many walkers, runners, riders, and cyclists. It provides a countryside environment close to the centres of Leamington and Warwick. Both the proposed building development and the "Northern Relief Road" would substantially reduce the amount of land that is available to be enjoyed and have a detrimental impact on the ambience and hence the amenity value of the land. Turning some of it into a maintained park land would detract from, rather than enhance its value.
 Old Milverton is one of the last surviving villages close to Leamington that has not been absorbed into the greater conurbation. If the proposals go ahead it is only a matter of time before it is also absorbed by Leamington.
Proposed New Roads
 Turning the A452 between Leamington and Kenilworth into dual carriage way will not help traffic flows. At peak times the delays on the A452 result from commuters wanting access to the Town centres.
 Building nearly 3000 houses north of Leamington will simply increase the congestion.
 The dual carriage way will have a detrimental effect on the picturesque northern gateway to Leamington and southern gateway to Kenilworth.
 A "Northern Relief Road" (budgeted cost £28m) is not required. Traffic flows tend to be north to south rather than east to west. The road will serve no purpose other than to take new home owners quickly on to the A46 and to jobs and shopping opportunities away from our Towns. If the development does not go ahead the road will not be required.
 A "Northern Relief Road" will form a natural barrier and encourage further development in the Green Belt up to this new road. It will need to be built across the flood plain (at considerable cost) and will violate an important nature corridor along the River Avon.
 The A46 already effectively provides a Northern Relief Road.
 If the proposed development is concentrated in the South of Leamington there is an existing road network that could be upgraded at considerably lower cost than the £28m allocated to construct a "Northern Relief Road". The resultant savings could be used to enhance other services such as improvements to Warwick Hospital.
New Out of Town Stores
 Warwick District Council's vision is to make "Warwick District a Great Place to Live, Work and Visit". A key element which already makes Warwick District a Great Place to Live, Work and Visit is the number of independent retailers and the pleasant and unique "feel" that this gives to our High Streets.
 The proposed "out of town" retail operations will be another blow to independent retailers in Leamington, Kenilworth and Warwick as further "out of town" shopping will take trade away from the Towns.
 More out of town shopping and the A452 dual carriage way between Leamington and Kenilworth will detract from the uniqueness of our Towns making them like any other in the UK and deter visitors.
Loss of Agricultural Land
 There will be a loss of a significant amount of high quality agricultural land in Blackdown and Old Milverton.
Number of Homes included in the Forecasts
 Warwick District Council has added nearly 1400 homes to the number that it anticipates will be required so as to include a "buffer" in the forecasts. If this "buffer" is removed from the forecast there is no need to include the land at Old Milverton and Blackdown in the proposals.
 Insufficient account has been taken of potential windfall sites in the forecasts. The model used to calculate the number of houses required appears flawed by using average data over recent years for demand rather than projecting on the basis of the current downward trends.
Alternative sites
 If the requirement is to "spread the pain" of development around Warwick and Leamington why is the preferred plan to concentrate development on a north, south axis rather than east, west? There are two sites west of Warwick that have been identified which are not in the Green Belt but are not included in the Preferred Options.
 In the 2009 Core Strategy land was identified to the west and east of Radford Semele outside the Green Belt. I understand that the land east of Radford Semele has been rejected in the current Preferred Options because of gas pipe lines. Why do the gas pipe lines rule out the entire site for development when the building constraints only prevent construction within 100 metres of the pipelines? Surely these resulting corridors could be used imaginatively to encourage wild life or as cycle routes.
 The area around Grove Farm to the south of Leamington (not Green Belt land) was included in the 2009 Core Strategy. I understand that this has been excluded from the Preferred Options because there are concerns that it would lead to coalescence with Bishops Tachbrook (also not in the Green Belt). The 2009 Core Strategy proposed an area of restraint to prevent coalescence with Bishops Tachbrook which could still be introduced. If preventing coalescence is so important why is Warwick District Council encouraging development in the Green Belt north of Leamington when one of the main purposes of the Green Belt is to prevent towns merging? It just does not make any sense.
Conclusions
The areas identified for development in the Preferred Options for the Local Plan issued by Warwick District Council simply fulfil the political aspirations of the majority of the Council's members to "spread the pain of the development". The Preferred Options are not based on sound planning principals. Very Special Circumstances to permit 45% of the development in the Green Belt and in particular in Old Milverton and Blackdown cannot be demonstrated. There are other suitable sites for development which are not in the Green Belt. The building of a new "Northern relief Road" and turning the A452 into dual carriageway will not address any of the existing traffic congestion. Developing the Green Belt in Old Milverton and Blackdown will deprive the community of an area of countryside close to Leamington and Warwick that is used by many for recreational purposes. The area of Green Belt between Leamington and Kenilworth is particularly important because it provides a narrow "green lung"between the two towns, preventing their coalescence and preserving their identities. It should continue to be protected. I therefore urge Warwick District Council to reconsider its Preferred Options to develop this area.

See attachment

The Town Council of Royal Leamington Spa broadly welcomes the Plan, and below gives a more detailed response on particular items of the Plan. We expect to incorporate our vision for Leamington Spa into a Plan for the Town in due course.

Delivering Growth (PO1 & PO3)

We welcome the broad location of growth. We agree that an annual average increase of 600 new homes for the next 20 years is a reasonable and fair target. Many of the Wards in the Town are already densely populated, and we note that the Plan anticipates some growth in these areas.

Affordable housing (PO5)

We approve the requirement that 40% of new homes on developments of 10 or more dwellings, and 5 or more dwellings in the rural areas, should be affordable housing.

Mixed communities (PO6)

We approve the option for a mix of housing, and note that strategic sites will include Extra Care Housing. We believe in a balanced and mixed population and welcome families and single people in all our Wards.

Whilst the Town Council is proud of the diverse population in Leamington, we would request the District Council introduce a policy to restrict the number and density of Student Houses and Houses in Multiple Occupation to ensure that they do not adversely impact on the character of neighbourhoods to the detriment of family households. The Town Council requests close involvement in the input into the policy on mixed communities.

We would also welcome developments that demonstrate a more imaginative provision for students, that are not simply converting existing family housing.

Economy (PO8)

We welcome the proposals to ensure a wide range of employment. We particularly support the regeneration and enhancement of existing employment areas.

The Town Council believes that the Local Plan needs to encourage the continuing growth of the already successful Computer Games industry and the further development of Silicon Spa as the primary UK centre of excellence for the industry. The Local Plan also needs to support further growth in the innovative automotive industry much of which is based in the District or on the edge of the District as this is likely to provide future employment in the Leamington and Warwick conurbation.

Retailing and Town Centres (PO9)

We welcome the support for Town Centre retailing and a Town Centre first message. We believe that the `Town' includes the whole town, and that developments should be considered in the area south of Regent Street, in the Parade and in Old Town.
The Town Council believes that we should promote and support Fair Trade initiatives.

We are committed to strategies that promote the town for retail provision, leisure, entertainment and eating establishments. We can promote our parks and green spaces as important attributes of the Town Centre.

However, we see that `shopping' also includes local shops. The Town Council would prefer there to be a policy on where supermarkets should be located, and that local communities should be consulted about any new proposals for supermarket development.

Historic Environment (PO11)

We welcome the intention to protect the historic environment. We see that this includes the historic areas of the Old Town, and would be pleased to work with the District Council in listing the historic assets, and reviewing the Conservation Area. We are pleased to note the District Council's encouragement of regeneration of appropriate sites within the historic environment. We strongly affirm that the historical integrity of the area is threatened by sex entertainment establishments and oppose any such establishment, which we see as an inappropriate development.
The Town Council supports the Blue Plaque scheme, and the Guild of Guides Walks.

Climate Change (PO12)

As a Transition Town, the Town Council welcomes the intention to include a policy on climate change.

Transport (PO14)

We support the option to minimise the need to travel, and to promote sustainable forms of transport. In addition to the proposals in the Plan, we believe that a higher priority should be given to cycle provision, and to ensuring that all new developments encourage ease of access by bicycles between areas of the District. This includes cycle lanes and provision to park cycles.

Residents should also be encouraged to travel by bus for work and leisure with the encouragement of more quality bus routes into and across Leamington.

Encourage the co-ordination of different forms of transport to encourage more residents to travel by foot, bus, train and bicycle.

Green Infrastructure (PO15)

We welcome the intention to protect and enhance the assets as identified in the Plan. We are pleased to see the introduction of "Green Wedges" as an alternative to areas of restraint.
We would also be in favour of consideration of a policy that considers garden preservation. We support greener neighbourhoods through our tree planting scheme, and through our support of Allotment Societies.

Culture and Tourism (PO17)

We support the intention to develop this appropriately and would welcome opportunities to share ideas on promoting the cultural facilities of Leamington. We believe there is scope for improving the visual impact for visitors to Leamington who arrive by rail or canal.

We are proud of the assets of the Town and are committed to maintaining them as welcoming and friendly venues for residents and visitors.


ADDITION

Evening Economy

The Town Council is concerned that the District Council's Policy on the Evening Economy has not yet been completed and so is not available for consultation. The evening economy is important to Leamington, but unless it is carefully considered it can produce public dangers, so it is important to the Town that there is a well-considered policy in place that takes account of the needs of residents, visitors, the businesses and public safety.

Thank you for your email of 1st June 2012 re the above subject. The Councillors of Baginton Parish Council
have considered the Preferred Options documentation. We have also attended the WRECF meeting of
28.6.12 and the WDC Proposed Development Forum of 2.7.12. We have debated these issues at various
meetings. We have also attended the Gateway Developers presentation at Baginton Village Hall of 19.6.12
where we gained written feedback from many concerned residents.
This letter sets out our opposition to the Gateway proposals, as presented to residents on 19.6.12, being
included in the Local Plan Preferred Options. It also puts forward our preferences regarding housing need for
the area based, on our current Parish Plan. Whilst the majority of the proposals are satisfactory, in our view,
we are alarmed and concerned by tentative proposals to include the "Gateway" in the proposals, as
illustrated in the Preferred Options documents. We write asking you to consider all our comments below
when making your judgement:-
1. BPC oppose Preferred Options 8.15, 8.18 and 8.42 abstracts of which are in Appendix 1 of this
letter. BPC opposes the inclusion of the Gateway shown in Map 3, an abstract of which is shown in
Appendix 2 of this letter. The Gateway proposals are not appropriate development and should not
be included, for reasons as set out below.
2. The NPPF calls for Protecting the Green Belt in section 9. See abstracts of section 9 in Appendix 3
of this letter. Baginton Parish borders with Coventry City. There is a vital need to prevent the
unrestricted sprawl of Coventry into Rural Warwickshire, safeguard the countryside from
encroachment and preserve the setting and special character of our village, with its Roman Fort,
Castle and Grade 1 listed church amongst other things. The gateway proposal is contrary to these
fundamental requirements of the NPPF. The development encroaches on previously undeveloped
Green Belt fields which provide a vital buffer between rural Warwickshire and Coventry City. It is
essential that this buffer remains. BPC believes that WDC have an ideal opportunity to prevent the
urban sprawl of urban Coventry into rural Warwickshire. WDC should not therefore support the
Gateway project, which must be removed from the Preferred Options and local plan. The
development is in the protected Green Belt with no very special circumstances to justify its
existence. The openness of this Green Belt land must be maintained.
3. The environmental effects of the Gateway proposal have not yet been considered and there are
many reasons why such a proposal is unsustainable development adversely affecting the
environment and contrary to the requirements of the NPPF. There is no need for such a
development, which should be omitted from the local plan.
4. The proposal significantly affects the nationally significant Highways Agency Tollbar improvement
scheme; the affects which need to be clearly annotated in the local plan.
5. The Gateway includes a "smart card" system for allowing Baginton residents access to Rowley
road, but with no details of how this would be run.
6. It is noted the large industrial units are envisaged to have 24/7 operations, yet the environmental
effects of 24/7 HGV operations on local rural and other communities has not been considered.
7. The proposals are unsustainable as they fail to comply with fundamental tests in the NPPF. The
proposals are to develop Green Belt land but with no very special circumstances to warrant such
development. It is both necessary and essential for WDC to consider all other developments with
extant planning permission in the wider area. There are many such developments in the locality and
which are suited to developments of this nature, e.g. (but not limited to) the huge sites at Ansty and
Ryton, both with infrastructure already in place. Preferred Options, section 8.42 (Section 8.33 of the
draft Local Plan) specially refers to the Coventry Gateway project, it specifically states 'To
demonstrate that there are not any other preferable and suitable sites'. The above clearly
shows that there are alternative sites available with extant planning permission within the subregion,
and further afield, which provide more than adequate development opportunity, so there is
no need for this development. It is essential that the Local plan includes a requirement to review all
existing developable land in the sub-region and further afield, to ensure the proposals are robust.
BPC demonstrates that there ARE other preferable and suitable sites, so the Gateway should be
excluded.
8. There is no need, either economic or otherwise, for the Gateway proposals to be included in the
local plan. There is no case for releasing land in the Green belt for the Gateway development.
9. The development to the north of the A45, in Coventry, can be developed without destroying the
Green Belt to the south of the A45, providing 4000 jobs for the benefit of the region. There is no
need for the Gateway development south of the A45.
10. The provision of "up to" 14000 jobs is inaccurate and misleading. Given that 4000 of the 14000 jobs
quoted are for development north of the A45, within boundary of Coventry, already with planning
permission granted to another developer (Whitley Business Park), it is wholly inaccurate for the
Local Plan to headline up to 14000 jobs. Of the remaining 10,000 jobs, it is highly likely that these
will not be newly created jobs, but in the main taking jobs form elsewhere in the sub region and
further afield. These jobs can and should be created using the vast acreage of sites in the sub
region, and nearby, which are already available, or have infrastructure already in place, or have
extant planning permission, or which are otherwise far more suitable to gain planning permission.
The local plan should quote a realistic level of job creation, within WDC only, accounting for all
other sites.
11. The closing of the Bubbenhall Road and Rowley Road to the general public will destroy the many
local rural businesses which thrive in Baginton Parish, e.g. Baginton Village Store, Hong Kong
House, Smiths Nurseries, Russell's Nurseries, Oak Farm, The Old Mill, The Oak Pub, British
Legion Club and many others. Each would be adversely affected and forced to close with the loss
of jobs, adversely affecting the local sustainable community, contrary to the NPPF. It is absolutely
essential that the Bubbenhall and Rowley Roads be maintained as a pubic right of way with the
present alignment between Baginton and Bubbenhall, to maintain the sustainability of local rural
businesses hence comply with a fundamental aspect of the NPPF.
12. BPC are also concerned that the provision of a new road west of the runway could be put into a
deep cutting which would pave the way for future runway expansion. It is absolutely essential that
the Bubbenhall Road be maintained as a pubic right of way with the present alignment between
Baginton and Bubbenhall, to prevent the Airport from runway expansion in the long term. See old
proposals from September 2002 in Appendix 4 of this letter. BPC acknowledges this is not part of
current proposals but BPC are most concerned that the proposed Bubbenhall Road alterations
could facilitate the opportunity to allow such development in the future. This must not be allowed to
be facilitated, by ensuring the Bubbenhall Road stays as it is and the proposed alterations shown
on the Preferred Options are omitted from the emerging Local Plan.
13. The documents presented do not adequately correlate the requirements of the NPPF with the
proposals for the Gateway. The proposals are not therefore robust in the view of BPC, so the
proposals should be omitted.
14. There is an excellent "Green Infrastructure" opportunity to maintain the undeveloped green belt
green fields which lie to the South of the A45 and which will be adversely affected by the Gateway
project. Instead of the Gateway WDC should give consideration to developing this area under the
Green infrastructure scheme. This will have the advantage of ensuring that the surrounding areas,
such as Baginton Parish, do not suffer from urban sprawl and maintain important opportunities for
Flora and Fauna to flourish. The planted buffer zone to the urban sprawl proposed for the Gateway
is insufficient compensation for the loss of the undeveloped green belt green fields which presently
act as a natural buffer between urban Coventry and rural Warwickshire. It is also far to close to the
Lunt Roman Fort. The Gateway should be omitted from the Local Plan.
15. BPC are very concerned that the Preferred Options summary leaflet makes no mention of the
Gateway development, only showing "highway improvements as per abstract from the summary in
Appendix 5 of this letter, which are as per Map 5 of the preferred options.... This is
misrepresentative of the developer's intentions. The public are not therefore being afforded the
opportunity to see the true extent of the proposals in the summary leaflet, so are not being afforded
the opportunity to comment. This must be rectified by modifying the summary document to include
the developer's true intentions. These are not highway improvements but will destroy public
highway rights of way which are essential for the prosperity of the many rural businesses which
thrive in this area and which will be destroyed by the Gateway development. These are not
improvements but will serve to develop a huge area of green belt land and create urban sprawl,
contrary to the principles in the NPPF. It is essential that these proposals be omitted from the
Local Plan
16. The 12.3.12 WDC map entitled "unrestricted natural and green corridor greater than 2Ha" doesn't
show the green space south of the A45 which forms a natural barrier between Coventry and
Warwickshire, and is undeveloped Greenfield Greenbelt land protecting Baginton from urban
sprawl. The map should be amended, the area recognised as such and the area not allowed to be
developed.
17. Councilors believe that the Gateway proposals, by a private developer who also owns the Airport
and who is also past and proposed Chairman of the Local Enterprise Partnership promoting the
development, are foisting an unwanted and unnecessary development on Baginton village which
will ruin this rural village community, destroy essential Green Belt and destroy its local amenities
and businesses. The quality of life of Baginton and Bubbenhall residents will be significantly
adversely affected by the Gateway proposals. The proposal is against resident's basic human rights
under the Human Rights Act, due to the traffic and operations noise from huge warehouse logistics
development which will run 24 hours per day, seven days per week, with especially adverse effects
at night and weekends. Cllrs anticipate significant HGV traffic movements all night which will be
particularly disturbing to residents.
18. The Gateway development in not sustainable compared with other nearby developments with
extant planning permission, which are sustainable.
19. The proposed smart card access system for local residents and businesses is impracticable and
unworkable, with no one willing to operate it, certainly not Baginton PC. It is understood alternatives
are under consideration but based on what BPC are aware of at this time these proposals are
damaging to the village and must not be allowed to proceed.
20. The proposals put into jeopardy the construction of the Highways Agency Tollbar Island proposals
due to commence early next year. The proposals will not facilitate major improvements to the road
network not already covered by the HA proposals, but will only add to the traffic in this area.. In
addition, the proposals will only add to the traffic in this area, so will not facilitate improvements
over and above what is already proposed by the HA, so the statement must be removed from Para
8.33 of the draft.
21. It is noted from the presentation on the Local Plan by WDC of 28.6.12, at Baginton Village Hall, that
there is 23 hectares of business development land proposed within WDC boundaries separate to
that of the Gateway. Noting that many commercial premises within the sub region, and slightly
further afield in Solihull, lie empty and unused at this time, the additional 23 hectares of business
development land is more than sufficient to satisfy the need for economic growth without the
Gateway project. There is no need for the Gateway project and this must be omitted from the
proposals
22. BPC believes it is entirely inappropriate for WDC to support the C&W Gateway proposals, which
are against the fundamental principles of the NPPF, adversely affects the environment, adversely
affects Parish residents human rights to peace and quiet, will destroy rural businesses based in
Warwickshire, will develop on high quality green field Green Belt with no very special
circumstances, will create urban sprawl and which will jeopardise industrial development elsewhere
in the local area which already has planning permission or has been previously developed and will
destroy the openness of the area, amongst other things. The Gateway should be removed from the
Local Plan
23. Councillors believe there is a clear conflict of interest between the LEP, which we understand is to
be once again chaired by the Owner of both development companies, Sir Peter Rigby, and the
broader requirements of the residents of WDC. BPC Cllrs reinforce the need for WDC to be
independent and not compromise its integrity through the forced will of a developer who is intent on
ruining our unspoiled corner of rural Warwickshire for financial gain. It is wrong therefore to refer to
the LEP within the Local Plan.
24. WDC should modify the proposals to state that its preferred option is to utilise to the maximum
capacity all sites in the sub region with extant planning permission prior to developing any further
site on Green Belt Land. WDC should review all existing developed land within the sub-region. It is
vital that WDC explores and justifies the case for releasing land within the Green Belt when existing
Brownfield and other sites with extant planning permission exist within the sub region remain underutilised
and unoccupied.
25. BPC observes that the Gateway proposals do not protect the character and scale of the village, nor
the openness of the rural countryside around the village, so should be omitted.
26. BPC has already gained written feedback from almost one hundred residents, all of whom believe
the Gateway proposal is damaging to Baginton and there is no justification for ruining the Green
Belt. All wish to see the Green Belt protected. It is essential that WDC takes account of the wishes
of all local residents and excludes this development from the local plan.
27. All the above demonstrates that the Gateway site, which is stated in 8.18 as being "identified as a
site of regional importance for employment to serve the regeneration needs of the Coventry and
Warwickshire sub region" is fundamentally incorrect, fundamentally unnecessary and fundamentally
against most requirements of the NPPF, so should be omitted from the local plan.
Regarding housing policy, Baginton has a Parish Plan and requests that the deliverables in this document be
accounted for by WDC in formulating the Local Plan. In particular please note the below comments:-
28. BPC supports modest sustainable increases to housing in accordance with our letter L075A to
WDC of 8.1.12, a copy of which is enclosed as Appendix 6. This is based on the output from the
Baginton Parish Plan. The Local Plan should include opportunity related to small scale sustainable
development of this nature, to retain the nature and character of the village and help to support the
many local rural businesses in the village. Please note in particular that in all cases any housing
shall be wholly in character with the village, be sympathetic to the amenity of existing
properties/people and shall not interfere with the Green Belt. BPC opposes the Gateway
development on the Green Belt to protect the rural nature of our village, to protect the openness of
the area and to protect the surrounding area from urban sprawl.
29. BPC objects to the classification of villages generally. The Local Plan must not dictate the type of
housing development to villages, but rather should take into account village desires under the
Localism act and in the case of Baginton, our Parish Plan. In this respect we again ask WDC to
account for our letter L075A as point Nr 28 above.
In conclusion, BPC consider that the proposed gateway is entirely inappropriate and ill considered
unsustainable development, contrary to fundamental requirements of the NPPF, with no need given the
significant size and number of underutilised employment creating developments which already exist with full
planning permission in the Coventry and Warwickshire sub region area and further afield. There are no very
special circumstances to develop on the Green Belt, rural businesses need to be protected, urban sprawl
must be prevented and the openness of this Green Belt land must be maintained.
BPC oppose all Gateway development south of the A45 and recommend that the Gateway be omitted from
the Preferred Options and excluded from the Local Plan, with any development limited only to that shown to
the north of the A45, which is within the boundary of Coventry City Council, utilising Ansty, Ryton and other
existing suitable sites for any economic development over and above the 23 hectares already allowed for
within the Preferred Options and emerging Local Plan. Housing policy should follow our recommendations in
Appendix 6 herein.
Please confirm you will consider all the above and confirm you will omit all aspects of the damaging and
unsustainable Gateway development from the emerging Local Plan, within the boundary of WDC.

At a recent Parish Council meeting, The Chairman and Councillors of Leek Wootton & Guy's Cliffe Parish Council discussed the Local Plan. Their views are below -

The Parish Council are particularly concerned with the following proposals in the draft Local Plan:

1) [PO16] We are opposed to any Village Envelope and Green belt boundary changes within Leek Wootton.
It is felt strongly that this creates a significant erosion of the boundary and development protections in our area, and it is contrary to the recently adopted Parish Plan.

2) [PO1] We believe that the basis upon which projections of future population and housing needs are not realistic or supported by proven evidence, and that the housing development plans for Warwick District should be much smaller than those proposed.

3) [PO4] The proposal for 30-80 new dwellings in Leek Wootton is contrary to our Parish Plan (fully backed by residents survey responses) which states that any large scale development is precluded and individual new property proposals possible only within the current building envelope.

4) [PO14/PO15] The proposed 'Leamington Northern Relief road' will unavoidably cause excessive environmental damage, having to cross a railway line, river and a flood plain.

5) [PO1/PO14] The large developments proposed in the surrounding area particularly Kenilworth will inevitably increase significantly the traffic through Leek Wootton unless these developments are kept to a more manageable size.

scanned letter

See Attachments

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We are writing to object to the proposal for 3,330 new houses in Warwick. In objecting we refer to the National Planning Policy Framework which "aims to strengthen local decision making and reinforce the importance of up-to-date plans".

Population Growth

The NPPF states that there should be a clear strategy "taking account of the needs of the residential and business communities".

Why has the number of 10,800 new homes (up to 25,000 more people) been proposed which is the same number as proposed in the Core Strategy and was strongly resisted by Warwick District Council at that time? The West Midlands Regional Office was vehemently criticised by WDC for producing these flawed and untenable figures. Your figures do not comply with WCC population figures and are therefore unreliable. A 40% increase in Warwick's population over 15 years is clearly unsustainable and will cause immense damage to the character of the County Town. Migration from other areas into Warwick's more attractive green environment has produced most of the population growth. The provision of more houses will encourage more migration and Warwick will no longer be an attractive area. The new Plan should cater for LOCAL needs not migration into the area. You have included figures to cover an increase in students but they should be housed near the Universities not in the District, especially in south Leamington. Increasingly high concentrations of students in certain areas is an issue of concern.

Regarding your assumptions on the demand for housing, given that more than 50% of national population growth has been from immigration over the last two decades, and the government has publicly stated it wishes to greatly reduce this future net immigration, why is Warwick District planning for an even greater level of growth over the next 15 years, than has been experienced in the recent past? Warwick District population has increased by 12% since 2000, which is approximately twice the rate of increase for Warwickshire, twice the national average increase, and over three times the increase for West Midlands. Warwick has had its fair share of development over the years with major estates at Warwick Gates and Chase Meadow (with further development allocated), Hatton Park, along the Myton Road and many other infillings. This is far greater than other areas in the District and history has shown that the necessary infrastructure has never been put in place. The NPPF (48) states that Local planning authorities may make an allowance for windfall sites in the five-year supply". 1,224 properties have planning permission or a planning brief at the moment and yet you do not appear to have taken these into consideration. This would equate to a two-year supply of houses. We do not believe our authority has identified and brought back into residential use the 300-400 empty houses and buildings (NPPF 51) to the extent they should have done.

We believe that the only motivation for WDC producing such figures for demand is the income that will benefit WDC in New Homes Bonus, rent, rates, council tax monies etc.

Brownfield Sites

The NPPF (111) states "Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land) provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land."

So why are we not making it a priority to develop brownfield sites first and regenerate poorer housing in urban areas? The Ford Foundry site is a prime example of revitalising an eyesore of a brownfield site to vastly improve the area and bring it back into good use. There are many more examples of brownfield sites in Warwick District which could be regenerated.

Gypsy Site

We suggest the land adjacent to Junction 15 of the M40 might be a suitable site. There is little nearby existing housing, but a public bus service and good road access

Green Belt

The NPPF (79) states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence."

An incredible 37% of the 11,000 homes proposed for Warwick District are to be built on the land south-east of Warwick, covering nearly all of the green space between the Banbury Road, Greys Mallory, Europa Way, Myton and the Technology Park. This would mean estates more than three times the size of Warwick Gates, Woodloes Park or Chase Meadow!

The NPPF (76) states "By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances". "Once established, Green Belt boundaries should only be altered in exceptional circumstances." (NPPF 83) Yet your reason for allocating development on Green Belt is that "there is nowhere else to build" (your quote at the Warwick Society Meeting).

NPPF (88) states "When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.." The exceptions given in NPPF 89 and 90 do not apply in your proposed Local Plan. Our Green Space is already designated.and we are objecting to this scale of development which will undoubtedly impact negatively on the character of Warwick and the quality of life of existing residents. Why are we facing urban sprawl rather than the housing being spread equitably around the District as you stated was your aim? The previous Core Strategy stated that 90% of the population live in the urban areas and 10% in rural areas. Yet in the new Plan less than 10% of housing is proposed for villages, some of which, such as Barford, would welcome more homes including low-cost housing to build up sustainable communities with schools and facilities and meet the need for affordable rural housing. Those that grew up in the villages and wish to remain there would then have the opportunity to do so. We would propose that at least another 1,000 could be spread around the villages and the number proposed for Warwick reduced.

The area to the west of Europa Way was identified as an area of restraint at the time of planning the Warwick Technology Park. It was put forward as an untouchable green buffer zone to separate Warwick from Leamington Spa to prevent the two towns becoming one urban sprawl. The District has 85% green belt but 45% of this is to be built on, thus reducing the gap between conurbations. The green space threatened is valued rich agricultural land, essential for food self-sufficiency, environmentally precious landscape with many wildlife habitats and biodiversity including badger setts and also prevents coalescence which you declare is one of your aims. Our existing green space provides open space, sports and recreation and such land, including playing fields, should not be built on!

Alternative Sites

The previous Core Strategy identified several other sites with potential for housing. Local villages where there are good transport links and the potential to improve road access should be developed rather than the urban fringe development of Warwick. The Warwick Parkway area provides a first class rail link. Hatton has a station and easy access to the A46 and Barford has immediate access to the M40 and A46. Two other areas of potential for large scale housing provision are Radford Semele and Lapworth which already have infrastructure to cope with further development, with good public transport, roads and a railway station.

This in turn would mean much smaller developments around Milverton and Warwick would therefore be required. Although you state that there are three gas lines near Bishops Tachbrook. I can see from the map that there is an area to the west which could take some housing whilst avoiding the gas lines. There are other areas which were identified in the Core Strategy options which have not been considered this time, such as the A46 corridor and further development at Sydenham. The commercial units at Sydenham have mostly closed and been boarded up and would offer an ideal brownfield site for development.

Yet your reason for allocating development on Green Belt, against the National Planning Policy Framework is that "there is nowhere else to build". This argument is totally flawed and I would expect the Inspector to find this Plan unsound if only on this issue.

The NPPF (17) states that planning should be "empowering local people to shape their surroundings."

Why has this amount of housing been proposed for South Warwick when the previous consultation on the Core Strategy produced a 97% response in overwhelming opposition to housing here (700 objecting to the Europa Way, Gallows Hill and Banbury Road area.. Why were those results not heeded when you devised the new Plan? These plans do not reflect the aspirations of the community as the Government intended in the Localisation Act.

 
Flood Risk

The NPPF (94) states that "Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk". Also "Local Plans should take account of climate change over the longer term, including factors such as flood risk....." and (NPPF 99) "When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure." We already have existing green infrastructure to mitigate against water run-off and flood risk but you are proposing to build on it!

The NPPF (101) states "The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test." There are other available sites as already stated. "A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall." (NPPF 102) You have not carried out a Strategic Flood Risk Assessment before allocating these sites for housing.

Europa Way and an area to the south of Gallows Hill are in flood zones and at significant risk of flooding, yet housing is proposed in Flood Zone 1, adjacent to Zones 2 and 3. Areas at risk of flooding have always been designated areas of restraint but you are dispensing with these. More concrete on green fields here which currently soak up heavy rainfall must increase water run-off and impact on the areas of Warwick which already suffer from flooding, especially around Myton Road and Bridge End. This is contrary to NPPF 100 "Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere." The previous Core Strategy decided that this area may not be needed for development in the future being an area of restraint and the worst area for infrastructural needs. Development is not necessary in these areas of flood risk and should be avoided, certainly not put into the first phase for building. Home-owners would also face being turned down for insurance in postcodes where there is flood risk. This problem will possibly increase next year when the agreement between the Government and the Insurance Association ends. The Portobello development, built on a flood plain, is a prime example where many of the apartments are still unsold. This area you have designated for building is vital for flood alleviation and should not be built on at all. At the very least it should be the last designated site.

Density

Garden Town suburbs sound admirable but naiïve when you look at the number of buildings proposed and the impact on the environment. This concept did not materialise in Warwick Gates or Chase Meadow and developers will build at high density for increased profit margins. 1,100 houses were first proposed for Chase Meadow and now it is to be 1,600. WDC has no budget for tree maintenance and developers cannot be relied upon to carry this out, as we have seen in other recent developments. After 14 years Chase Meadow still has unadopted roads, only just received its link road to the local school and the prospect of a community centre for sports provision and social interaction. Developers will not be persuaded to build at 30 units per hectare and there is no means of insisting on this. This is just a red herring in our opinion, as are green wedges since you admitted that where these are proposed, you will be reliant on private landowners to permit their development. Once again, funding for this would be dependent on developers' contributions and these monies, being in short supply, would be diverted for other more essential infrastructure.

Why are we allocating housing for the Coventry Gateway project? It should be up to Coventry Council to provide for this. They should also provide more dwellings for Warwick University students which would free up hundreds of dwellings (including Station House with over 200 student flats) in the South of Leamington to private affordable starter homes and family homes. WDC have recently been forced to change their planning policy because of the problematic increase in HMOS in the District.

Infrastructure

The NPPF (17) states that strategies should "deliver sufficient community and cultural facilities and services to meet Local needs". Also (NPPF 162) "Local planning authorities should work with other authorities and providers to:

* assess the quality and capacity of infrastructure for transport, water supply, wastewater and its treatment, energy (including heat), telecommunications, utilities, waste, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demands and

* take account of the need for strategic infrastructure including nationally significant infrastructure within their areas."

Yet you confirm that infrastructure will not be put in place before building commences but that you hope that infrastructure will be provided from developers' contributions, whilst admitting that this may not raise enough to cover escalating costs of new roads, bridges, schools, extra health provision, policing, fire service, community centres etc. If left to developers, history has shown this may not happen. Infrastructure needs will then be prioritised and some areas may miss out. You have admitted that infrastructure proposals will be prioritised and there will be a cut-off point when the money runs out. We have seen no architects' proposed site plans showing each area with all the necessary infrastructure in place. You have provided no idea of potential costs at all. You have provided no results of studies at all. Warwick has already lost its police station and fire station, roads are completely congested at peak times, schools are drastically oversubscribed and have no places (particularly Myton which is the catchment area), the hospital is at breaking point and cannot cope with the load, having day surgeries and evening clinics to clear backlogs and lack of parking leads to innumerable late attendance for appointments, and the police haven't a clue how they can cope with more communities. Utilities such as water, sewers, electricity provision will have to be provided at escalating massive cost.

CIL

The NPPF (175) states "Where practical, Community Infrastructure Levy charges should be worked up and tested alongside the Local Plan. The Community Infrastructure Levy should support and incentivise new development, particularly by placing control over a meaningful proportion of the funds raised with the neighbourhoods where development takes place."

You have not provided information on these charges at all. We do not believe that there will be anywhere near the amount of funding available from CIL to cover the above extra infrastructure needs, especially new roads, bridges, schools and hospital.

 
Air Quality/Traffic

The NPPF (17) states that the Plan should "support the transition to a low carbon future" and contribute to "reducing pollution". Also "Local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions." (NPPF 95)

The NPPF (17) states that policies should "recognise town centres as the heart of their communities and pursue policies to support their viability and vitality". (30) "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion". Also (NPPF 124) "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."

The traffic congestion that Warwick already suffers will increase by a possible 6,000+ extra cars from extra South Warwick housing alone, let alone the increase from 10,800 new homes, bringing with it increased pollution in areas where air quality is already over the limit. The Warwick District Air Quality action plan 2008 identified the entire road network within Warwick town centre as exceeding maximum NO2 levels as set out in the Air Quality Regulations (England) (Wales) 2000. Air quality remains in breach of these regulations and will become toxically high with the 27% increase in traffic volume resulting from the Local Plan preferred options. There is no management plan to address these levels. The County Council admitted that air quality will suffer as carbon emissions will increase in surburban sprawl. You admitted that you did not know how the carbon emissions could be reduced by the 20% currently necessary. It therefore seems incredible that the large-scale housing developments on the edge of Warwick are suggested with a likely 40% increase in the town's population, over 15 years. This will inevitably add to the congestion and air pollution; so why is it in the plan on this scale?

The NPPF (34) states that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised." "A key tool to facilitate this will be a Travel Plan" (NPPF 36). All developments which generate significant amounts of movement should be required to provide a Travel Plan". We have not seen such a Travel Plan.

Myton Road, Banbury Road and Europa Way are all highly congested with long queues or at a standstill at peak times including the Town centre and often emergency vehicles cannot negotiate a way through, even via the pavements. If the closed Warwick Fire Station were to be relocated at Queensway, their vehicles would experience increased problems and response times would be worsened. There is a suggestion that Europa Way could be widened but this would exacerbate bottlenecks when the traffic reaches the roundabouts. The County say they can mitigate but not contain the resulting increase in traffic and admit there are places where congestion will worsen.

Historic Environment

Pinch points at bridges cannot be alleviated and the 300-year old Castle Bridge already carries 20,000 vehicles per day and cannot sustain an increase in traffic without threat to its very structure. We should be trying to reduce this traffic to prevent the bridge collapsing, not increase it. The NPPF (112) states "As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional." The precious historic and listed buildings in Warwick are being damaged by traffic vibration and pollution and this problem will only worsen. Increased commuting traffic must not be funnelled through Warwick's congested urban centre. Danger to schoolchildren and others is currently problematic on our roads and will be exacerbated near schools such as at Woodloes and Aylesford/Newburgh.. We are given no concrete proposals for new roads, only ideas. A North Leamington relief road suggestion could cost £50million+ and the idea that the A452 could be routed to the Fosse - one of the most dangerous roads in the County is preposterous. The proposal to create a dual carriageway along Europa Way to alleviate the traffic queuing off and on to the M40 will have the opposite effect at the eastern end of Myton Road with the addition of Morrisons and the proposed trading estate and Aldi supermarket all exiting out on to the double roundabout system. The present Plan does not address these traffic problems sufficiently and should be "refused on transport grounds where the residual cumulative impacts of development are severe (NPPF 32).

Conclusion

You state that in 2026 Warwick District will be renowned for being "A mix of historic towns and villages set within an attractive rural landscape of open farmland and parklands that have developed and grown in a way which has protected their individual characteristics and identities....." In our opinion this could not be farther from the truth.

The above comments demonstrate that this Plan is seriously flawed. It is not specific to the needs or the character of this area and the necessary infrastructure is not deliverable. We believe the Planning Inspector will declare it unsound. It cannot be justified as "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence" and it is not "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework." (NPPF 182)

This Plan should be completely revised taking account of the above, specifically reducing the numbers of housing proposed for Warwick.

I look forward to your response to the comments contained in this letter.

Dear Sir,
My preferred option plan consultation feedback:
GREEN BELT - National Planning Policy Framew9rk requires "very special circumstances"
The Green Belt covers only 13% of the area of England. This preferred plan is for 10,800 dwellings
and 43% of land used will be green belt. How can this be justified when there is still plenty of white
field land available south of Leamington? Presumably the "very special circumstances" come into
effect when the 57% development on white fields has been used. This growth is scheduled to take
15 years at a constant annual rate of 555 houses per year. 57% of 15 is 8.55. So it will be eight and a
half years before these "very special circumstances" (ie. white field sites are filled and green belt is
needed) comes into effect. By then another plan will have been made!
I disagree strongly with any relaxation of the green belt which is there to stop conurbations merging.
This plan will leave less than 1 Y, miles between ~Kenilworth and Leamington.
Why does Kenilworth need to expand? It has always been in the past a much smaller town than
Leamington and Warwick and mushroomed massively in the 1960s, and also in the 1980s when
Knights Meadow and the Lindisfarne Drive estates were built. Why should we let this happen again
to keep pace with the other towns? Councillors tell me that the Green Belt is strangling Kenilworth.
This is precisely its purpose. We should be grateful that our town has these safeguards in place to
protect it.
770 dwellings equates to about 1770 people which is almost a 10% increase in Kenilworth's
population in an area which is quite detached from Kenilworth and is not likely to make its
inhabitants feel a part of the community. The town centre should be in the middle of the town. Far
too much development is on the east side and it should now be the turn of the west, if the Green
Belt has to be sacrificed, where there is no risk of it merging with other towns and which would be ~
short walk to the centre of town without cars needing to be used.
THICKTHORN.
How was the Thickthorn site chosen?
Surely not because it abuts the A46 which is noisy both day and night. Was a site visit made to see
just how noisy it will be for all the inhabitants? Were decibel readings taken at various points up the
hill to ascertain the suitability of this site? The noise is particularly bad on a hot sunny day with the
prevailing south-west wind. What about HS2 whose boom will be heard at Thickthorn as it passes 18
times per hour in both directions on the EAST side? This estate will be on the flight path of Coventry
*
International Airport where there is no restriction on night flights and jets scream right over the
proposed development land and at a very low level on their way to Baginton as they have to avoid
the Birmingham flight path, (which is also noisy) as this is the crossover point of the two flightpaths.
It would be a very selfish decision to commit people to a life of misery with all this noise even
through double glazing. This is not the same scenario as the Woodloes where houses abut the road,
which at that point is 4 lanes instead of 6, where there the A46 is the other side of the natural sound
barrier of Primrose Hill. At Thickthorn noise is impossible to stop owing to the contours of the land
which is a basin causing the noise to be trapped and sweep up the hill towards dwellings. The noise
is incessant both day and night. It is an ideal location for the sports fields which are already there,
where people can go away at the end and not have to endure it 24 hours a day. Office buildings
along it will not dissipate the sound.
TRAFFIC
Having 1200 cars discharging from the estate each morning will be a nightmare and cause even
longer queues up Birches Lane and into Glasshouse Lane. It will be a worse effect than the horse fair
there every day of the year. Updating St Johns gyratory presumably means traffic lights which will
cause long tailbacks into the town centre as they have priority under the give-way scheme.
I cannot understand how a dual carriageway between Kenilworth and Leamington will help as all the
traffic will have to funnel in at either end and will just result in 4 lanes of slow moving traffic instead
of 2. Creation of bus lanes will in any case limit traffic flow to one lane in each direction to speed up
a bus every 10 minutes if you're lucky, and nothing will be gained in terms of traffic build up.
There are no points wide enough along Glasshouse Lane for the junction of a spine road, as the
corner with Rocky Lane is on a dangerous bend. In any case, Glasshouse Lane is a unique and
attractive feature of 1930s period landscaping, a Kenilworth gem, which should be preserved and
which junctions along its length will destroy.
NUMBERS
Where do these figures come from for 10,800 houses?
It is in the interest of the District Council to have as many new houses as possible, as they receive 6
times the Council Tax from the New Homes Bonus Scheme for every new dwelling completed and
more than that if they are affordable housing.
This plan is not led by suitability but the interest of landowners to sell off their land for housing.
These are not sufficient grounds for this massive increase in population concentrated in a small area
as the plans make little use of rural area development. Lots of villages need regenerating. Radford
Semele has had no growth since the 1960s and has a school in place already. It has good transport
links to the M40, Fosse Way and Leamington Station and IT IS IN A WHITE FIELD ZONE. If such a large
number are needed, they should be put in the South Leamington area on white field sites as
Leamington already has all the amenities (parks, department stores, nightclubs, cinemas) jobs to
support it. This is a Warwick District Council plan not a Kenilworth plan and there are plenty of other
places where housing could be built.
WHAT ARE YOU, OUR TOWN COUNCIL, DOING?
Old Milverton and Blackdown Parish Council are sending a formal objection on behalf of the area.
Where is the formal OBJECTION from our town council on behalf of its 23,000 residents? Our town
should be protected from losing its identity.
Offices are not needed -lots are available to rent. St Johns next to Jet garage, old Pottertons site.
Industrial land is not needed as Archery Fields is empty with fountains and wasteful landscaping at
the entrance.
You cannot make people live and work in the same place. These ideas don't work. Kenilworth is not
an industrial town and should not strive to be such.
THE A46 WAS PLACED WHERE IT IS TO KEEP IT AWAY FROM THE POPULATION.
Why were these ideas devised secretly without asking the people who voted for you their opinions
before consulting the district planners?
CONCLUSION
Population figures should be challenged.
Green belt should be protected.
Consideration of the effect on the HEALTH of people living alongside a motorway with NOISE and
POOR AIR QUALITY owing to constant fumes and directly under a flight path with NOISE due to very
low flying aircraft should be made.