PO16: Green Belt

Green belt boundaries should not be changed. This plan will lead to the eventual linking up of Warwick, Kenilworth and Leamington Spa. That is why the Green belt boubnaries were defined where they are in the first place.

Quoting "16.3 Green Belt boundaries should only be altered in exceptional circumstances..".
This is not an exceptional circumstance, it is some entirely predictable growth. The Green belts were established entirely to stop what is proposes "the nibbling away" by council's too lazy to seek alternative solutions.

Apply the proposed process for cat 3 villages to all green belt.

In general we fully support the maintenance of the Green Belt status and accept the proposed reductions as they relate to settlements. We would suggest that at least the amount removed is added as an increase to the total Green Belt in the WDC area and preferably that the whole of WDC, with the exception of settlements, should become Greenbelt to minimise the amount of development "sprawl" which is occurring.

I would like to register my objection to the current plans to build on green belt land. in my opinion Warwick District Council has failed to demonstrate that there are any exceptional circumstances that would allow you to build on green belt land. As you are well aware, the National Planning Policy Framework states as follows:
http://www.communities.gov.uk/documents/planningandbuilding/pdf/2116950.pdf

83. Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or
review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long
term, so that they should be capable of enduring beyond the plan period.

87. As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.

88. 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.

I would suggest that you look again at the plans for the Green Belt which should be held sacrosanct. Once the principle of development on the Green Belt has been breached, there is absolutely no protection against the future arguments by developers who would want to snatch "just a bit more". They will use our faliure to protect the Green Belt in 2012 as justification for doing so. Whilst not wishing to argue that I therefore support building on the green fields south of Leamington, I put the Green Belt principle first.

I suggest that the council redoubles its efforts to find brownfield sites to build housing on. I am horrified that instead of housing, the old Ford site is to become yet another supermarket. This space could have provided many social rented homes. It is not hard to identify other brownfield sites which should be considered first.

I particularly object to the building on the green belt north of Leamington on the basis that the infrastruture for roads and access from motorways is all in the South. If you allow developments in the Green Belt north of Leamington, it will lead to a totally unnecessary northern relief road, eating further into the green belt land.

The consultation at 7.19, states that the sustainability appraisal of the options showed that focusing development outside the Green Belt had clear advantages associated with the provision of sustainable transport options and reducing the need to travel. Thus the proposed allocation of Green Belt land fails on the review criteria of paragraph 84 of the Framework. Equally it is clear that development of non-Green Belt land to the South of Leamington does meet the review criteria both in offering more sustainable transport options and in using locations outside the Green Belt.

Furthermore, it is not at all clear that the need for housing developments is as high as you make out. I would point out that the most recent housing development on Pottertons fields has not all been sold. This indicates that there may be a problem with the projections of future demand and in particular whether developers will be allowed to take a "if we build it, they will come" approach which is not an approach that is practical with housing. Once built on, the countryside is ruined forever.

I would also point out that there has been an ecological survey by The Habitat Biodiversity Audit Partnership on behalf of the District Council which demonstrates the rich wildlife and ecology of the area. In particular, building on the Green Belt will affect the ability of wildlife to use "wildlife corridors" and the habitat will lose its richness and fail to thrive.

I am writing to register my objection to the development of site identified as East Milverton within the proposed Warwick District Council (WDC) Development May 2012.

Whilst acknowledging the need for additional housing during the period 2014-2029 and the overall approach; the Preferred option in its current form, (i) goes beyond identified housing need at the expense of the
Green Belt, (ii) ignores national planning policy guidelines for development of Green Belt, and (iii) does not recognise other development opportunities that are better suited to development and more consistent with WDC's own stated sustainable growth objectives and evidence base.

Objection 1: Housing requirement.
The New Local Plan (NLP) Preferred options May 2012 Page 19 (7.22) identifies a requirement for 6986 dwellings not including windfall sites over the period of the plan. In its current form the Local Plan indicates
it would deliver 8360 dwellings, equal to an over provision of 1370 (19.6%) dwellings.

Objection 2: Exceptional circumstances and planning conditions for developing the Green Belt have not been met
2.1 As identified in Objection 1, the WDC plan overstates the need for housing development by 1370 dwellings during the period of the plan invalidating any exceptional need for the redrawing of the Green Belt.

2.2 The development of East Milverton does not comply with National Planning Policy Framework March 2012 guideline chapter 9, Paragraph 85, point 6 as it its fails to provide clearly defined permanent boundaries for Green Belt and would enable and likely lead to the future coalescence of Milverton village, which would be in direct contravention of three of the five stated purposes of Green Belt.

2.3 In the event that a policy of limited encroachment/coalescence to encompass East and West Milverton were to be considered, then this too should be rejected. Areas such as land adjacent to Bishops Tachbrook, not designated Green Belt, should be required to be developed prior to any redrawing of the Green Belt under the test of "exceptional circumstances".

2.4 The NLP page 9 (4.11.7) 'seeks to ensure that new developments are appropriately distributed across the district and designed and located to maintain and improve the quality of the built and natural environments, particularly historic areas and buildings, sensitive wildlife habitats and areas of high landscape value'.

In the event that Green Belt land should be required, the current proposal does not rescind Green Belt on a lowest value first basis. East Milverton has been identified as possessing higher landscape value than other deliverable areas in the district such as the Kenilworth sites (K18 & K19) bounded by Glasshouse Lane and Crewe Lane (inc. Woodside Management Centre) where development is also more consistent with the National Policy Framework guidelines and WDC stated Local Plan objectives. These sites however are not included within the proposed Local Plan.

It is essential to pressure the rural character of the Budbrooke villages and ensure that only the current amenities and infrastructure shortcomings are addressed. The area school is at capacity. The residence of this area bought homes here because of the rural character and to change that would inpact on lifestyles here and would be detrimental to house prices.

Baddesly Clinton Parish Council have considered the options and in line with previous observations expressed by Baddesley Clinton Parish Council for PO3, PO4 we as a Parish Council generally support the preferred option for PO16 with carefully considered alteration to some green belt for some villages. We do feel that such infill that may be allowed in category 3 villages (remaining in green belt) should only be undertaken on a case by case basis without a presumption that it would be allowed and that the preservation of the green belt is a very important issue.

Protecting the existing Green Belt from inappropriate development is supported, but it should be noted that the 'Green Belt' was created to protect the area around Coventry from over development and does not extend to the south of the District. In these areas development has generally not been permitted outside the village envelope which has conserved the countryside and maintained a healthy supply of good quality agricultural land

The Green Belt has successfully protected Norton Lindsey without restricting limited redevelopment/new housing on a proportionate scale. Accordingly there is no need to redraw the Green Belt boundary.

Hampton magna and Hampton on the hill should be removed from this. It is essential to preserve current rural character and address the current amenities and infrastructure shortcomings. Please remove from plan.

The Green Belt is a valuable asset to the whole community and building on it is the start of its decline.
Building on the Green Belt will cause the towns of Kenilworth and Leamington to coalesce.

Green Belt Boundaries 16.3,16.10 and NPPF para 85

I note that the boundary of the Green Belt around Kenilworth will be
drastically altered to accommodate a number of the preferred development
options. I consider this a pertinent time to review the boundary as a whole
and remove any inappropriate or ineffectual areas of land from the Green
Belt.

In particular I suggest that the land on the north corner of Crewe Lane and
Glasshouse Lane be removed from the Green Belt. This land is surrounded by
built development or forms part of the domestic curtilage of Reservoir
House and currently serves no useful Green Belt purpose. Furthermore, it
seems to clearly be an area which the NPPF para 85 states when defining
boundaries, should not be included.

If removed from the Green Belt it is likely this parcel with seperate
vehicular access may be regarded as
suitable for a small bungalow style dwelling. This would be commensurate
with a policy of identifying possible windfall sites and using them as a
contribution towards required housing numbers.

This would seem a logical step before further 'genuine greenbelt' is
considered for future development due to satisfying future housing need.

Noted.

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Submission made on behalf of the Hatton Parish Plan Steering Group.
Overall Strategy
The overriding principle of the National Planning Policy Framework (NPPF) is Sustainable Development. When the previous Core Strategy was being prepared, three sites at Hatton Green, which landowners had put forward for development, were dismissed because the general location was considered to be unsustainable. If the area was considered unsustainable then, how does it suddenly become sustainable and where is the evidence to support this change? Indeed, where is the evidence to suggest that housing spread across the district is the most sustainable form of development?
Table 7.2 show approximately 10% of new housing will be in villages, roughly half of which will be concentrated in five villages along the A4177/B4439 corridor - most of which lack the facilities to support sustainable development. Moreover, this will create a corridor of development that will seriously threaten the integrity of the Green Belt. The A4177 and B4439 are also dangerous roads with bad accident records. Potentially another 400 houses will obviously increase the danger, yet the Plan contains no infrastructure improvements to reduce the risks.
We therefore have serious misgivings about the strategic approach to rural areas.
Local Plan Policy PO4: Distribution of Sites for Housing
We object to the inclusion of Hatton as a Category 2 village. In a recent survey for the Parish Plan, 60% of respondents said they are opposed to more housing. We expect the natural reaction will be to dismiss this as NIMBYism, but there are several sound reasons why residents consider this designation to be inappropriate:
1. Hatton has already contributed more than its fair share of housing to the District, with numbers having increased six-fold in the last 20 years, from 140 to 845 units.
2. The 700 new houses at Hatton Park mean the parish now has two distinct settlements, plus a significant scatter of other houses. We now need time to assimilate the massive impact this change has had and develop a cohesive community.
3. Neither Hatton Park nor Hatton Green has the basic facilities needed to support sustainable growth. Hatton Park has a village hall, small general stores and a reasonable bus service, but all children have to travel to school by bus and there is no bus service to the nearest post office or doctors. Hatton Green has a primary school, but this is already over-subscribed and further expansion would only exacerbate the current traffic problems in the village. Otherwise there is a village hall, but only a skeleton bus service with timings that preclude travelling to work by bus. We do not consider these modest, dispersed facilities sufficient to justify designation as a Category 2 village. They certainly don't measure up to the statement in paragraph 7.34 that "a limited amount of development is directed to those villages with a good range of services and public transport to the towns".
4. If the 700 homes at Hatton Park, with their wide range of types and tenures, cannot meet local needs through natural turnover, then it is highly unlikely that 30-80 extra homes, spread over 15 years, will make any difference. Nor is it likely "to encourage new services" as envisaged in paragraph 7.35.
Notwithstanding the above, we recognise that communities cannot stand still and that further development will be required at some stage to sustain the two existing settlements. Indeed, responses to the Parish Questionnaire show that just over a quarter of residents would favour more starter homes, shared ownership or rented homes. Very few, however, would favour more of the larger homes. The issue is how best to satisfy the residents' views.
We do not believe designation as a Category 2 village, with its subsequent implications for the Green Belt, is the best solution.
Local Plan Policy PO16: Green Belt
The Parish Questionnaire shows virtually 80% of residents to be in favour of retaining the Green Belt as it is, though a quarter consider there could be some review of boundaries.
Paragraph 79 of the NPPF says "the essential characteristics of Green Belts are their openness and their permanence". Paragraph 83 goes on to say "Once established, Green Belt boundaries should only be altered in exceptional circumstances" and that authorities "should have regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period".
Taking these statements together, our interpretation is that Green Belts should be essentially permanent; their boundaries, once established (which is the case in Warwickshire), should only be reviewed in exceptional circumstances; and if boundaries are reviewed they should endure beyond the fifteen years of the Local Plan. We question whether the levels of housing being an proposed for Category 2 villages - an average of two to five a year spread over fifteen years - is sufficient to amount to 'exceptional circumstances'. (If all or most were to be built at once however, e.g. very close to our parish at Haseley Manor, then this might constitute exceptional circumstances, but this would almost certainly lead to pressures to release more land.) Because of this we are very concerned that, if village 'envelopes' are created within the Green Belt, the NPPF requires boundaries to be drawn to accommodate expansion beyond the fifteen year period of the current Plan. Notwithstanding the safeguarding provisions in paragraph 85 of the NPPF, we believe this would expose areas to the threat of premature development, which we know from past experience would be extremely difficult to resist.
We certainly believe that creating 'envelopes' for each of the five proposed Category 1 and 2 villages along the A4177/B4439 corridor would fundamentally threaten the integrity of the Green Belt.
In the case of Hatton, with its two very compact settlements, we believe the interests of its residents would best be served by leaving both villages 'washed over' by the Green Belt, leaving any future development to be dealt with as 'limited infilling' or 'limited affordable housing for community needs' in accordance with the NPPF paragraph 89.
Infrastructure
We are surprised that the Plan contains no proposals for improvements to the A4177 and B4439. Both of these roads are extremely dangerous, with the severity of accidents along the stretches at Hatton almost twice the county average (Warwickshire County Council Traffic Accident Statistics pers comm.). Both roads also carry traffic diverted from the M40 and M42 at times when there are incidents on either motorway.
With potentially up to 400 more houses proposed for the five Category 1 and 2 villages along this corridor, the accident risk can only increase and we believe the Local Plan should make provision for infrastructure improvements to minimise the risks.

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Cubbington Parish Council have discussed the issues contained in the Local Plan Preferred Options published by the District Council and wish to make the following comments:
1. There are considerable concerns regarding the proposal to redefine the boundaries of the Green Belt around rural parishes, including Cubbington. The Parish Council strongly oppose this proposal as, potentially, it could result in the loss of large areas of highly valued countryside which have been protected from development for very many years. If it is eventually decided to proceed with this review, the Parish Council would expect to be consulted about any proposals to change the Green Belt locally. At all costs, the Green Belt controlling the use of the land between Cubbington and Lillington, bordered by Rugby Road, Offchurch Road and Welsh Road must be protected.
2. It is understood that 15 to 20% of the Blackdown development site, designated as Location 5 in the Options, comes within the boundary of the Cubbington parish. This could result in up to 230 dwellings being built on this area alone with the balance of 940 dwellings being built on the adjoining area within the parish of Blackdown. The Parish Council anticipate that this number of additional dwellings, with possibly in excess of over 3000 residents, will have a major impact on the local infrastructure and the social, leisure and shopping facilities in Cubbington. Therefore, should this area be approved for development, the Parish Council's view is that they must be involved in the detailed planning and decisions about how the resulting infrastructure levy will be utilised.
3. It is understood that Old Milverton and Blackdown Joint Parish Council will be making representations regarding the development proposals of this land and Cubbington Parish Council support fully the comments they will be making.
4. In November 2009 a report was published by the Warwickshire Rural Community Council on the outcome of a housing needs survey carried out in the parish. This indicated that there was demand for a small number of affordable dwellings to be built in the parish for occupation by people who had family links with other residents in the parish. A scheme was subsequently devised by the WRCC for seven affordable dwellings to be built on an area of land off Coventry Road. To make this scheme financially viable it was suggested that, if necessary, a small number of additional houses should be built for sale on the open market. These proposals have not yet been able to proceed due to funding not being available through the District Council. However, the Parish Council understand that the matter is now being pursued with the involvement of the Orbit Housing Group. The Parish Council believe that this scheme should be reflected in the Local Plan to help ensure that it can proceed.

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I wish to take advantage of the opportunity being offered to local residents to comment on the Local Plan Preferred Options that are currently under consideration by Warwick District Council.
I am a member of Cubbington Parish Council, representing Cubbington North Ward where aspects of the proposal are causing great concern. I should make it clear that, while I am commenting in my capacity as a councillor representing a ward which is directly affected by the proposal, the views expressed below are my own and are not made on behalf of Cubbington Parish Council.
I wish to comment upon Preferred Option PO16 "Green Belt" and, in particular, proposals for two large housing developments on Green Belt land, identified as Milverton Gardens and Blackdown, and to make, as yet unspecified, changes to the Green Belt boundaries around Cubbington in order to allow further housing development around the village. The Blackdown development would extend into Cubbington North Ward and is, accordingly, a direct concern, as is the redrawing of our Green Belt boundaries. The Milverton development would also be likely to have indirect impacts on residents of Cubbington North Ward, in particular in increased traffic flows on roads in the general area.
"For the last fifty years, green belts have acted as one of the best known and most popular planning tools for protecting our countryside. They still command widespread public support. Although we can never know for certain what would have happened in the West Midlands without them it is likely that the geography of the region would be very different - and not for the better. They have preserved sharp distinctions between urban and rural areas, encouraged development in cities and towns instead of allowing it to sprawl outwards, and prevented towns and cities from coalescing and losing their separate identities."
This is the judgement of CPRE West Midlands, as expressed in the Introduction to its June 2007 publication What Price West Midlands Green Belts? (http://www.cprewm.org.uk/GreenBelt%2002.07.07.pdf).
That the CPRE is right in its assumption that the green belt concept "still commands widespread public support" is evident from the reaction that the Council's plans have engendered in the communities of Old Milverton, Blackdown and Cubbington.
Up until now the general presumption has been that new housing development within the Green Belt was "inappropriate" and, as far as I understand it, this policy has been enforced by Warwick District Council. However, the proposals in the May 2012 WDC publication Local Plan Preferred Options appear to signal a total departure from this principle and risk undoing much of the good work of the last fifty years.
Paragraph 80 of national Planning Policy Framework (NPPF) lists one of the five purposes of Green Belt as "to check the unrestricted sprawl of large built-up areas". Map 4 that is appended to the May 2012 document Local Plan Preferred Options shows the proposed housing development sites as ringing the Leamington Spa/Warwick urban area in what appears to be a "text book" illustration of urban sprawl.
Paragraph 80 of the NPPF identifies another purpose of the Green Belt as "to prevent neighbouring towns merging into one another". The Green Belt north-west of Cubbington provides such a buffer between Leamington Spa and Kenilworth. The proposed Milverton Gardens and Blackdown developments will eat significantly into the green strip dividing these two towns.
Paragraph 85 of the NPPF requires local authorities to "define boundaries clearly, using physical features that are readily recognisable and likely to be permanent". The current Green Belt boundary in Cubbington North Ward is the A445, and this seems an appropriate demarcation line being, at this point, a town road with extensive urban development on one side. If the Blackdown development takes place, this demarcation line will become the B4113, which is clearly a country road currently unsullied by development.
Paragraphs 87 and 88 of the NPPF warn against the damage that "inappropriate development" can cause to the Green Belt and that development in Green Belt should only be approved "in very special circumstances". Such special circumstances, we are told, "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". With the exception of certain types of building, which are listed in paragraph 89 of the NPPF, we are told that "a local planning authority should regard the construction of new buildings as inappropriate in Green Belt". New housing is not one of the exceptions permitted by the NPPF.
I have read carefully the "justification" in chapter 7 of Local Plan Preferred Options and feel that this document signally fails to demonstrate the existence of "very special circumstances" that justify large-scale building on the Green Belt. In particular, paragraph 7.29 indicates that sufficient land to satisfy the identified housing needs can be provided without any incursion into the Green Belt. The unique status of the Green Belt should protect it from development when there is an alternative, and this alternative clearly exists.
Also, paragraph 7.32 of Local Plan Preferred Options appears to indicate that an earlier study (Joint Green Belt Study) suggested that the site of the proposed Blackdown development was "not suitable for further study". Why then has it been included in the Preferred Options?
I find it particularly inappropriate to propose the construction of a Park and Ride car park on Green Belt land.
The NPPF defines "sustainable development" as that which meets "the needs of the present without compromising the ability of future generations to meet their own needs". The proposed developments at Milverton Gardens and Blackdown clearly fail this test, as their realisation would clearly deprive future generations of a significant part of the Green Belt protection that the present residents of Cubbington North Ward enjoy.
In conclusion, I find it particularly ironic that Warwick District Council has responded to the threat to our countryside posed by HS2 by rigorously opposing it, taking a prominent role in the 51m alliance of local authorities. Yet this same authority is proposing to inflict damage on Green Belt land that lies within a kilometre or so of the Green Belt land that HS2 will consume. Surely, this is irrational and inconsistent behaviour.

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