Mod 14 - Policy DS15

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It is essential that the plan does not return to a scheme involving any development on the North Leamington Green Belt. The Green Belt in this area meets the 5 key roles of Green Belt and is an excellent and well used cultural and exercise related resource. Development in Kenilworth, Baginton and Lillington already take land from this essential Green Belt and further development on it would not be sustainable. It must not be permitted.
I would also like to make the following points:
1. A Joint Strategic Housing Needs Analysis is currently being performed with Coventry City Council. If this review identifies that it is necessary to increase the number of houses above those currently proposed I believe that there is sufficient non Green Belt land to accommodate this additional development.
2. The Revised Development Strategy has a fair distribution of new housing across the District. It is fair because there are still plans for new houses in the Green Belt at Thickthorn and Lillington as well as proposed development in villages.
3. The Revised Development Strategy proposes that most of the new development is located close to where employment opportunities already exist (e.g. industrial parks to the South of Leamington & Warwick) this provides an opportunity for people to live close to their place of work, reducing or eliminating commuting for many people, reducing pollution & improving quality of life. Furthermore there is ample space to build to the south of Leamington as the next nearest town is Banbury.
4. Focusing development in the South, in one broad area, ensures adequate public services can be provided and developed to meet the needs of the new population. These services can be designed to meet the exact needs of that new population and planned within easy walking and cycling distance, minimising traffic congestion. If development were to be more spread across the district public services would have to be developed in an inferior and unacceptable "make-do-and-mend" fashion which would provide poorer levels of service to both existing and new residents in those areas.
5. The Revised Development Strategy provides for improvement to the road network South of Leamington to relieve the existing congestion and to cater for the new development. The transport assessment clearly shows that development in the North would generate more traffic congestion in the district as it would have forced people to travel south to employment land, shopping (e.g. supermarkets) and the M40. Loss of vital Green Belt recreation land would also have resulted in more people travelling by car for recreation.
6. It is possible that mitigation methods may need to be employed in the Southern areas to reduce pollution and congestion but the work needed to do this would be less than for development in the North. For instance putting the country park in the South next to the existing houses, with new housing beyond it, would make the green-park more accessible. It could be crossed by cycle-ways and would act as a green-lung to reduce air pollution.
In conclusion the exclusion of development in the North Leamington Green Belt enables the plan to comply with the NPPF. Any attempt to re-introduce development in the North Leamington Green Belt would be unacceptable and be bitterly opposed as no exceptional circumstances exist; the land is a vital and immeasurable resource for the future of the district and is critical to its future sustainability.
Development in the South reduces traffic congestion and reduces air pollution, it enables better provision of public services and other facilities with better access to the employment hubs in the South.

Removal of green belt land of such high value - geographically, socially and agriculturally, would not be consistent with national policy.
Reasons for my objections are as follows:-
Milverton.
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 want 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:
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 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.
3. Much of the traffic using the A452 crosses to the south of Leamington where there are the 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 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 North of Milverton should remain in the Green Belt. If it is lost, it is gone forever.
The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.
In short:
* There is no viable reason why green belt land of such value north of Milverton should be used to support Coventry City Council's housing need.
* The "Exceptional Circumstances" needed to remove this land from the green belt do not exist. 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, irresponsible and bad planning.

I am writing to object to the provision in the revised draft of the Local Plan to remove about half of Old Milverton from the Green Belt, and subsequently to allow development of the land along Old Milverton Lane, between the Nuffield Private hospital and the railway bridge in Old Milverton.
These proposals are unsound because they do not comply with national policy with respect to the development of land in the Green Belt. Warwick District Council has failed to demonstrate the "Exceptional Circumstances" required to allow land to be removed from the Green belt. During the revision of the draft Local Plan the land north of Milverton was included for development to help meet the housing needs of Coventry, despite the fact that there is land nearer to Coventry, with a lower "Green Belt Value" than the land in Old Milverton. Use of land in Old Milverton to meet the housing needs of Coventry, rather than land closer to Coventry, will lead to higher commuting costs, associated traffic congestion and pollution. Hardly sustainable development, rather ill conceived, irresponsible and bad planning.
The Green Belt has been very successful in preventing Leamington and Kenilworth merging. The proposed development would reduce this green space to less than 1.5 miles and set a dangerous precedent for further large scale development north of Leamington and so leading eventually to the two towns merging and loss of community identity.
Other reasons for keeping the land in Old Milverton in the Green Belt are the agricultural and amenity values of the land involved. The land is productive arable land, while large numbers of people walk (and run) from north Leamington to Old Milverton across the footpaths from Northumberland Road and the bottom of Guys Cliffe Avenue, both during the week and at weekends, providing considerable health benefits to the participants (and some dogs).
Commuters, often crossing the town and going to and from places of employment south of the town, and the daily school run, are the causes of local traffic congestion and associated pollution. The layout of the town precludes major new road construction to cope with the increasing traffic and it is difficult to see how the proposed Park and Ride scheme in Blackdown can help address this problem. There will be no dedicated buses so potential users will have to fit in with the bus timetables, making the scheme unattractive. The decriminalisation of parking offences and the current parking provisions (space and price) have greatly improved the availability of parking for shoppers in Leamington compared with ten years ago, so shoppers will have no incentive to use the proposed Park and Ride scheme.

I believe that Modifications 16 and 14 are unsound because:

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. The costs of houses in the Leamington area will also be higher than in Coventry restricting the viability of people buying houses with the express purpose of commuting to Coventry. This is not the best financial option for the council in helping boost affordable housing.

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.
In short rather than adding value to the area this development will degrade it and create unnecessary pressure on the road network going in and out of Leamington - which is already stretched to say the least!

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
I believe that in order for Modifications 16 and 14 to become sound:

* The land North of Milverton should remain in the Green Belt
* The development proposed on the land north of Milverton should be reallocated to alternative sites closer to Coventry which have a lower "Green Belt" value and are capable of delivering the required housing.
* The road network is already overwhelmed and this whole project will be a stain on the green and pleasant land that is Leamington Spa.

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The Club notes that the Council's draft local plan has identified Kings Hill for the development of 4,000 houses and in doing so it has included the land that the Club leases from Coventry City Council as part of this development.
In reflecting on these proposals the Club wish to state that given the information currently available it opposes the housing development and wishes to remain on its existing location and continue to develop our facilities for the local community. This position is consistent with the PPS and other Policies - specifically Para 74 of the NPPF:
74. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
To this end the Club feels that the Local Plan should more clearly reference the opportunity to develop the community, social and sporting offer to the new population through the development of the Club given the right circumstances. The Club has therefore commented on the modifications to the Local Plan as attached.
We also note the lack of any communication with us concerning your planned development and would expect that we will be included in all future communications regarding this proposed development. The Club wish to work with Warwick District Council, Coventry City Council and all relevant National sports' Governing Bodies to best meet the Club's facility needs now and into the future.
If you have any questions or would like further clarification on any of the information provided then please do not hesitate to contact me.

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Removal of land north of Milverton from the green belt
Allocation of land north of Milverton for development
Mod no. 16 and 14
para. 2.81 and Policy DS15
Policies map H44
The lands proposed for 'development' are currently used for farming and local business.
They are also community grounds. Furthermore, this violates environmental
conservation of the warwickshire greenbelt. The proposed development and removal of the greenbelt is not sound and not in accordance to the democratic will of the Milverton community.
We need to consult the local communities before any 'developments' are made on their grounds. Only local companies should have rights to build/develop on local
grounds because they would be the ones who would know the socio-economic
and even well-being impact of their development. A company who is not local to the grounds being put forward for removal/development has no idea the socio-ecomonic and wellbeing impact that will have on the local community on whose grounds they are developing. The policy proposed is that only a company local to the Milverton area (who know the area and the impact of any developments) should be the only ones with development rights. If they are not local and not aware of the impact of their development they shouldn't have rights to make it. Thank You

Removal of land north of Milverton from the Green Belt
Mod. no. 16
para. 2.81
Mod policies map no. H44
Allocation of land north of Milverton for development
Mod no. 14
para. no. Policy DS15
mod policies map no. H44

The exceptional circumstances required by the national planning policy framework to remove the land north of Milverton form 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 1.5 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 A542, 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 crossed 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 that really works and this is because there is such limited parking in Oxford city centre
There are already lots of car parks in this are 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

Removal of land north of Milverton from the Green Belt
Mod. no. 16
para. 2.81
Mod policies map no. H44
Allocation of land north of Milverton for development
Mod no. 14
para. no. Policy DS15
mod policies map no. H44


The exceptional circumstances required by the national planning policy framework to remove the land north of Milverton form 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 1.5 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 A542, 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 crossed 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 that really works and this is because there is such limited parking in Oxford city centre
There are already lots of car parks in this are 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

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