Mod 14 - Policy DS15

Development of the green belt land to the north of Milverton does not comply with the National Planning Policy Framework, is not sustainable, is not close to employment opportunities, and is, therefore, inappropriate.
The modifications to the Local Plan propose 250 houses and park-and-ride scheme on the Green Belt in Old Milverton. In addition land for a further 1100 houses, employment opportunities and a railway station is to be removed from the Green Belt and safeguarded for use in the future. The Exceptional Circumstances required by the National Planning Policy Framework to allow this land to be removed from the Green Belt do not exist.
Warwick District Council says that this development is to support Coventry City Council's housing need; although it also states that the safeguarded land could be used in the future to support Leamington's housing need. If this land is to be used to support Leamington's housing need, as has been previously demonstrated and recognised by Warwick District Council, there are no exceptional circumstances to remove it from the green belt. There are other more appropriate and sustainable sites outside the green belt. Exceptional circumstances do not exist to remove this land from the green belt to support Coventry's housing need. There are lower value green belt sites closer to Coventry which on the basis of planning precedent should be used in preference to the land in Old Milverton. The idea that Warwick District Council should promote commuting from Old Milverton to Coventry is ill conceived and bad planning. In practice people who want to live and work in Leamington will not buy houses in Old Milverton.
In general park and ride schemes only work if there is insufficient parking available in a town. There is plenty of parking available in Leamington. The scheme is predicated on a significant rise in parking charges to try and change behavior. The proposed park and ride scheme on the land north of Milverton is too close to Leamington town centre to reduce traffic flows on the A452 and too close to Leamington to make it attractive to users.
The idea that a railways station could be built in Old Milverton is impractical. The railway is in a deep cutting

Mod 14 Objections

Objection 1: Planning Inspectorate Instruction Correspondence Ref PIN/T3725/429/5 regarding Duty to Cooperate has not been met.
The engagement between the six different councils comprising the wider Coventry and Warwickshire Housing Market Area cannot be considered constructive. Specifically Warwick District Council and Coventry Council have not taken sufficient account of available and lower value Green Belt. Doing so would negate the need to remove Miverton from the Green Belt

Objection 2 A lack of consistent approach by Coventry City Council and Warwick District Council shows a lack of strategic cooperation
The Coventry Local Plan states
It should be clarified however that at the current time some of these sites are within the Coventry Green Belt and as such remain constrained by Green Belt policy until such time as the Local Plan is adopted. As such, these sites will not be considered readily available until such time as the land is removed from the Green Belt.
If WDC were to adopt a consistent approach with Coventry City Council then either Milverton would remain outside any consideration for removal from Green Belt, or Green Belt land within Coventry would be included and adopted into the Coventry Local Plan. In any event Milverton should be logically excluded from development if a consistent and cooperative approach were adopted.

The Joint Green Belt Study identifies Parcel RL1 (Milverton) as being of significantly higher value than other Green Belt land. More appropriate Green Belt land including BU3, BE1, BE4, BE5 and N6 in Nuneaton and Bedworth, C6 and LL2 in Rugby, KG3 in Warwick is identified by the JGB as being effectively 'infill' and would be well contained by existing significant features and the landscape.

Objection 3 Exceptional circumstances and planning conditions for developing the Green Belt at Milverton have not been met
As identified in Objection 1, the Coventry City Council has not taken into account available suitable Green Belt land when making its housing availability assessment. The Coventry City SLAA LP53 January 2016 identifies 29 different sites suitable for housing schemes greater than100 units which could provide 10,424 housing units in Coventry alone if taken into account. Considerable evidence exists to show that exceptional circumstances to remove Milverton from the Green Belt not been met and any attempt to do so would risk rejection of the modified Local Plan by the Planning Inspectorate.

Objection 4 Developing East Milverton is not consistent with NLP objective (4.12.4). help the public access and enjoy open spaces...reduce the risk of flooding; keep the effects of climate change (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles.

The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies North Milverton (L07) is a Green Belt site of medium value. Other assessment referred to within the Landscape Character Assessment for Land South of Leamington and Warwick show the North Milverton Green Belt as being of high value, in contrast, for example, to part of the Blackdown site adjacent to Sandy Lane (referred to as WL6a/b in this document and shown to be of medium value). The Milverton site is enjoyed by a wide section of the community, it is an important asset in supporting healthy lifestyles for residents and visitors of all ages - whether it be walking, running or cycling. The public footpath that transverses the site provides a valuable access point from Leamington to the Warwickshire country side and should be protected.

There are strong grounds for environmental concern regarding proposed development of the site.
The Strategic Housing Land Availability Site Assessment for Leamington Part 1 identifies that:
* a part of the site falls within a flood zone 3A and implicitly should not be developed;
* it contains a Water Source Protection Zone and an area of Groundwater Vulnerability, which would require consultation with and permission from the Environment Agency before any encroaching development. We know from a past pollution incident from the Nuffield Hospital, and related correspondence, that the Environmental Agency view this Zone/area with extreme seriousness.
* it would result in the extensive loss of Grade 2 agricultural land which both contributes to a sustainable economy and to the character of the landscape.

The proposed park-and-ride scheme is unsustainable because:
1) There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable;
2) the site is too close to Leamington. It would be better if the site were focused on the A46, which could form part of the Thickthorn development, and so provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry;
3) Much of the traffic using the A452 crosses to the south of Leamington where there are major employers;
4) Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington;
5) Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre;
6) There are a lot of car parks in this area of Green Belt with impervious surfaces, all of which reduce the area's ability to absorb rainfall, and contribute to flooding.
A railway station is unviable because the railway line is in deep cutting in Old Milverton, making construction impractical.

Exceptional Circumstances are required by the National Planning Policy Framework to remove the land north of Milverton from the green belt in order to support stated aim of Mod 14. These
circumstances have not been demonstrated. Coventry City Council has requested neighboring councils assist them in meeting Coventry's housing need by providing land for housing on land adjacent to Coventries boundaries.
The proposed use of this green belt land, on the boundary of Leamington's built up area, does not meet Coventry Council's request for land on the
boundary with Coventry.
The park-and-ride scheme is unsuitable being too close to Leamington.

Leamington Spa is a small town and does not need another Park and Ride in the north. There is one already five minutes drive away at Warwick Parkway. There is also adequate parking in the town.
Worst of all, these sites are on the Green Belt. Park and Ride is definitely not, by any stretch of the imagination "Special Circumstances".
The whole idea is flawed.
1. Sites earmarked are too close to the town centre and will not reduce congestion.
2. There will be no dedicated buses so who is going to pay and wait maybe half and hour for a bus which may or may not take them near their place of work.
3. It will be inconvenient for shoppers who will also have to wait for a bus and will have to carry their shopping on the bus.
4. there are already enough car parks and parking spaces in Leamington.
5. There are already enough car parks in North Leamington with impervious surfaces which contributes to flooding.
This Park and Ri8de will fail, as the one in Stratford on Avon has failed. More Green Belt will have been destroyed, and developers will come in by default.
Maybe that is what you want but we definitely do not.

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical
The consultation has been wholly inadequate with no proper or meaningful engagement on the proposals.
The plan does not take into account the significant effect of the increased traffic on residents and how the new proposals will tackle the increased congestion particularly on Kenilworth Road and Northumberland Road.

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
It is unlikely that people who live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks

I believe the proposed park and ride scheme is unsustainable as I understand that buses will not be dedicated so users will have to time their visits to coincide with the bus timetable - this will not be an enticement for people to use the service.

Also, the site is too close to Leamington. surely it would be better if it was closer to to the A46/A452 roundabout and part of the Thickthorn development. Then it would be providing for more locations: Warwick, Leamington, Kenilworth, Warwick University and even Coventry.

Major employers are based to the south of Leamington and much of the traffic using the A452 crosses to the south.

There is plenty of parking in Leamington Spa so shoppers are unlikely to use the park and ride service.
Oxford has a successful park and ride scheme because there is so little parking in Oxford city centre.

Given the increasing problems with flooding which all the evidence suggests is only likely to get worse we should not be adding more impervious surfaces to this area of Green Belt where there are already a lot of car parks reducing the area's ability to absorb rainfall.

A railway station is unviable because the railway line is in such a deep cutting in Old Milverton so construction would be impractical.

I believe the plan to be unsound because the amendments to the previous draft plan have added land to the north of Milverton to meet Coventry City Council's housing need. This would destroy high quality green belt land unnecessarily when there are much more appropriate sites nearer to Coventry. Housing people from Coventry here will simply add commuting and increase what are already very congested road locally.

I strongly believe that the 'exceptional circumstances' required by the National Planning Policy Framework to remove the green belt land to the north of Milverton have not been demonstrated by Warwick District Council.
People who want to live and work in Coventry will not want to buy houses on land to the north of Milverton that will be much more expensive than sites on the edge of Coventry and therefore not be affordable and thus this development proposal will not support Coventry's housing need which could be met much better locally. Instead of spreading outwards in low rise housing why can't the City build up like London to meet housing need?

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the green belt to be taken into account and those with the least value to be removed from the green belt first. Alongside Coventry City Council Warwick District Council has assessed sites on the edge of Coventry as being of lower green belt value. There are therefore suitable sites with a lower green belt value that should be used in preference to the land north of Milverton and on this basis the plan is not sound.

Not only would the plan get rid of productive farm land it will also permanently destroy with long established wild life habitat. Our development (Vernon Close) backs onto the fields and amongst other wildlife we have owls and woodpeckers in our communal gardens. This will destroy their habitats.

We walk frequently in the greenbelt using the footpaths. These are extremely well used by local people for leisure purposes such as dog walking, running and walking and the plan will destroy an area which is highly valued by local residents and schools who use the area for nature studies.

The plan will also cause the green area between Leamington and Kenilworth to be reduced and set a precedent that risks the two towns joining instead of having a distinctive green belt area that separates them.

The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.

Warwick District Council has not demonstrated the Exceptional Circumstances required under the National Planning Policy Framework (NPPF) for the removal of the land North of Milverton from the Green Belt.
When proposing the removal of land from the Green Belt it's value must, by established precedence, be considered and proper account taken of it. Those Green Belt sites of the lowest value should be removed first. WDC, working with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if it was accepted North of Milverton was a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference.
There are more sustainable sites closer to Coventry which better support it's housing need rather than overflowing in to the land North of Milverton, and reducing the essential "green lung" between Leamington and Kenilworth to less than a mile and a half. Old Milverton Lane/Sandy Lane is narrow, unmarked and dangerous, with an acute bend and narrow bridge over the railway in Old Milverton. Development of the North of Milverton land will only increase traffic with more commuting and congestion, encouraging further road construction, resulting in additional adverse impact on the environment.
Brandon Lewis recently stressed the importance of Local Plans to;-
* provide for sustainable development and it's supporting infrastructure,
* recognise the intrinsic character and beauty of the countryside, and
* take into account all the benefits that an area has.

The estimated housing numbers proposed on the sites already identified within Coventry are significantly lower than could be achieved. Housing densities should be maximised on urban sites to minimise further unsustainable development outside the city and its environs.
In reality people who want to live and work in Coventry are unlikely to buy houses on land North of Milverton and therefore this development proposal will not actually support Coventry's housing need.
Highly productive farming land will be lost together with long established wildlife habitat, and the picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
The residents of local towns will be deprived of an outstanding area which is highly valued and sustainable for leisure, including rambling, orienteering, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
* No dedicated buses are proposed, meaning users will have to rely on the ordinary bus timetable
* The site is too close to Leamington, and would be better located around the A46/A452 junction, thereby providing for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* The A452 carries significant traffic to the major employers south of Leamington.
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington.
* There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the line is only a single track and is in a deep cutting in Old Milverton making construction impractical. It's worth noting the new Ricoh arena station is not providing the service expected.

Warwick District Council has not demonstrated the Exceptional Circumstances required under the National Planning Policy Framework (NPPF) for the removal of the land North of Milverton from the Green Belt.
When proposing the removal of land from the Green Belt it's value must, by established precedence, be considered and proper account taken of it. Those Green Belt sites of the lowest value should be removed first. WDC, working with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if it was accepted North of Milverton was a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference.
There are more sustainable sites closer to Coventry which better support it's housing need rather than overflowing in to the land North of Milverton, and reducing the essential "green lung" between Leamington and Kenilworth to less than a mile and a half. Old Milverton Lane/Sandy Lane is narrow, unmarked and dangerous, with an acute bend and narrow bridge over the railway in Old Milverton. Development of the North of Milverton land will only increase traffic with more commuting and congestion, encouraging further road construction, resulting in additional adverse impact on the environment.
Brandon Lewis recently stressed the importance of Local Plans to;-
* provide for sustainable development and it's supporting infrastructure,
* recognise the intrinsic character and beauty of the countryside, and
* take into account all the benefits that an area has.

The estimated housing numbers proposed on the sites already identified within Coventry are significantly lower than could be achieved. Housing densities should be maximised on urban sites to minimise further unsustainable development outside the city and its environs.
In reality people who want to live and work in Coventry are unlikely to buy houses on land North of Milverton and therefore this development proposal will not actually support Coventry's housing need.
Highly productive farming land will be lost together with long established wildlife habitat, and the picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
The residents of local towns will be deprived of an outstanding area which is highly valued and sustainable for leisure, including rambling, orienteering, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
* No dedicated buses are proposed, meaning users will have to rely on the ordinary bus timetable
* The site is too close to Leamington, and would be better located around the A46/A452 junction, thereby providing for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* The A452 carries significant traffic to the major employers south of Leamington.
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington.
* There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the line is only a single track and is in a deep cutting in Old Milverton making construction impractical. It's worth noting the new Ricoh arena station is not providing the service expected.

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt and to permit the proposed development have not been demonstrated by Warwick District Council ("WDC").

The proposed development of 250 is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton. Therefore this development will not support Coventry's housing need.

250 houses equates to an annual additional build requirement of only 19.2 houses over the remaining 13 years of the plan period. This is a very small number of houses which could be accommodated on other sites. Therefore, the harm caused to the green belt by this development by reason of inappropriateness outweighs any potential benefit.

The proposed park-and-ride scheme is unsustainable because:
* There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
* The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
* Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
* Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
* Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
* The proposal is predicated on a significant increase in car parking charges as an attempt to change behaviour and will have a detrimental effect on the Leamington as a Town Centre.

The "safeguarding" of additional land, North of Milverton, for the development of a further 1100 is also to support Coventry's housing need in the future. Again there are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction. The proposed development is therefore not sustainable.

Again, in practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.

The proposed railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.


WDC has also stated that the "safeguarded land" North of Milverton could be used in the future to support Leamington's housing need. Warwick District Council has previously accepted that the Exceptional Circumstances necessary to remove this land from the Green Belt to support Leamington's housing need do not exist. There are other green field sites that are available, and deliverable which should be used in preference.

The modifications to the Local Plan do not fully address the Planning Inspector's concerns set out in his letter dated 1st June 2015 which include:
* the importance of considering commuting;
* the need to maximise effectiveness;
* a lack of detailed analysis;
* an absence of a clear strateg
* insufficient justification; and
* the overall conclusion that he Local Plan is not positively prepared, justified, effective or consistent with national policy


The land North of Milverton has enormous amenity value. If used for development the residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.

The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.

Highly productive farming land will be lost together with long established wild life habitat.

In total Warwick District Council has agreed to provide land for 6000 houses to meet Coventry's housing need. However the modifications propose that only 2245 of these houses will be close to Coventry. The remaining houses will be located in Kenilworth, Warwick and Leamington. WDC's proposal to encourage commuting (most of which will be by road) on this scale is irresponsible and bad planning.

PARK AND RIDE

Leamington does not need a Park and Ride. There is plenty of parking in the town.
It definitely does not qualify for "Special Circumstances" to destroy the Green Belt.

It will fail.

For reasons set out elsewhere and in particular to Policy DS11 it is not considered that the proposed Strategic Sites have been properly identified through the Plan process. There has been inadequate Community Involvement and the proposed sites are based on a flawed analysis in the Sustainability Appraisal Addendum Report.
It also seems wholly wrong to state at THIS stage that "Proposals for the allocated strategic sites will be approved...." These sites have not been openly debated and it is strongly suggested that suitable additions/alternatives exist.

The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.

In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.

Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.

The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.

Highly productive farming land will be lost together with long established wild life habitat.

The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.

The proposed park-and-ride scheme is unsustainable because:

There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers
Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington,
Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is
because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which
reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

the plan is unsound as it does not take into account the vast areas of brown filed and lower Green Belt value land closer to coventry

the plan is unsound as it does not take into account additional traffic / pollution and stress on over stretched local amenities

The concept of a Park & Ride at Blackdown is flawed: -

- Park and Ride is traditionally located alongside key transport routes. If deemed necessary, the A46/A452 junction is an obvious option. It could serve Coventry, Warwick University, Kenilworth, Leamington Spa & Warwick with dedicated buses
- Leamington Spa has adequate parking, short & long term
- Large expanses of concrete have a significant impact on the flood plain. Currently the surrounding area regularly floods

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington,
Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is
because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which
reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington,
Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is
because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which
reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.



The proposed park-and-ride scheme is unsustainable because:
There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable

The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington,
Warwick, Kenilworth, Warwick University and potentially Coventry.

Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers

Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington

Oxford appears to have the only park and ride scheme in the country which really works and this is
because there is such limited parking in Oxford city centre.

There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which
reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The plan to develop North of Milverton, is unsound.
It is unlikely people who wish to live and work in coventry will move so far away from the community they wish to be part of.
There are more suitable, sustainable locations closer to Coventry.
Requires the removal of valuable green Belt land and would only contribute to an already congested A452.
A Park and Ride scheme located here would be ineffective and unsustainable since the majority of large employers are located to the south of Leamington, whilst sufficient parking exists within the town for shoppers and visitors.

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.



The proposed park-and-ride scheme is unsustainable because:
There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable

The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington,
Warwick, Kenilworth, Warwick University and potentially Coventry.

Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers

Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington

Oxford appears to have the only park and ride scheme in the country which really works and this is
because there is such limited parking in Oxford city centre.

There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which
reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1⁄2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington,
Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is
because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which
reduce the areas ability to absorb rainfall and contribute to flooding
A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
- There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable.
- The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
- Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers.
- Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington.
- Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
- There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding. A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

The EXCEPTIONAL CIRCUMSTANCES required by the National Planning Policy Framework to remove the land North of Milverton from the Green Belt have not been demonstrated by Warwick District Council.
The proposed development is to support Coventry City Council's housing need. There are sustainable sites closer to Coventry that should be used in preference to the land North of Milverton to reduce unnecessary commuting, inevitable congestion and further road construction.
In practice it is unlikely that people who want to live and work in Coventry will buy houses on land North of Milverton and therefore this development proposal will not support Coventry's housing need.
Precedence for releasing land from the Green Belt requires the "value" of potential sites to the Green Belt to be taken into account and those with the least value to be removed from the Green Belt first. WDC, in cooperation with Coventry City Council, has assessed sites on the edge of Coventry as being of lower Green Belt value. Even if development at Old Milverton was acceptable as a sustainable location for development, there are sites with a lower Green Belt value that should be used in preference to the land north of Milverton.
The "green lung" between Leamington and Kenilworth will be reduced to less than 1 1/2 miles.
The picturesque northern gateway to the historic regency town of Royal Leamington Spa will be destroyed.
Highly productive farming land will be lost together with long established wild life habitat.
The residents of local towns will be deprived of an area which is highly valued and sustainable for walking, running, cycling, riding, bird watching and is also used by local schools for educational walks.
The proposed park-and-ride scheme is unsustainable because:
- There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable.
- The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
- Much of the traffic using the A452 crosses to the south of Leamington where there are the major employers.
- Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington.
 Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
- There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding. A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical.

Leamington Spa is a small town which simply does not need a Park and Ride. There is more than adequate parking in town.
Worst of all the proposed site is Green Belt land, and a Park and Ride is not, by any stretch of the imagination, Exceptional Circumstances.
The Park and Ride will fail, as may have in other parts of the country. More precious Green Belt will have been destroyed and the developers will come in by default. Maybe this is what you want but residents, and anyone who cares about our rapidly diminishing green spaces, definitely do not.

The proposed park-and-ride scheme is unsustainable because:
 There will be no dedicated buses, so users will have to time visits to coincide with the bus timetable
 The site is too close to Leamington. It would be better if the site was focused on the A46 roundabout
with the A452, which could form part of the Thickthorn development, and provide for Leamington, Warwick, Kenilworth, Warwick University and potentially Coventry.
 Much of the traffic using the A452 crosses to the south of Leamington where there are the major
employers
 Shoppers are unlikely to use the park and ride when there is plenty of parking in Leamington
 Oxford appears to have the only park and ride scheme in the country which really works and this is because there is such limited parking in Oxford city centre.
 There are already a lot of car parks in this area of Green Belt with impervious surfaces all of which reduce the areas ability to absorb rainfall and contribute to flooding

A railway station is unviable because the railway line is in a deep cutting in Old Milverton making construction impractical

The land is in Green Belt, there is no demonstration of exceptional circumstances. It is illogical to use satisfy a housing need for a town by building houses somewhere different. Even if people are prepared to commute there will be an increased strain on infrastructure.